Text

Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4
	ML16071A137
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	03/03/2016
From:	; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16071A108	List: ML16071A110; ML16071A126; ML16071A132; ML16071A136; ML16071A137; ML16071A140; ML16071A144; ML16071A146; ML16071A147; ML16071A149; ML16071A150; ML16071A152; ML16071A153; ML16071A158; ML16071A160; ML16071A166; ML16071A170; ML16071A174; ML16071A176; ML16071A180; ML16071A181; ML16071A184; ML16071A185; ML16071A187; ML16071A188; ML16071A193; ML16071A195; ML16071A198; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 1 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 2 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 3 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 3; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 6; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 8 of 8; NL-15-1898, Enclosure 5: Vogtle Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 4; ... further results
References
	NL-15-1898
	Download: ML16071A137 (63)
	v • d • e

COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CGI: INITIATING CONDITIONS Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.

Justification:

Site use of terminology differs from NE! guidance.THRESHOLDS NEI 99-01 Rev 6 Vgle 12 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS (I) a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table (see below).(2) a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

(Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWR]* UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

AND c. ANY indication from the Containment Challenge Table (see below).Containment Challenge Table* CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]* If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.(1)(2)a. RPV level less than 181'-10" [TOAF] (63% on RVLIS full range) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table Cl.a. RPV level cannot be monitored for 30 minutes or longer.AND b. Core uncovery' is indicated by ANY of the following:

RE-005 OR 006 >40 REM/hr Erratic Source Range monitor indication UNPLANNED increase in Containment Sump, Reactor Coolant Drain Tank (RCDT) or Waste Holdup Tanks (WHT) levels of sufficient magnitude to indicate core uncovery AND c. ANY indication from the Containment Challenge Table C1.Containment Challenge Table C1 CONTAINMENT CLOSURE NOT established*

Explosive mixture inside containment greater than OR equal to 6% H 2 greater than O...R equal to 13 psig WITH CONTAINMENT Containment PressureCLSResalhd greater than OR~ equal to 52 psig WITH Tech Spec containment

____________________________integrity intact* If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.13 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference

/ Deviation

/ Justification Difference:

Justification:

Difference:

Justification:

Difference:

Justification:

Difference:

Justification:

Difference:

Justification:

Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level. Site specific information provided.

See V9 RPV Level/RVLIS Information.

Site use of terminology (RPV vs RCS) differs from NEI guidance.EAL Threshold (2)b -NEI 99-01 Rev 6 illustrates thresholds in bullet format. Vogtle threshold (2)b illustrates these thresholds using table format. Site specific information provided.

See V2 Rad Monitor Calculations and VI 0 Containment Sump, RCDT, WHiT Reference.

Editorial change -Human Factors consideration.

EAL Threshold (2)b, last bullet, refers to Other site-specific indications of core uncovery.

No Other site-specific indications are used at Vogtle.Vogtle does not use any other site-specific indications of core uncovery than those already identified in EAL Threshold (2)b.Table designator CI assigned to Containment Challenge Table.Editorial change to clearly identify tables within the document.NEI 99-01 Rev 6 Containment Challenge Table identifies an UNPLANNED increase in containment pressure.

Vogtle Table C1 identifies specific containment pressures for specific conditions.

Editorial change to clearly specify conditions when containment is challenged by pressure increase.Site specific information provided.

See VIi11H2 Concentration and V12 Containment Pressure Reference.

14 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~~CS1: INITIATING CONDITIONS

...Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.

Justification:

Site use of terminology differs from NEI guidance.~THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) a. CONTAINMVIENT CLOSURE not established.

(1) a. CONTAINMENT CLOSURE not established.

AND AND b. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level less than b. RPV level less than 185'-4" [6" below Bottom ID of loop](site-specific level). (72% on Full Range RVLIS).(2) a. CONTAINMENT CLOSURE established.

(2) a. CONTAINMENT CLOSURE established.

AND AND b. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level less than b. RPV level less than 181'-10" [TOAF] (63% on RVLIS full (site-specific level), range).(3) a. (Reactor vessel/RCS

[PWCR] or RPV [BWR]) level cannot (3) a. RPV level cannot be monitored for 30 minutes or longer.be monitored for 30 minutes or longer. AND AND b. Core uncovery is indicated by ANY of the following:Core uncovery is indicated by ANY of the following:

RE-005 OR 006 >40 REM/hr* (Site-specific radiation monitor) reading greater than Erratic Source Range monitor indication (site-specific value) UNPLANNED increase in Containment Sump, Reactor Coolant* Erratic source range monitor indication

[PWR] Drain Tank (RCDT) or Waste Holdup Tanks (WHT) levels of* UNPLANNED increase in (site-specific sump and/or sufficient magnitude to indicate core tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

Difference

/ Deviation

/ Justification 15 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference:

Justification:

Difference:

Justification:

Difference:

Justification:

EAL Thresholds (1)b and (2)b -NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level. Site specific information provided.

See V9 RPV Level/RVLIS Indications.

Site use of terminology (RPV vs RCS) differs from NEI guidance.EAL Threshold (3)b -NEI 99-01 Rev 6 illustrates thresholds in bullet format. Vogtle EAL Threshold (3)b illustrates these thresholds using table format. Site specific information provided.

See V2 Rad Monitor Calculations and VI 0 Containment Sump, RCDT, WHT Reference.

Editorial change -Human Factors consideration.

EAL Threshold (3)b, last bullet, refers to Other site-specific indications of core uncovery.

No Other site-specific indications are used at Vogtle.Vogtle does not use any other site-specific indications of core uncovery than those already identified in EAL Threshold (3)b.16 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CAI: INITIATING CONDITIONS Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.

Justification:

Site use of terminology differs from N El guidance.THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory as (1) Loss of RPV inventory as indicated by level less than elevation indicated by level less than (site-specific level). 185'-10" (73% on Full Range RVLIS).(2) a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot (2) a. RPV level cannot be monitored for 15 minutes or longer be monitored for 15 minutes or longer AND AND b. UNPLANNED increase in Containment Sump, Reactor b. UNPLANNED increase in (site-specific sump and/or tank) Coolant Drain Tank (RCDT) or Waste Holdup Tanks levels due to a loss of (reactor vessel/RCS

[PWR] or RPV (WHT) levels due to a loss of RPV inventory.

[BWR]) inventory.

Difference I Deviation I Justification Difference:

EAL Thresholds (1) and (2)a -NEI 99-01 Rev 6 refers to reactor vessel/RCS for PWRs. Vogtle uses RPV.Justification:

Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:

Site specific information provided.

See V9 RPV LevelIRVLIS Indicatons and VI0 Containment Sump, RCDT, WHT Reference.

17 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CA2: INITIATING CONDITIONS.

Difference

/ Deviation I Justification None THRESHOLDS NE! 99-01 Rev 6 Vogtle (!) Loss of ALL offsite and ALL onsite AC Power to (site-specific

(!) Loss of ALL offsite and ALL onsite AC Power to BOTH l(2)AA02 emergency buses) for 15 minutes or longer. AND1(2)BA03 for 15 minutes or longer.Table SI Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Diesel Generator 1 A Diesel Generator 2A Diesel Generator lB Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB Difference I Deviation I Justification Difference:

Site specific information provided in Table SI. See VI3 Emergency Buses Drawing.18 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CA3: INITIATING CONDITIONS Difference

/ Deviation

/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) UNPLANNED increase in RCS temperature to greater than (site- (1) UNPLANNED increase in RCS temperature to greater than 200 0 F specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.for greater than the duration specified in the following table.Table C2: RCS Heat-up Duration Thresholds Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Containment Closure Heat-up _____________

Status If Duration RCS Status Status I Duration Not intact Not Established 0 minutes Intact (but not at reduced No plcbe(or at reduced inventory)

Established ii20 minutes*inventory

[PWR]) Nojplial 60 minutes* Intact No plcbe 6 i nts Not intact (or at reduced Established j 20 minutes* (but not at reduced inventory)

Ntapial 0mnts inventor [PWR) Not Established 0 minutes

If an RCS heat removal system is in operation within this time frame* If an RCS heat removal system is in operation within this time frame and andRCS temperature is being reduced, the EAL is not applicable.

RCS temperature is being reduced, the EAL is not applicable.

(2) UNPLANNED RCS pressure increase greater than 10 psig. (This (2) UNPLANNED RCS pressure increase greater than (site-specific EAL does not apply during water-solid plant conditions.)

pressure reading). (This EAL does not apply during water-solid plant conditions.

[PWR])Difference

/ Deviation

/ Justification Difference:

Information included in RCS Heat-up Duration Thresholds Table for Vogtle is inverted from the presentation in NEI 99-01 Rev 6.Information is the same. Added Table C2 as designator for table.Justification:

Editorial change for Human Factors considerations

-worst case is presented first; clearly identify tables used in document.Difference:

Site specific information provided.

See VI TS Table 1.1-1 Modes.19 COLD HUTDWN /AEFUEINGISYSTEMG MALFUTINCTOSSSE CA6: INITIATING CONDITIONS Difference I Deviation

/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Seismic event (earthquake)

Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE 0 FIRE* EXPLOSION S EXPLOSION* (site-specific hazards) 0 Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:

b. EITHER of the following:

Event damage has caused indications of degraded 1. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.

The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference

/ Deviation

/ Justification 20 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference:

NEI 99-01 Rev 6 EAL Threshold (1)a, next to the last bullet, refers to site-specific hazards. No additional site specific hazards are identified for Vogtle.Justification:

Vogtle has not identified any additional site-specific hazards applicable to this threshold.

Difference:

NEI 99-01 Rev 6 EAL Threshold (1)b uses numbers to identify the two threshold conditions.

Vogtle EAL Threshold (1)b uses bullets.Justification:

Editorial change for clarity. This change does not affect the EAL threshold.

21 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CUt: INITIATING CONDITIONS Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRS. Vogtle uses RPV inventory.

Justification:

Site use of terminology differs from NEI guidance..... ...... ... THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) UNPLANNED loss of reactor coolant results in (reactor vessel/RCS (1) UNPLANNED loss of reactor coolant results in RPV level less than[PWR] or RPV [BWR]) level less than a required lower limit for 15 a required lower limit for 15 minutes or longer.minutes or longer. (2) a. RPV level cannot be monitored.

(2) a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot AND be monitored.

b. UNPLANNED increase in Containment sump, Reactor AND Coolant Drain Tank (RCDT), or Waste Holdup Tank b. UNPLANNED increase in (site-specific sump and/or tank) (WHiT) levels.levels.Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level.Justification:

Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:

Site specific information provided.

See V10 Containment Sump, RCDT, WHlT Reference.

22 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~~~CU2: INI'TITING CONDITIONS....

.NEI 99-01 Rev 6 Vogtle Loss of all but one AC power source to emergency buses for 15 minutes or Loss of all but one AC power source to emergency buses for 15 minutes or longer. longer.Difference

/ Deviation

/ Justification None THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) a. AC power capability to (site-specific emergency buses) is (1) a. AC power capability to BOTH l(2)AA02 AND l(2)BA03 reduced to a single power source for 15 minutes or longer, is reduced to a single power source for 15 minutes or AND longer.b. Any additional single power source failure will result in AND loss of all AC power to SAFETY SYSTEMS. b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.Table Si Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Diesel Generator 1A Diesel Generator 2A Diesel Generator lB Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB 23 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference

/ Deviation

/ Justification Difference:

Site specific information provided.

See Attachment V13 Emergency Buses Drawing.24 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU3: INITIATING CONDITIONS Difference

/ Deviation

/ Justification None~THRESHOLDS NEI 99-0 1 Rev 6 Vogtle (1) UNPLANNED increase in RCS temperature to greater than (site- (1) UNPLANNED increase in RCS temperature to greater than 200 °F.specific Technical Specification cold shutdown temperature limit). (2) Loss of ALL RCS temperature and RPV level indication for 15 (2) Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or minutes or longer.RPV [BWR]) level indication for 15 minutes or longer.Difference I Deviation I Justification Difference:

NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level.Justification:

Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:

Site specific information provided.

See V1 TS Table 1.1-1 Modes.25 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU4: INITIATING CONDITIONS Difference

/ Deviation

/ Justification None~THRESHOLDS Difference

/ Deviation

/ Justification Difference:

NEI 99-01 Rev 6 EAL Threshold (1) refers to Vital DC buses. Vogtle EAL threshold (1) identifies the specific DC buses.Justification:

Editorial change- Human Factors consideration that does not affect threshold.

Difference:

Site specific information provided.

See V14 DC System Information.

26 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU5: INIIATING CONDITIONS Difference

/ Deviation I Justification None..T..ESHOLDS NEI 99-01 Rev 6 Vogtle (1) Loss of ALL of the following onsite communication methods: (1) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) I In plant telephones (2) Loss of ALL of the following ORO communications methods:[

Public address system (site-specific list of communications methods) Plant radio systems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods: ENN (Emergency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: I ENS on Federal Telecommunications System (FTS)SCommercial phonesI Difference I Deviation

/ Justification Difference:

Site specific information provided.27 INDEPENDENT SPENT FUEL STORAGE FACILITY (ISFSI) ICS/EALS E-HUI: INITIATING CONDITIONS Difference

/ Deviation

/ Justification None THRESHOLD NEI 99-01lRev 6 Vogtle (1) Damage to a loaded cask CONFINEMENT BOUNDARY as (1) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the indicated by an on-contact radiation reading greater than ANY of the site-specific cask specific technical specification allowable radiation values listed in Table El.level) on the surface of the spent fuel cask. Table El Location of Dose Rate Total Dose Rate (Neutron + Gamma mR/br)HI-TRAC 125 Side -Mid-height

[950 Top [200 HI-STORM 100 Side -60 inches below mid-height 170 Side -Mid- height 180 Side -60 inches above mid-height 110 Center of lid* 50 Middle of top lid** 60 Top (outlet) duct 130 Bottom (inlet) duct 360* The center of the top lid represents a 6 in. radius.** The middle of the top lid represents an approximately 4 in. wide cylindrical "strin" located about mid-distance of the lid.28 INDEPENDENT SPENT FUEL STORAGE FACILITY (ISFSI) ICS/EALS Difference

/ Deviation

/ Justification Difference:

Site specific information provided.

See Attachment V15 ISFSI TS/Dose Rending Calculation.

29 FISSION PRODUCT BARRIER ICS/EALS PWR FISSION PRODUCT BARRIERS MATRIX -INITIATING CONDITIONS/THRESHOLDS NEI 99-01 Rev 6 FA1 -Any Loss or any Potential Loss of either FSI -Loss or Potential Loss of any two barriers.

FG1 -Loss of any two barriers and Loss or Potential the Fuel Clad or RCS barrier. Loss of the third barrier.FGI -Loss of any two barriers and Loss or FS1 -Loss or Potential Loss of any two barriers.

FA1 -Any loss or any Potential Loss of either the Fuel Potential Loss of the third barrier. Clad or RCS barrier Difference

/ Deviation

/ Justification None Fuel Clad Barrier RCS Barrier Containment Barrier Loss Potential Loss Losl Potential Loss Loss Potential Loss NEI 99-01 Rev 6 1. RCS or SG Tube Leakage 1. RCS or SG Tube Leakage 1. RCS or SG Tube Leakage Not Applicable A. RCS/reactor A. An automatic or A. Operation of a standby A. A leaking or Not Applicable vessel level less manual ECCS (SI) charging (makeup) RUPTURED SG is than (site-specific actuation is required pump is required by FAULTED outside of level), by EITHER of the EITHER of the containment.

following:

UNISOLABLE

1. UNISOLABLE RCS leakage RCS leakage OR OR* SG tube 2. SG tube leakage.RUPTURE.OR B. RCS cooldown rate 30 FISSION PRODUCT BARRIER ICS/EALS greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).

Not Applicable A. CORE COOLING CSF -ORANGE entry conditions met.A. An automatic or manual ECCS actuation is required by EITHER of the following:

UNISOLABLE RCS leakage OR* SG tube RUPTURE.A. Operation of a standby charging pump is required by EITHER of the following:

1. UNISOLABLE RCS leakage OR 2. SG tube leakage.OR B. RCS INTEGRITY CSF-RED entry conditions met A. A leaking or RUPTURED SG is FAULTED outside of containment.

Not Applicable Difference!/

Deviation

/ Justification Difference:

Justification:

Difference:

Justification:

Difference:

RCS Barrier Loss EAL Threshold 1.A -NEI 99-01 Rev 6 includes (SI) as clarifier for ECCS. Vogtle EAL Threshold 1.A does not include this clarifier.

Terminology difference RCS Barrier Potential Loss EAL Threshold 1.A -NEI 99-01 Rev 6 clarifies a charging pump as a makeup pump. Vogtle EAL Threshold 1.A does not include this clarifier.

Terminology difference

-Vogtle does not refer to charging pumps as makeup pumps.Site specific information provided.

See V16 CSFST Information.

31 FISSION PRODUCT BARRIER ICS/EALS NET 99-01 Rev 6 2. Inadequate Heat Removal 2. Inadequate Heat Removal 2. Inadequate Heat Removal A. Core exit A. Core exit Not Applicable A. Inadequate RCS heat Not Applicable A. 1. (Site-specific thermocouple thermocouple removal capability via criteria for readings greater readings greater steam generators as entry into core than (site-specific than (site-specific indicated by (site- cooling temperature temperature specific indications).

restoration value). value), procedure)

OR AND B. Inadequate RCS 2 etrto heat removal p.Roeuesnortio capability via effectivre withi steam generators 15etvewti as indicated by 15minutes.(site-specific indications).

A. CORE, COOI1NG A. COR.E COOLING Not Applicable A. HEAT SINK CSF -Not Applicable A. CORE COOLING CSF -RED entry CSF -ORANGE RED entry conditions CSF -RED entry conditions met entry conditions met. conditions met for met 15 minutes or OR longer B. HEAT SINK CSF-RED entry conditions met Difference l Deviation

/ Justfication Difference:

Site specific information provided.

See VI6 CSFST Information.

32 FISSION PRODUCT BARRIER ICS/EALS NET 99-01 Rev 6 3. RCS Activity / Containment Radiation

3. RCS Activity / Containment Radiation

3. RCS Activity I Containment Radiation A. Containment Not Applicable A. Containment radiation Not Applicable Not Applicable A. Containment radiation monitor monitor reading radiation monitor reading greater greater than (site- reading greater than than (site-specific specific value). (site-specific value).value).OR B. (Site-specific indications that reactor coolant activity is greater than 300 pCi/gm dose equivalent 1-131).

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!: I1 11117isii 1 ,77i l, l ii I77!i11 II"!

l i! ifiii; i li ii~~li{

Ii~ £ 7¢ ) 8.7E+2 mR/hr. RE-005 O_..R 006> 2.6E+5 mR/hr. _ 1.3E+7 mR/hr.OR B. Indications that reactor coolant activity is greater than 300 pCi/gm dose equivalent 1-131.Difference I Deviation

/ Justification 33 FISSION PRODUCT BARRIER ICS/EALS Difference:

Fuel Clad Barrier Loss EAL Threshold 3.B -NEI 99-01 Rev 6 directs use of site specific indiciations of dose equivalent 1-131. Vogtle EAL Threshold uses generic indications.

Justification:

It is implied that this EAL is satisfied by analysis of an RCS Sample. The Vogtle EAL basis document provides the user with additional guidance.IDifference:

Site specific information provided.

See V2 Rad Monitor Calculations.

34 FISSION PRODUCT BARRIER ICS/EALS NE! 99-01 Rev 6 4. Containment Integrity or Bypass 4. Containment Integrity or Bypass 4. Containment Integrity or Bypass Not Applicable Not Applicable Not Applicable Not Applicable A. Containment isolation is A. Containment required pressure greater than AND (site-specific value)EITHER of the OR following:

B. Explosive mixture 1. Containment exists inside integrity has been containment lost based on OR Emergency C. 1. Containment Director judgment, pressure greater OR than (site-2. UNISOLABLE specific pressure pathway from the setpoint)containment to the AND environment exists. 2. Less than one OR full train of B. Indications of RCS (site-specific leakage outside of system or containment, equipment) is operating per design for 15 minutes or longer.35 FISSION PRODUCT BARRIER ICS/EALS Not Applicable Not Applicable Not Applicable Not Applicable A. Containment isolation is required AND EITHER of the following:

1. Containment integrity has been lost based on Emergency Director judgment.OR 2. UNISOLABLE pathway from the containment to the environment exists.OR B. Indications of RCS leakage outside of containment.
A. CONTAINMENT CSF RED entry conditions met.OR B. CTMT hydrogen concentration greater than 6%OR C. I. CONTAINMENT CSF ORANGE conditions met.AND 2. Less than Four CTMT fan coolers and one full train of CTMT Spray is operating per design for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Potential Loss EAL Thresholds 4.A and 4.C.1 -Site specific information provided.
See V16 CSFST Information.
Difference:
Potential Loss EAL Threshold 4.B -NEI 99-01 Rev 6 refers to Explosive mixture exists inside containment.
Vogtle threshold specifies the hydrogen concentration that is considered an explosive mixture in containment.
See VIi 11H2 Concentration.
Justification:
Human factors consideration, use of a specific measurable and recognizable concentration facilitates the determination that EAL threshold has been met.Difference:
Potential Loss EAL Threshold 4.C.2 -NEI 99-01 Rev 6 refers to only one train of a site specific system. Vogtle threshold includes additional components (four CTMT fan coolers) that support CTMT spray to meet this entry condition.
Justification:
Plant design difference.
36 FISSION PRODUC BA01RReRv 6/A NEI 99-01 Rev 6 5. Other Indications
5. Other Indications
5. Other Indications A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as applicable) applicable) applicable) applicable) applicable) applicable)
$ v Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Difference
/ Deviation
/ Justification Difference:
No additional EALs identified for Vogtle.Justification:
No additional EALs identified.
NEI 99-01 Rev 6 6. Emergency Director Judgment 6. Emergency Director Judgment 6. Emergency Director Judgment A. ANY condition in A. ANY condition in A. ANY condition in the A. ANY condition in the A. ANY condition in the A. ANY condition in the opinion of the the opinion of the opinion of the opinion of the opinion of the the opinion of the Emergency Emergency Emergency Director Emergency Director Emergency Director that Emergency Director Director that Director that that indicates Loss of that indicates Potential indicates Potential Loss that indicates Loss of indicates Loss of indicates Potential the RCS Barrier. Loss of the RCS of the Containment the Containment the Fuel Clad Loss of the Fuel Barrier. Barrier. Barrier.Barrier. Clad Barrier.A. ANY condition in A. ANY condition in A. ANY condition in the A. ANY condition in the A. ANY condition in the A. ANY condition in the opinion of the the opinion of the opinion of the opinion of the opinion of the the opinion of the emergency emergency emergency director emergency director that emergency director that emergency director director that director that that indicates loss of indicates potential loss indicates loss of the that indicates indicates loss of indicates potential the RCS Barrier, of the RCS Barrier, containment barrier, potential loss of the the fuel clad loss of the fuel containment barrier.barrier, clad barrier.37 FISSION PRODUCT BARRIER ICS/EALS Difference
/ Deviation
/ Justification None 38 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HGI: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. A HOSTILE ACTION is occurring or has occurred within (1) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific the PROTECTED AREA as reported by security shift security shift supervision).
supervision.
AND AND b. EITHER of the following has occurred:
b. EITHER of the following has occurred: I. ANY of the following safety functions cannot be 1.ANY of the following safety functions cannot be controlled or maintained, controlled or maintained.
Reactivity control 0 Reactivity control* Core cooling [PWR] / RPV water level [BWR] 0 Core cooling* RCS heat removal 0 RCS heat removal OR OR 2. Damage to spent fuel has occurred or is 2. Damage to spent fuel has occurred or is IMMINENT.IMMINENT.Difference I Deviation
/ Justification Difference:
Site specific information provided.39 HZRSADOHER:
CONITIOTNS AFFECTINGPLNTSAEYI/AL HG7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None....THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or involve actual or IMMINENT substantial core degradation or melting melting with potential for loss of containment integrity or HOSTILE with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the ACTION that results in an actual loss of physical control of the facility.
Releases can be Justificationably expected to exceed EPA facility.
Releases can be Justificationably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the Protective Action Guideline exposure levels offsite for more than the immediate site area. immediate site area.Difference
/ Deviation
/ Justification None 40 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HSI INITIATING CONDITIONS Difference
/ Deviation
/ Justification None NEI 99-01 Rev 6 Vogtle (I) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift PROTECTED AREA as reported by security shift supervision.
supervision).
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.41 HAZADSADOHER:
CONDITIOT-NS AFFECTINGPLNTSAEYI/EL HS6: INITIATING CONDITIONS Difference I Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. An event has resulted in plant control being transferred (1) a. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown from the control room to the remote shutdown panels due panels and local control stations).
to a control room evacuation.
AND AND b. Control of ANY of the following key safety functions is not b. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).
reestablished within 15 minutes.* Reactivity control 0 Reactivity control* Core cooling [PWRJ / RPV water level [BWR] 0 Core cooling* RCS heat removal 0 RCS heat removal Difference
/ Deviation
/ Justification Difference:
Site specific information provided.42 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HS7: INITITING CONDITIONS NEI 99-01 Rev 6 Vogtle I)Other conditions exist which in the judgment of the Emergency (1)cto Other conditions exist which in the judgment of the emergency drco paroatdeclrtion of aSthe pulcoA OTLEATO htresultsrenin.proatdeclrtion of aithe puliAre HOTIerg ACTINtayrslsi D inteene/Dvitiona daag orsmaicaiousat,()twrniepronlo netoa amg rmlcosat,()twr iepronlo effetiver acessition equipmet needed for the protmectio of the publiec, effectiver acessition equipmet needed for the protectio of the publiecy Anyrelease iniare noat expected tores in prgexpsure levelscure which Anyrelease iniare noat expected tores in prgexpsure levelscre which poexedEAPoetvAction GutepulcorH IdliE expIosutatresuleves beynd thetexedEAPoctvAction GutulcrHSIdliE expIosutatresleves beyndh site boundary, site boundary.Difference I Deviation
/ Justification None 43 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HAl: INITATING CONDITIONS NE1 99-01 Rev 6 Vogtle HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. attack threat within 30 minutes.Difference
/ Deviation
/ Justification None THRSHOLDS NE1 99-01 Rev 6 Vogtle (1) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific OWNER CONTROLLED AREA as reported by security shift security shift supervision).
supervision.
(2) A validated notification from NRC of an aircraft attack threat within (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. 30 minutes of the site.Difference I Deviation
/ Justification Difference:
Site specific information provided.44 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALSINITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Votl 45 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)
AND b. Entry into the room or area is prohibited or impeded.(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any Table Hi plant rooms or areas: AND b. Entry into the room or area is prohibited or impeded.Table HI Applicable Building Room Number Mode 1 CB-226, I CB-A45, 2CB-223, 2CB-A22 I CB-A77, ICB-B61, 1 CB-B76, ICB-B79 3 2CB-A79, 2CR-B01 Control Building 2CB-B04, 2CB-B 18 1CB-226, 1CB-A45 1CB-B84, 2CB-B85 4 2CB-223, 2CB-A22 1CB-A48, ICB-A50 2CB-A15, 2CB-A16 ____AFW Pump AFW Pump HFWouse Operation and 1,2, 3 standby Readiness 1AB-A28, 2AB-A72 A-level demin vessel 1,2, 3 valve galleries I AB-A24, 2AB-A77 3 1AB -A08,3 Auxiliary 2AB-AI01 Building 1AB-C85, 1AB-C89 2AB-C38, 2AB-C44 1AB-BI5 MEZZ l AB-B 19 MEZZ 2AB-B117 MEZZ__________2AB-BI 119 MEZZ ____Difference
/ Deviation
/ Justification Difference:
Site specific information provided.46 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~HA6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) An event has resulted in plant control being transferred from the (1) An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control room to the remote shutdown panels due to a control room control stations), evacuation.
Difference I Deviation I Justification Difference:
Site specific information provided.47 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA7: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) other conditions exist which, in the judgment of the Emergency (1) Other conditions exist which, in the judgment of the emergency Director, indicate that events are in progress or have occurred which director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline limited to small fractions of the EPA Protective Action Guideline exposure levels. exposure levels.Difference
/ Deviation
/ Justification None 48 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS.....:HINITIATING CONDITION NE1 99-01 Rev 6 Vogtle (1)frmA SECURITY CONDITION orthrat. dosootinoleirHSTLE (1 d SECURITY CONDITION orthrat.de o nov OTL Difference I Deviation
/ Justification (2)us tification:
Eiorial chanedib leascrlyidet ifeyta threat i directed agant the siogtle) N sifcte. faceil scrt hetdietda EP Difference:
Site specific information provided.49 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS Difference
/ Deviation
/ Justification TflRSHOLDS NE! 99-01 Rev 6 Vogtle (1) Seismic event greater than Operating Basis Earthquake (OBE) as (1) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: indicated by the Seismic Monitoring System indicating greater than (site-specific indication that a seismic event met or exceeded OBE 0.12 g acceleration.
limits)Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V17 Seismic Indications/Alarms (OBE).50 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS 113: INITIATING C N IIN Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) A tornado strike within the PROTECTED AREA. (1) A tornado strike within the PROTECTED AREA.(2) Internal room or area flooding of a magnitude sufficient to require (2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode, component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA is impeded (3) Movement of personnel within the PROTECTED AREA (PA) is due to an offsite event involving hazardous materials (e.g., an offsite impeded due to an offsite event involving hazardous materials (e.g., chemical spill or toxic gas release).
an offsite chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to (4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles, prohibit the plant staff from accessing the site via personal vehicles.(5) (Site-specific list of natural or technological hazard events) (5) Sustained hurricane force winds greater than 74 mph forecast to be at the plant site in the next four hours.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.51 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~HU4: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEt 99-01 Rev 6 Vogtle (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
the following FIRE detection indications:
Report from the field (i.e., visual observation)
Report from the field (i.e., visual observation)
Receipt of multiple (more than I) fire alarms or 0 Receipt of multiple (more than 1) fire alarms or indications indications
Field verification of a single fire alarm S Field verification of a single fire alarm AND AND b. The FIRE is located within ANY of the Table H2 plant b. The FIRE is located within ANY of the following plant rooms or areas.rooms or areas: (2) a. Receipt of a single fire alarm (i.e., no other indications of a (site-specific list of plant rooms or areas) FIRE).(2) a. Receipt of a single fire alarm (i.e., no other indications of a AND FIRE). b. The FIRE is located within ANY of the Table H2 plant AND rooms or areas.b. The FIRE is located within ANY of the following plant AND rooms or areas: c. The existence of a FIRE is not verified within 30-minutes (site-specific list of plant rooms or areas) of alarm receipt.AND (3) A FIRE within the plant PROTECTED AREA (PA) or ISFSI c. The existence of a FIRE is not verified within 30-minutes PROTECTED AREA not extinguished within 60-minutes of the of alarm receipt, initial report, alarm or indication.
(3) A FIRE within the plant or ISFSI [for plants with an ISFSI outside (4) A FIRE within the plant PROTECTED AREA (PA) or ISFSI the plant Protected Area] PROTECTED AREA not extinguished PROTECTED AREA that requires firefighting support by an offsite within 60-minutes of the initial report, alarm or indication, fire response agency to extinguish.
52 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (4) A FIRE within the plant or ISFS1 [for plants with an ISFSI outside Table 112 the plant Protected Area] PROTECTED AREA that requires Containment Building fieihigspotb noffsite fire response agency to extinguish.
NSCW Cooling Towers fireighing upprt b anDiesel Generator Building Auxiliary Building Fuel Handling Building Control Building Diesel Fuel Oil Storage Tank Pumphouse Auxiliary Feedwater Pumphouse Difference
/ Deviation
/ Justification Difference:
EAL Thresholds (l)b and (2)b -added reference to Table 112 instead of listing areas separately for each threshold.
Justification:
Hluman factors consideration
-applicable rooms are the same for each threshold.
Placing these rooms into one table and referencing that table simplifies the process for identifying applicable rooms.Difference:
EAL Thresholds (3) and (4) -added PROTECTED AREA (PA) after plant.Justification:
Clarifies plant areas that are applicable to these thresholds.
Difference:
Added Table 112 with applicable site specific room listing.53 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NE! 99-01 Rev 6 Vogtle (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems monitoring are expected unless further degradation of safety systems Occurs. occurs.Difference
/ Deviation
/ Justification None 54 SYSTEM MALFUNCTIONS ICS/EALS SG1: INITIATING CONDITIONS
...Difference
/ Deviation
/ Justification None THRESHOLDS NEI199-01 Rev 6 Vogtle (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses). l(2)AA02 AND 1(2)BA03.AND AND b. EITHER of the following:
b. EITHER of the following:
Restoration of at least one AC emergency bus in less
Restoration of at least one AC emergency bus in less than (site-specific hours) is not likely. than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.* (Site-specific indication of an inability to adequately
CORE COOLING CSF -RED conditions met.remove heat from the core)Difference I Deviation I Justification Difference:
Site specific information provided.
See VI3 Emergency Buses Drawing and V16 CSFST Information.
55 SYSTEM MALFUNCTIONS ICS/EALS SG8: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses) for 15 minutes or longer. I (2)AA02 AND 1l(2)BA03 for 15 minutes or longer.AND AND b. Indicated voltage is less than (site-specific bus voltage b. Indicated voltage is less than 105 VDC on ALL 125 VDC value) on ALL (site-specific Vital DC busses) for 15 busses I(2)AD1, 1(2)BD1, I(2)CDI, I(2)DD1 for 15 minutes or longer. minutes or longer.Difference I Deviation I Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing and V14 DC System Information.
56 SYSTEM MALFUNCTIONS ICS/EALS~SSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS...
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.57 SYSTEM MALFUNCTIONS ICS/EALS SS5: INITIATING CONDITIONS NEI199-01 Rev 6 Vogtle Inability to shut down the reactor causing a challenge to (core cooling [PWR] Inability to shut down the reactor causing a challenge to core cooling or RCS/ RPV water level [BWR]) or RCS heat removal, heat removal.Difference
/ Deviation
/ Justification None~THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An automatic or manual (trip [PWR] I scram [BWR]) did 4-not shutdown the reactor.AND b. All manual actions to shut down the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* (Site-specific indication of an inability to adequately remove heat from the core)* (Site-specific indication of an inability to adequately remove heat from the RCS)(1) a. An automatic or manual trip did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* Core Cooling CSF -RED conditions met* Heat Sink CSF -RED conditions met Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V16 CSFST Information.
58 SYSTEM MALFUNCTIONS ICS/EALS SS8: INITITING CONDITIONS Difference I Deviation I Justification None THRESHOLDS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V14 DC System Information.
59 SYSTEM MALFUNCTIONS ICS/EALS SAI: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Loss of all but one AC power source to emergency buses for 15 minutes or Loss of all but one AC power source to emergency buses for 15 minutes or longer. longer.Difference
/ Deviation
/ Justification None THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) a. AC power capability to (site-specific emergency buses) is (1) a. AC power capability to BOTH I(2)AA02 AND I(2)BA03 reduced to a single power source for 15 minutes or longer, is reduced to a single power source for 15 minutes or AND longer.AND b. Any additional single power source failure will result in a b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS. loss of all AC power to SAFETY SYSTEMS.Table Si Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer INXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer INXRB 2NXRB Diesel Generator 1 A Diesel Generator 2A Diesel Generator 1 B Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB 60 SYSTEM MALFUNCTIONS ICS/EALS Difference
/ Deviation I Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.61 SSTEM MNTALFUNGCODTIONS ISEL SM: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An UNPLANNED event results in the inability to monitor (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the one or more of the following parameters from within the Control Room for 15 minutes or longer. Control Room for 15 minutes or longer.[BWR parameter list] [P WR parameter list] Reactor Power Reactor Power Reactor Power RCS Level RCS Pressure RPV Water Level RCS Level In-Core/Core Exit Temperature RPV Pressure RCS Pressure Wide Range Level in at least one steam generator Primary Containment In-Core/Core Exit Steam Generator Main or Auxiliary Feed Water Flow Pressure Temperature Suppression Pool Level Levels in at least (site- AND specific number) steam generators
b. ANY of the following transient events in progress.Suppression Pool Steam Generator Auxiliary S Atmtco aulrnakgetrta 5 Temperature or Emergency Feed Water
Atmtco aulrnakgetrta 5 Flow thermal reactor power* Electrical load rejection greater than 25% full electrical AND load* Reactor trip* ECCS actuation b. ANY of the following transient events in progress.62 SYSTEM MALFUNCTIONS ICS/EALS* Automatic or manual runback greater than 25%thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Difference
/ Deviation I Justification Difference:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Vogtle specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 does not specifly Steam Generator Main Feed Water Flow. Vogtle specifies use of Main Feed Water or Auxiliary Feed Water Flow indications.
Justification:
Site determination that Main feed water flow is also applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 includes (SI) after ECCS. Vogtle does not include (SI) after ECCS.Justification:
Site preference, does not detract or affect EAL determination, 63 SYSTEM MALFUNCTIONS ICS/EALS... SA5: INITIATING CONDITIONS NE1 99-01 Rev 6 Vogtle Automatic or manual (trip [PWR] / scram [BWR]) fails to shut down the Automatic or manual trip fails to shut down the reactor, and subsequent reactor, and subsequent manual actions taken at the reactor control consoles manual actions taken at the reactor control consoles are not successful in are not successful in shutting down the reactor. shutting down the reactor.Difference
/ Deviation
/ ,Justification None~THRESHOLDS NEI199-01 Rev 6 Vogtle (1) a. An automatic or manual (trip [PWR] / scram [BWR]) did (1) a. An automatic or manual trip did not shutdown the reactor.not shutdown the reactor.AND AND b. Manual actions taken at the reactor control consoles are not b. Manual actions taken at the reactor control consoles are not successful in shutting down the reactor.successful in shutting down the reactor.Difference
/ Deviation
/ Justification None 64 SYSTEM MALFUNCTIONS ICS/EALS SA9: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake) 0 Seismic event (earthquake)
Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE S FIRE* EXPLOSION 0 EXPLOSION* (site-specific hazards)
Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:
b. EITHER of the following:
Event damage has caused indications of degraded I. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.
The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference I Deviation I Justification 65 SYSTEM MALFUNCTIONS ICS/EALS Difference:
No additional site specific hazards identified.
Justification:
Site personnel have determined that no additional site specific hazards are applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 EAL Threshold (l)b uses numbers to identify the two threshold conditions.
Vogtle EAL Threshold (l)b uses bullets.Justification:
Editorial change for clarity. This change does not affect the EAL threshold.
66 SSTEM MNTALFUNGCODTIONS ISEL SUl: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) Loss of ALL offsite AC power capability to (site-specific (1) Loss of ALL offsite AC power capability to BOTH. l(2)AA02 AND emergency buses) for 15 minutes or longer. 1 (2)BA03 for 15 minutes or longer.Table S2 Unit I Unit 2 Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.67 SYSTEM MALFUNCTIONS ICS/EALS SUJ2: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle UNPLANNED loss of Control Room indications for 15 minutes or longer. UNPLANNED loss of Control Room indications for 15 minutes or longer.Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.(1) a.An UNPLANNED event results in the inability to monitor one or more of the following parameters fromn within the Control Room for 15 minutes or longer.[BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment In-Core/Core Exit Pressure Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Steam Generator Temperature Auxiliary or Emergency Feed Water Flow Reactor Power RCS Level RCS Pressure In-Core/Core Exit Temperature Wide Range Level in at least one steam generator Steam Generator Main or Auxiliary Feed Water Flow Difference
/ Deviation I Justification 68 SYSTEM MALFUNCTIONS ICS/EALS Difference:
Justification:
Difference:
Justification:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Vogtle specifies use of Wide Range Level indication.
Site determination that Wide Range Level indication is applicable to this EAL threshold.
NEI 99-0 1 Rev 6 does not specifiy Steam Generator Main Feed Water Flow. Vogtle specifies use of Main Feed Water or Auxiliary Feed Water Flow indications.
Site determination that Main feed water flow is also applicable to this EAL threshold.
69 SSTEM MNALFUNGCODTIONS ISEL SU3~ INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits.Difference I Deviation
/ Justification None ThRESHOLDS NE1 99-01 Rev 6 Vogtle-t (1) (Site-specific radiation monitor) reading greater than (site-specific value).(2) Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
(1) RE-48000 reading greater than 5.0 p.Ci/gm.(2) RCS coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits as indicated by ANY of the following:
Dose Equivalent 1-131 greater than 1 ttCi/gm for greater than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Dose Equivalent 1-131 greater than Technical Specification figure 3.4.16-1 limits RCS specific activity greater than 100/s pCi/gm gross radioactivity Difference
/ Deviation
/ Justification Difference:
EAL Threshold (2) -Revised wording including table with conditions that meet the EAL threshold.
Justification:
Editorial change to clearly indicate Technical Specification limits to plant personnel.
Intent of NE! 99-01 Rev 6 EAL Threshold (2) is still met with this change.Difference:
Site specific information provided for EAL Thresholds (1) and (2). See VI8 Rad Monitor Calculation (RE-48000) and V19 TS 3.4.1.6 RCS Activity.70 SYSTEM MALFUNCTIONS ICS/EALS SU4: INITIATING CONDITIONS DifrecI Deviation
/ Justification THRSHOLDS NE1 99-01 Rev 6 Vogtle (1) RCS unidentified or pressure boundary leakage greater than (site- (1) RCS unidentified or pressure boundary leakage greater than 10 gpm specific value) for 15 minutes or longer, for 15 minutes or longer.(2) RCS identified leakage greater than (site-specific value) for 15 (2) RCS identified leakage greater than 25 gpm for 15 minutes or minutes or longer. longer.(3) Leakage from the RCS to a location outside containment greater (3) Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer. than 25 gpm for 15 minutes or longer.Difference I Deviation I Justification Difference:
Site specific value is not used for EAL Thresholds (1) and (2). See V20 TS 3.4.13 RCS Operational Leakage.Justification:
VEGP Tech Spec leak rate is less than identified threshold values. Per Developer Notes the identified values are used.71 SYSTEM MALFUNCTIONS ICS/EALS SUS5: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. An automatic (trip [PWR] / scram [BWRJ) did not (1) a. An automatic trip did not shutdown tbe reactor.shutdown the reactor. AND AND b. A subsequent manual action taken at the reactor control b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.consoles is successful in shutting down the reactor.(2) a. A manual trip ([PWR] / scram [BWRJ) did not shutdown (2) a. A manual trip did not shutdown the reactor.the reactor. AND AND b. EITHER of the following:
b. EITHER of the following:
A subsequent manual action taken at the reactor control 1. A subsequent manual action taken at the reactor consoles is successful in shutting down the reactor.control consoles is successful in shutting down the
A subsequent automatic trip is successful in shutting reactor. down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b uses numbers to identify the two threshold conditions.
Vogtle EAL Threshold (2)b uses bullets.Justification:
Editorial change for clarity. This change does not affect the EAL threshold.
72 SYSTEM MALFUNCTIONS ICS/EALS SU6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (!) Loss of ALL of the following onsite communication methods: (1) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) In plant telephones (2) Loss of ALL of the following ORO communications methods: Public address system (site-specific list of communications methods) Plant radios sytems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods:{ENN (Emer ency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: ENS on Federal Telecommunications System (FTS)Commercial phones Difference
/ Deviation
/ Justification None 73 SYSTEM MALFUNCTIONS ICS/EALS SU7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NE1 99-01 Rev 6 Vogtle (!) a. Failure of containment to isolate when required by an (1) a. Failure of containment to isolate when required by an actuation signal, actuation signal.AND AND b. ALL required penetrations are not closed within 15 b. ALL required penetrations are not closed within 1 5 minutes of the actuation signal. minutes of the actuation signal.(2) a. Containment pressure greater than (site-specific pressure).
(2) a. Containment pressure greater than 52 psig.AND AND b. Less than one full train of (site-specific system or b. Less than 4 CTMT fan coolers and one full train of CTMT equipment) is operating per design for 15 minutes or spray is operating per design for 15 minutes or longer.longer.Difference
/ Deviation
/ Justification Difference:
NEI 99-0 1 Rev 6 refers to only one train of a site specific system. Vogtle EAL threshold includes additional components (four CTMT fan coolers) that support CTMT spray to meet this threshold entry condition.
Justification:
Plant design difference.
Difference:
Site specific information provided.
See V2 1 Containment Pressure Information.
74 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CGI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.
Justification:
Site use of terminology differs from NE! guidance.THRESHOLDS NEI 99-01 Rev 6 Vgle 12 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS (I) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table (see below).(2) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:
(Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication
[PWR]* UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
AND c. ANY indication from the Containment Challenge Table (see below).Containment Challenge Table* CONTAINMENT CLOSURE not established*
(Explosive mixture) exists inside containment
UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]* If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.(1)(2)a. RPV level less than 181'-10" [TOAF] (63% on RVLIS full range) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table Cl.a. RPV level cannot be monitored for 30 minutes or longer.AND b. Core uncovery' is indicated by ANY of the following:
RE-005 OR 006 >40 REM/hr Erratic Source Range monitor indication UNPLANNED increase in Containment Sump, Reactor Coolant Drain Tank (RCDT) or Waste Holdup Tanks (WHT) levels of sufficient magnitude to indicate core uncovery AND c. ANY indication from the Containment Challenge Table C1.Containment Challenge Table C1 CONTAINMENT CLOSURE NOT established*
Explosive mixture inside containment greater than OR equal to 6% H 2 greater than O...R equal to 13 psig WITH CONTAINMENT Containment PressureCLSResalhd greater than OR~ equal to 52 psig WITH Tech Spec containment
____________________________integrity intact* If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.13 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference
/ Deviation
/ Justification Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level. Site specific information provided.
See V9 RPV Level/RVLIS Information.
Site use of terminology (RPV vs RCS) differs from NEI guidance.EAL Threshold (2)b -NEI 99-01 Rev 6 illustrates thresholds in bullet format. Vogtle threshold (2)b illustrates these thresholds using table format. Site specific information provided.
See V2 Rad Monitor Calculations and VI 0 Containment Sump, RCDT, WHiT Reference.
Editorial change -Human Factors consideration.
EAL Threshold (2)b, last bullet, refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Vogtle.Vogtle does not use any other site-specific indications of core uncovery than those already identified in EAL Threshold (2)b.Table designator CI assigned to Containment Challenge Table.Editorial change to clearly identify tables within the document.NEI 99-01 Rev 6 Containment Challenge Table identifies an UNPLANNED increase in containment pressure.
Vogtle Table C1 identifies specific containment pressures for specific conditions.
Editorial change to clearly specify conditions when containment is challenged by pressure increase.Site specific information provided.
See VIi11H2 Concentration and V12 Containment Pressure Reference.
14 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~~CS1: INITIATING CONDITIONS
...Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.
Justification:
Site use of terminology differs from NEI guidance.~THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) a. CONTAINMVIENT CLOSURE not established.
(1) a. CONTAINMENT CLOSURE not established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than 185'-4" [6" below Bottom ID of loop](site-specific level). (72% on Full Range RVLIS).(2) a. CONTAINMENT CLOSURE established.
(2) a. CONTAINMENT CLOSURE established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than 181'-10" [TOAF] (63% on RVLIS full (site-specific level), range).(3) a. (Reactor vessel/RCS
[PWCR] or RPV [BWR]) level cannot (3) a. RPV level cannot be monitored for 30 minutes or longer.be monitored for 30 minutes or longer. AND AND b. Core uncovery is indicated by ANY of the following:Core uncovery is indicated by ANY of the following:
RE-005 OR 006 >40 REM/hr* (Site-specific radiation monitor) reading greater than Erratic Source Range monitor indication (site-specific value) UNPLANNED increase in Containment Sump, Reactor Coolant* Erratic source range monitor indication
[PWR] Drain Tank (RCDT) or Waste Holdup Tanks (WHT) levels of* UNPLANNED increase in (site-specific sump and/or sufficient magnitude to indicate core tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
Difference
/ Deviation
/ Justification 15 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
EAL Thresholds (1)b and (2)b -NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level. Site specific information provided.
See V9 RPV Level/RVLIS Indications.
Site use of terminology (RPV vs RCS) differs from NEI guidance.EAL Threshold (3)b -NEI 99-01 Rev 6 illustrates thresholds in bullet format. Vogtle EAL Threshold (3)b illustrates these thresholds using table format. Site specific information provided.
See V2 Rad Monitor Calculations and VI 0 Containment Sump, RCDT, WHT Reference.
Editorial change -Human Factors consideration.
EAL Threshold (3)b, last bullet, refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Vogtle.Vogtle does not use any other site-specific indications of core uncovery than those already identified in EAL Threshold (3)b.16 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CAI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRs. Vogtle uses RPV inventory.
Justification:
Site use of terminology differs from N El guidance.THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory as (1) Loss of RPV inventory as indicated by level less than elevation indicated by level less than (site-specific level). 185'-10" (73% on Full Range RVLIS).(2) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot (2) a. RPV level cannot be monitored for 15 minutes or longer be monitored for 15 minutes or longer AND AND b. UNPLANNED increase in Containment Sump, Reactor b. UNPLANNED increase in (site-specific sump and/or tank) Coolant Drain Tank (RCDT) or Waste Holdup Tanks levels due to a loss of (reactor vessel/RCS
[PWR] or RPV (WHT) levels due to a loss of RPV inventory.
[BWR]) inventory.
Difference I Deviation I Justification Difference:
EAL Thresholds (1) and (2)a -NEI 99-01 Rev 6 refers to reactor vessel/RCS for PWRs. Vogtle uses RPV.Justification:
Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:
Site specific information provided.
See V9 RPV LevelIRVLIS Indicatons and VI0 Containment Sump, RCDT, WHT Reference.
17 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CA2: INITIATING CONDITIONS.
Difference
/ Deviation I Justification None THRESHOLDS NE! 99-01 Rev 6 Vogtle (!) Loss of ALL offsite and ALL onsite AC Power to (site-specific
(!) Loss of ALL offsite and ALL onsite AC Power to BOTH l(2)AA02 emergency buses) for 15 minutes or longer. AND1(2)BA03 for 15 minutes or longer.Table SI Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Diesel Generator 1 A Diesel Generator 2A Diesel Generator lB Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB Difference I Deviation I Justification Difference:
Site specific information provided in Table SI. See VI3 Emergency Buses Drawing.18 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CA3: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) UNPLANNED increase in RCS temperature to greater than (site- (1) UNPLANNED increase in RCS temperature to greater than 200 0 F specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.for greater than the duration specified in the following table.Table C2: RCS Heat-up Duration Thresholds Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Containment Closure Heat-up _____________
Status If Duration RCS Status Status I Duration Not intact Not Established 0 minutes Intact (but not at reduced No plcbe(or at reduced inventory)
Established ii20 minutes*inventory
[PWR]) Nojplial 60 minutes* Intact No plcbe 6 i nts Not intact (or at reduced Established j 20 minutes* (but not at reduced inventory)
Ntapial 0mnts inventor [PWR) Not Established 0 minutes
If an RCS heat removal system is in operation within this time frame* If an RCS heat removal system is in operation within this time frame and andRCS temperature is being reduced, the EAL is not applicable.
RCS temperature is being reduced, the EAL is not applicable.
(2) UNPLANNED RCS pressure increase greater than 10 psig. (This (2) UNPLANNED RCS pressure increase greater than (site-specific EAL does not apply during water-solid plant conditions.)
pressure reading). (This EAL does not apply during water-solid plant conditions.
[PWR])Difference
/ Deviation
/ Justification Difference:
Information included in RCS Heat-up Duration Thresholds Table for Vogtle is inverted from the presentation in NEI 99-01 Rev 6.Information is the same. Added Table C2 as designator for table.Justification:
Editorial change for Human Factors considerations
-worst case is presented first; clearly identify tables used in document.Difference:
Site specific information provided.
See VI TS Table 1.1-1 Modes.19 COLD HUTDWN /AEFUEINGISYSTEMG MALFUTINCTOSSSE CA6: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
Seismic event (earthquake)
Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE 0 FIRE* EXPLOSION S EXPLOSION* (site-specific hazards) 0 Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:
b. EITHER of the following:
Event damage has caused indications of degraded 1. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.
The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference
/ Deviation
/ Justification 20 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference:
NEI 99-01 Rev 6 EAL Threshold (1)a, next to the last bullet, refers to site-specific hazards. No additional site specific hazards are identified for Vogtle.Justification:
Vogtle has not identified any additional site-specific hazards applicable to this threshold.
Difference:
NEI 99-01 Rev 6 EAL Threshold (1)b uses numbers to identify the two threshold conditions.
Vogtle EAL Threshold (1)b uses bullets.Justification:
Editorial change for clarity. This change does not affect the EAL threshold.
21 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~CUt: INITIATING CONDITIONS Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS inventory for PWRS. Vogtle uses RPV inventory.
Justification:
Site use of terminology differs from NEI guidance..... ...... ... THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) UNPLANNED loss of reactor coolant results in (reactor vessel/RCS (1) UNPLANNED loss of reactor coolant results in RPV level less than[PWR] or RPV [BWR]) level less than a required lower limit for 15 a required lower limit for 15 minutes or longer.minutes or longer. (2) a. RPV level cannot be monitored.
(2) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot AND be monitored.
b. UNPLANNED increase in Containment sump, Reactor AND Coolant Drain Tank (RCDT), or Waste Holdup Tank b. UNPLANNED increase in (site-specific sump and/or tank) (WHiT) levels.levels.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level.Justification:
Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:
Site specific information provided.
See V10 Containment Sump, RCDT, WHlT Reference.
22 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS~~~CU2: INI'TITING CONDITIONS....
.NEI 99-01 Rev 6 Vogtle Loss of all but one AC power source to emergency buses for 15 minutes or Loss of all but one AC power source to emergency buses for 15 minutes or longer. longer.Difference
/ Deviation
/ Justification None THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) a. AC power capability to (site-specific emergency buses) is (1) a. AC power capability to BOTH l(2)AA02 AND l(2)BA03 reduced to a single power source for 15 minutes or longer, is reduced to a single power source for 15 minutes or AND longer.b. Any additional single power source failure will result in AND loss of all AC power to SAFETY SYSTEMS. b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.Table Si Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Diesel Generator 1A Diesel Generator 2A Diesel Generator lB Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB 23 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See Attachment V13 Emergency Buses Drawing.24 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU3: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NEI 99-0 1 Rev 6 Vogtle (1) UNPLANNED increase in RCS temperature to greater than (site- (1) UNPLANNED increase in RCS temperature to greater than 200 °F.specific Technical Specification cold shutdown temperature limit). (2) Loss of ALL RCS temperature and RPV level indication for 15 (2) Loss of ALL RCS temperature and (reactor vessel/RCS
[PWR] or minutes or longer.RPV [BWR]) level indication for 15 minutes or longer.Difference I Deviation I Justification Difference:
NEI 99-01 Rev 6 refers to reactor vessel/RCS level for PWRs. Vogtle uses RPV level.Justification:
Site use of terminology (RPV vs RCS) differs from NEI guidance.Difference:
Site specific information provided.
See V1 TS Table 1.1-1 Modes.25 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU4: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (1) refers to Vital DC buses. Vogtle EAL threshold (1) identifies the specific DC buses.Justification:
Editorial change- Human Factors consideration that does not affect threshold.
Difference:
Site specific information provided.
See V14 DC System Information.
26 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ICS/EALS CU5: INIIATING CONDITIONS Difference
/ Deviation I Justification None..T..ESHOLDS NEI 99-01 Rev 6 Vogtle (1) Loss of ALL of the following onsite communication methods: (1) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) I In plant telephones (2) Loss of ALL of the following ORO communications methods:[
Public address system (site-specific list of communications methods) Plant radio systems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods: ENN (Emergency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: I ENS on Federal Telecommunications System (FTS)SCommercial phonesI Difference I Deviation
/ Justification Difference:
Site specific information provided.27 INDEPENDENT SPENT FUEL STORAGE FACILITY (ISFSI) ICS/EALS E-HUI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLD NEI 99-01lRev 6 Vogtle (1) Damage to a loaded cask CONFINEMENT BOUNDARY as (1) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the indicated by an on-contact radiation reading greater than ANY of the site-specific cask specific technical specification allowable radiation values listed in Table El.level) on the surface of the spent fuel cask. Table El Location of Dose Rate Total Dose Rate (Neutron + Gamma mR/br)HI-TRAC 125 Side -Mid-height
[950 Top [200 HI-STORM 100 Side -60 inches below mid-height 170 Side -Mid- height 180 Side -60 inches above mid-height 110 Center of lid* 50 Middle of top lid** 60 Top (outlet) duct 130 Bottom (inlet) duct 360* The center of the top lid represents a 6 in. radius.** The middle of the top lid represents an approximately 4 in. wide cylindrical "strin" located about mid-distance of the lid.28 INDEPENDENT SPENT FUEL STORAGE FACILITY (ISFSI) ICS/EALS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See Attachment V15 ISFSI TS/Dose Rending Calculation.
29 FISSION PRODUCT BARRIER ICS/EALS PWR FISSION PRODUCT BARRIERS MATRIX -INITIATING CONDITIONS/THRESHOLDS NEI 99-01 Rev 6 FA1 -Any Loss or any Potential Loss of either FSI -Loss or Potential Loss of any two barriers.
FG1 -Loss of any two barriers and Loss or Potential the Fuel Clad or RCS barrier. Loss of the third barrier.FGI -Loss of any two barriers and Loss or FS1 -Loss or Potential Loss of any two barriers.
FA1 -Any loss or any Potential Loss of either the Fuel Potential Loss of the third barrier. Clad or RCS barrier Difference
/ Deviation
/ Justification None Fuel Clad Barrier RCS Barrier Containment Barrier Loss Potential Loss Losl Potential Loss Loss Potential Loss NEI 99-01 Rev 6 1. RCS or SG Tube Leakage 1. RCS or SG Tube Leakage 1. RCS or SG Tube Leakage Not Applicable A. RCS/reactor A. An automatic or A. Operation of a standby A. A leaking or Not Applicable vessel level less manual ECCS (SI) charging (makeup) RUPTURED SG is than (site-specific actuation is required pump is required by FAULTED outside of level), by EITHER of the EITHER of the containment.
following:
following:
UNISOLABLE
1. UNISOLABLE RCS leakage RCS leakage OR OR* SG tube 2. SG tube leakage.RUPTURE.OR B. RCS cooldown rate 30 FISSION PRODUCT BARRIER ICS/EALS greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).
Not Applicable A. CORE COOLING CSF -ORANGE entry conditions met.A. An automatic or manual ECCS actuation is required by EITHER of the following:
UNISOLABLE RCS leakage OR* SG tube RUPTURE.A. Operation of a standby charging pump is required by EITHER of the following:
1. UNISOLABLE RCS leakage OR 2. SG tube leakage.OR B. RCS INTEGRITY CSF-RED entry conditions met A. A leaking or RUPTURED SG is FAULTED outside of containment.
Not Applicable Difference!/
Deviation
/ Justification Difference:
Justification:
Difference:
Justification:
Difference:
RCS Barrier Loss EAL Threshold 1.A -NEI 99-01 Rev 6 includes (SI) as clarifier for ECCS. Vogtle EAL Threshold 1.A does not include this clarifier.
Terminology difference RCS Barrier Potential Loss EAL Threshold 1.A -NEI 99-01 Rev 6 clarifies a charging pump as a makeup pump. Vogtle EAL Threshold 1.A does not include this clarifier.
Terminology difference
-Vogtle does not refer to charging pumps as makeup pumps.Site specific information provided.
See V16 CSFST Information.
31 FISSION PRODUCT BARRIER ICS/EALS NET 99-01 Rev 6 2. Inadequate Heat Removal 2. Inadequate Heat Removal 2. Inadequate Heat Removal A. Core exit A. Core exit Not Applicable A. Inadequate RCS heat Not Applicable A. 1. (Site-specific thermocouple thermocouple removal capability via criteria for readings greater readings greater steam generators as entry into core than (site-specific than (site-specific indicated by (site- cooling temperature temperature specific indications).
restoration value). value), procedure)
OR AND B. Inadequate RCS 2 etrto heat removal p.Roeuesnortio capability via effectivre withi steam generators 15etvewti as indicated by 15minutes.(site-specific indications).
A. CORE, COOI1NG A. COR.E COOLING Not Applicable A. HEAT SINK CSF -Not Applicable A. CORE COOLING CSF -RED entry CSF -ORANGE RED entry conditions CSF -RED entry conditions met entry conditions met. conditions met for met 15 minutes or OR longer B. HEAT SINK CSF-RED entry conditions met Difference l Deviation
/ Justfication Difference:
Site specific information provided.
See VI6 CSFST Information.
32 FISSION PRODUCT BARRIER ICS/EALS NET 99-01 Rev 6 3. RCS Activity / Containment Radiation
3. RCS Activity / Containment Radiation
3. RCS Activity I Containment Radiation A. Containment Not Applicable A. Containment radiation Not Applicable Not Applicable A. Containment radiation monitor monitor reading radiation monitor reading greater greater than (site- reading greater than than (site-specific specific value). (site-specific value).value).OR B. (Site-specific indications that reactor coolant activity is greater than 300 pCi/gm dose equivalent 1-131).
!i! 17S177 i i~~ii 711 I~ 1>¢
!: I1 11117isii 1 ,77i l, l ii I77!i11 II"!
l i! ifiii; i li ii~~li{
Ii~ £ 7¢ ) 8.7E+2 mR/hr. RE-005 O_..R 006> 2.6E+5 mR/hr. _ 1.3E+7 mR/hr.OR B. Indications that reactor coolant activity is greater than 300 pCi/gm dose equivalent 1-131.Difference I Deviation
/ Justification 33 FISSION PRODUCT BARRIER ICS/EALS Difference:
Fuel Clad Barrier Loss EAL Threshold 3.B -NEI 99-01 Rev 6 directs use of site specific indiciations of dose equivalent 1-131. Vogtle EAL Threshold uses generic indications.
Justification:
It is implied that this EAL is satisfied by analysis of an RCS Sample. The Vogtle EAL basis document provides the user with additional guidance.IDifference:
Site specific information provided.
See V2 Rad Monitor Calculations.
34 FISSION PRODUCT BARRIER ICS/EALS NE! 99-01 Rev 6 4. Containment Integrity or Bypass 4. Containment Integrity or Bypass 4. Containment Integrity or Bypass Not Applicable Not Applicable Not Applicable Not Applicable A. Containment isolation is A. Containment required pressure greater than AND (site-specific value)EITHER of the OR following:
B. Explosive mixture 1. Containment exists inside integrity has been containment lost based on OR Emergency C. 1. Containment Director judgment, pressure greater OR than (site-2. UNISOLABLE specific pressure pathway from the setpoint)containment to the AND environment exists. 2. Less than one OR full train of B. Indications of RCS (site-specific leakage outside of system or containment, equipment) is operating per design for 15 minutes or longer.35 FISSION PRODUCT BARRIER ICS/EALS Not Applicable Not Applicable Not Applicable Not Applicable A. Containment isolation is required AND EITHER of the following:
1. Containment integrity has been lost based on Emergency Director judgment.OR 2. UNISOLABLE pathway from the containment to the environment exists.OR B. Indications of RCS leakage outside of containment.
A. CONTAINMENT CSF RED entry conditions met.OR B. CTMT hydrogen concentration greater than 6%OR C. I. CONTAINMENT CSF ORANGE conditions met.AND 2. Less than Four CTMT fan coolers and one full train of CTMT Spray is operating per design for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Potential Loss EAL Thresholds 4.A and 4.C.1 -Site specific information provided.
See V16 CSFST Information.
Difference:
Potential Loss EAL Threshold 4.B -NEI 99-01 Rev 6 refers to Explosive mixture exists inside containment.
Vogtle threshold specifies the hydrogen concentration that is considered an explosive mixture in containment.
See VIi 11H2 Concentration.
Justification:
Human factors consideration, use of a specific measurable and recognizable concentration facilitates the determination that EAL threshold has been met.Difference:
Potential Loss EAL Threshold 4.C.2 -NEI 99-01 Rev 6 refers to only one train of a site specific system. Vogtle threshold includes additional components (four CTMT fan coolers) that support CTMT spray to meet this entry condition.
Justification:
Plant design difference.
36 FISSION PRODUC BA01RReRv 6/A NEI 99-01 Rev 6 5. Other Indications
5. Other Indications
5. Other Indications A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as A. (site-specific as applicable) applicable) applicable) applicable) applicable) applicable)
$ v Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Difference
/ Deviation
/ Justification Difference:
No additional EALs identified for Vogtle.Justification:
No additional EALs identified.
NEI 99-01 Rev 6 6. Emergency Director Judgment 6. Emergency Director Judgment 6. Emergency Director Judgment A. ANY condition in A. ANY condition in A. ANY condition in the A. ANY condition in the A. ANY condition in the A. ANY condition in the opinion of the the opinion of the opinion of the opinion of the opinion of the the opinion of the Emergency Emergency Emergency Director Emergency Director Emergency Director that Emergency Director Director that Director that that indicates Loss of that indicates Potential indicates Potential Loss that indicates Loss of indicates Loss of indicates Potential the RCS Barrier. Loss of the RCS of the Containment the Containment the Fuel Clad Loss of the Fuel Barrier. Barrier. Barrier.Barrier. Clad Barrier.A. ANY condition in A. ANY condition in A. ANY condition in the A. ANY condition in the A. ANY condition in the A. ANY condition in the opinion of the the opinion of the opinion of the opinion of the opinion of the the opinion of the emergency emergency emergency director emergency director that emergency director that emergency director director that director that that indicates loss of indicates potential loss indicates loss of the that indicates indicates loss of indicates potential the RCS Barrier, of the RCS Barrier, containment barrier, potential loss of the the fuel clad loss of the fuel containment barrier.barrier, clad barrier.37 FISSION PRODUCT BARRIER ICS/EALS Difference
/ Deviation
/ Justification None 38 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HGI: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. A HOSTILE ACTION is occurring or has occurred within (1) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific the PROTECTED AREA as reported by security shift security shift supervision).
supervision.
AND AND b. EITHER of the following has occurred:
b. EITHER of the following has occurred: I. ANY of the following safety functions cannot be 1.ANY of the following safety functions cannot be controlled or maintained, controlled or maintained.
Reactivity control 0 Reactivity control* Core cooling [PWR] / RPV water level [BWR] 0 Core cooling* RCS heat removal 0 RCS heat removal OR OR 2. Damage to spent fuel has occurred or is 2. Damage to spent fuel has occurred or is IMMINENT.IMMINENT.Difference I Deviation
/ Justification Difference:
Site specific information provided.39 HZRSADOHER:
CONITIOTNS AFFECTINGPLNTSAEYI/AL HG7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None....THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or involve actual or IMMINENT substantial core degradation or melting melting with potential for loss of containment integrity or HOSTILE with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the ACTION that results in an actual loss of physical control of the facility.
Releases can be Justificationably expected to exceed EPA facility.
Releases can be Justificationably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the Protective Action Guideline exposure levels offsite for more than the immediate site area. immediate site area.Difference
/ Deviation
/ Justification None 40 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HSI INITIATING CONDITIONS Difference
/ Deviation
/ Justification None NEI 99-01 Rev 6 Vogtle (I) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift PROTECTED AREA as reported by security shift supervision.
supervision).
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.41 HAZADSADOHER:
CONDITIOT-NS AFFECTINGPLNTSAEYI/EL HS6: INITIATING CONDITIONS Difference I Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. An event has resulted in plant control being transferred (1) a. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown from the control room to the remote shutdown panels due panels and local control stations).
to a control room evacuation.
AND AND b. Control of ANY of the following key safety functions is not b. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).
reestablished within 15 minutes.* Reactivity control 0 Reactivity control* Core cooling [PWRJ / RPV water level [BWR] 0 Core cooling* RCS heat removal 0 RCS heat removal Difference
/ Deviation
/ Justification Difference:
Site specific information provided.42 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HS7: INITITING CONDITIONS NEI 99-01 Rev 6 Vogtle I)Other conditions exist which in the judgment of the Emergency (1)cto Other conditions exist which in the judgment of the emergency drco paroatdeclrtion of aSthe pulcoA OTLEATO htresultsrenin.proatdeclrtion of aithe puliAre HOTIerg ACTINtayrslsi D inteene/Dvitiona daag orsmaicaiousat,()twrniepronlo netoa amg rmlcosat,()twr iepronlo effetiver acessition equipmet needed for the protmectio of the publiec, effectiver acessition equipmet needed for the protectio of the publiecy Anyrelease iniare noat expected tores in prgexpsure levelscure which Anyrelease iniare noat expected tores in prgexpsure levelscre which poexedEAPoetvAction GutepulcorH IdliE expIosutatresuleves beynd thetexedEAPoctvAction GutulcrHSIdliE expIosutatresleves beyndh site boundary, site boundary.Difference I Deviation
/ Justification None 43 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HAl: INITATING CONDITIONS NE1 99-01 Rev 6 Vogtle HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. attack threat within 30 minutes.Difference
/ Deviation
/ Justification None THRSHOLDS NE1 99-01 Rev 6 Vogtle (1) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific OWNER CONTROLLED AREA as reported by security shift security shift supervision).
supervision.
(2) A validated notification from NRC of an aircraft attack threat within (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. 30 minutes of the site.Difference I Deviation
/ Justification Difference:
Site specific information provided.44 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALSINITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Votl 45 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)
AND b. Entry into the room or area is prohibited or impeded.(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any Table Hi plant rooms or areas: AND b. Entry into the room or area is prohibited or impeded.Table HI Applicable Building Room Number Mode 1 CB-226, I CB-A45, 2CB-223, 2CB-A22 I CB-A77, ICB-B61, 1 CB-B76, ICB-B79 3 2CB-A79, 2CR-B01 Control Building 2CB-B04, 2CB-B 18 1CB-226, 1CB-A45 1CB-B84, 2CB-B85 4 2CB-223, 2CB-A22 1CB-A48, ICB-A50 2CB-A15, 2CB-A16 ____AFW Pump AFW Pump HFWouse Operation and 1,2, 3 standby Readiness 1AB-A28, 2AB-A72 A-level demin vessel 1,2, 3 valve galleries I AB-A24, 2AB-A77 3 1AB -A08,3 Auxiliary 2AB-AI01 Building 1AB-C85, 1AB-C89 2AB-C38, 2AB-C44 1AB-BI5 MEZZ l AB-B 19 MEZZ 2AB-B117 MEZZ__________2AB-BI 119 MEZZ ____Difference
/ Deviation
/ Justification Difference:
Site specific information provided.46 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~HA6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) An event has resulted in plant control being transferred from the (1) An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control room to the remote shutdown panels due to a control room control stations), evacuation.
Difference I Deviation I Justification Difference:
Site specific information provided.47 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA7: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (I) other conditions exist which, in the judgment of the Emergency (1) Other conditions exist which, in the judgment of the emergency Director, indicate that events are in progress or have occurred which director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline limited to small fractions of the EPA Protective Action Guideline exposure levels. exposure levels.Difference
/ Deviation
/ Justification None 48 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS.....:HINITIATING CONDITION NE1 99-01 Rev 6 Vogtle (1)frmA SECURITY CONDITION orthrat. dosootinoleirHSTLE (1 d SECURITY CONDITION orthrat.de o nov OTL Difference I Deviation
/ Justification (2)us tification:
Eiorial chanedib leascrlyidet ifeyta threat i directed agant the siogtle) N sifcte. faceil scrt hetdietda EP Difference:
Site specific information provided.49 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS Difference
/ Deviation
/ Justification TflRSHOLDS NE! 99-01 Rev 6 Vogtle (1) Seismic event greater than Operating Basis Earthquake (OBE) as (1) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: indicated by the Seismic Monitoring System indicating greater than (site-specific indication that a seismic event met or exceeded OBE 0.12 g acceleration.
limits)Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V17 Seismic Indications/Alarms (OBE).50 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS 113: INITIATING C N IIN Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) A tornado strike within the PROTECTED AREA. (1) A tornado strike within the PROTECTED AREA.(2) Internal room or area flooding of a magnitude sufficient to require (2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode, component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA is impeded (3) Movement of personnel within the PROTECTED AREA (PA) is due to an offsite event involving hazardous materials (e.g., an offsite impeded due to an offsite event involving hazardous materials (e.g., chemical spill or toxic gas release).
an offsite chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to (4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles, prohibit the plant staff from accessing the site via personal vehicles.(5) (Site-specific list of natural or technological hazard events) (5) Sustained hurricane force winds greater than 74 mph forecast to be at the plant site in the next four hours.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.51 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~HU4: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEt 99-01 Rev 6 Vogtle (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
the following FIRE detection indications:
Report from the field (i.e., visual observation)
Report from the field (i.e., visual observation)
Receipt of multiple (more than I) fire alarms or 0 Receipt of multiple (more than 1) fire alarms or indications indications
Field verification of a single fire alarm S Field verification of a single fire alarm AND AND b. The FIRE is located within ANY of the Table H2 plant b. The FIRE is located within ANY of the following plant rooms or areas.rooms or areas: (2) a. Receipt of a single fire alarm (i.e., no other indications of a (site-specific list of plant rooms or areas) FIRE).(2) a. Receipt of a single fire alarm (i.e., no other indications of a AND FIRE). b. The FIRE is located within ANY of the Table H2 plant AND rooms or areas.b. The FIRE is located within ANY of the following plant AND rooms or areas: c. The existence of a FIRE is not verified within 30-minutes (site-specific list of plant rooms or areas) of alarm receipt.AND (3) A FIRE within the plant PROTECTED AREA (PA) or ISFSI c. The existence of a FIRE is not verified within 30-minutes PROTECTED AREA not extinguished within 60-minutes of the of alarm receipt, initial report, alarm or indication.
(3) A FIRE within the plant or ISFSI [for plants with an ISFSI outside (4) A FIRE within the plant PROTECTED AREA (PA) or ISFSI the plant Protected Area] PROTECTED AREA not extinguished PROTECTED AREA that requires firefighting support by an offsite within 60-minutes of the initial report, alarm or indication, fire response agency to extinguish.
52 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (4) A FIRE within the plant or ISFS1 [for plants with an ISFSI outside Table 112 the plant Protected Area] PROTECTED AREA that requires Containment Building fieihigspotb noffsite fire response agency to extinguish.
NSCW Cooling Towers fireighing upprt b anDiesel Generator Building Auxiliary Building Fuel Handling Building Control Building Diesel Fuel Oil Storage Tank Pumphouse Auxiliary Feedwater Pumphouse Difference
/ Deviation
/ Justification Difference:
EAL Thresholds (l)b and (2)b -added reference to Table 112 instead of listing areas separately for each threshold.
Justification:
Hluman factors consideration
-applicable rooms are the same for each threshold.
Placing these rooms into one table and referencing that table simplifies the process for identifying applicable rooms.Difference:
EAL Thresholds (3) and (4) -added PROTECTED AREA (PA) after plant.Justification:
Clarifies plant areas that are applicable to these thresholds.
Difference:
Added Table 112 with applicable site specific room listing.53 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NE! 99-01 Rev 6 Vogtle (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems monitoring are expected unless further degradation of safety systems Occurs. occurs.Difference
/ Deviation
/ Justification None 54 SYSTEM MALFUNCTIONS ICS/EALS SG1: INITIATING CONDITIONS
...Difference
/ Deviation
/ Justification None THRESHOLDS NEI199-01 Rev 6 Vogtle (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses). l(2)AA02 AND 1(2)BA03.AND AND b. EITHER of the following:
b. EITHER of the following:
Restoration of at least one AC emergency bus in less
Restoration of at least one AC emergency bus in less than (site-specific hours) is not likely. than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.* (Site-specific indication of an inability to adequately
CORE COOLING CSF -RED conditions met.remove heat from the core)Difference I Deviation I Justification Difference:
Site specific information provided.
See VI3 Emergency Buses Drawing and V16 CSFST Information.
55 SYSTEM MALFUNCTIONS ICS/EALS SG8: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses) for 15 minutes or longer. I (2)AA02 AND 1l(2)BA03 for 15 minutes or longer.AND AND b. Indicated voltage is less than (site-specific bus voltage b. Indicated voltage is less than 105 VDC on ALL 125 VDC value) on ALL (site-specific Vital DC busses) for 15 busses I(2)AD1, 1(2)BD1, I(2)CDI, I(2)DD1 for 15 minutes or longer. minutes or longer.Difference I Deviation I Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing and V14 DC System Information.
56 SYSTEM MALFUNCTIONS ICS/EALS~SSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS...
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.57 SYSTEM MALFUNCTIONS ICS/EALS SS5: INITIATING CONDITIONS NEI199-01 Rev 6 Vogtle Inability to shut down the reactor causing a challenge to (core cooling [PWR] Inability to shut down the reactor causing a challenge to core cooling or RCS/ RPV water level [BWR]) or RCS heat removal, heat removal.Difference
/ Deviation
/ Justification None~THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An automatic or manual (trip [PWR] I scram [BWR]) did 4-not shutdown the reactor.AND b. All manual actions to shut down the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* (Site-specific indication of an inability to adequately remove heat from the core)* (Site-specific indication of an inability to adequately remove heat from the RCS)(1) a. An automatic or manual trip did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* Core Cooling CSF -RED conditions met* Heat Sink CSF -RED conditions met Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V16 CSFST Information.
58 SYSTEM MALFUNCTIONS ICS/EALS SS8: INITITING CONDITIONS Difference I Deviation I Justification None THRESHOLDS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V14 DC System Information.
59 SYSTEM MALFUNCTIONS ICS/EALS SAI: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Loss of all but one AC power source to emergency buses for 15 minutes or Loss of all but one AC power source to emergency buses for 15 minutes or longer. longer.Difference
/ Deviation
/ Justification None THRSHOLDS NEI 99-01 Rev 6 Vogtle (1) a. AC power capability to (site-specific emergency buses) is (1) a. AC power capability to BOTH I(2)AA02 AND I(2)BA03 reduced to a single power source for 15 minutes or longer, is reduced to a single power source for 15 minutes or AND longer.AND b. Any additional single power source failure will result in a b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS. loss of all AC power to SAFETY SYSTEMS.Table Si Unit 1 Unit 2 Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAA 2NXAA Unit Auxiliary Transformer Unit Auxiliary Transformer 1NXAB 2NXAB Reserve Auxiliary Transformer Reserve Auxiliary Transformer INXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer INXRB 2NXRB Diesel Generator 1 A Diesel Generator 2A Diesel Generator 1 B Diesel Generator 2B Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB 60 SYSTEM MALFUNCTIONS ICS/EALS Difference
/ Deviation I Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.61 SSTEM MNTALFUNGCODTIONS ISEL SM: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An UNPLANNED event results in the inability to monitor (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the one or more of the following parameters from within the Control Room for 15 minutes or longer. Control Room for 15 minutes or longer.[BWR parameter list] [P WR parameter list] Reactor Power Reactor Power Reactor Power RCS Level RCS Pressure RPV Water Level RCS Level In-Core/Core Exit Temperature RPV Pressure RCS Pressure Wide Range Level in at least one steam generator Primary Containment In-Core/Core Exit Steam Generator Main or Auxiliary Feed Water Flow Pressure Temperature Suppression Pool Level Levels in at least (site- AND specific number) steam generators
b. ANY of the following transient events in progress.Suppression Pool Steam Generator Auxiliary S Atmtco aulrnakgetrta 5 Temperature or Emergency Feed Water
Atmtco aulrnakgetrta 5 Flow thermal reactor power* Electrical load rejection greater than 25% full electrical AND load* Reactor trip* ECCS actuation b. ANY of the following transient events in progress.62 SYSTEM MALFUNCTIONS ICS/EALS* Automatic or manual runback greater than 25%thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Difference
/ Deviation I Justification Difference:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Vogtle specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 does not specifly Steam Generator Main Feed Water Flow. Vogtle specifies use of Main Feed Water or Auxiliary Feed Water Flow indications.
Justification:
Site determination that Main feed water flow is also applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 includes (SI) after ECCS. Vogtle does not include (SI) after ECCS.Justification:
Site preference, does not detract or affect EAL determination, 63 SYSTEM MALFUNCTIONS ICS/EALS... SA5: INITIATING CONDITIONS NE1 99-01 Rev 6 Vogtle Automatic or manual (trip [PWR] / scram [BWR]) fails to shut down the Automatic or manual trip fails to shut down the reactor, and subsequent reactor, and subsequent manual actions taken at the reactor control consoles manual actions taken at the reactor control consoles are not successful in are not successful in shutting down the reactor. shutting down the reactor.Difference
/ Deviation
/ ,Justification None~THRESHOLDS NEI199-01 Rev 6 Vogtle (1) a. An automatic or manual (trip [PWR] / scram [BWR]) did (1) a. An automatic or manual trip did not shutdown the reactor.not shutdown the reactor.AND AND b. Manual actions taken at the reactor control consoles are not b. Manual actions taken at the reactor control consoles are not successful in shutting down the reactor.successful in shutting down the reactor.Difference
/ Deviation
/ Justification None 64 SYSTEM MALFUNCTIONS ICS/EALS SA9: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake) 0 Seismic event (earthquake)
Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE S FIRE* EXPLOSION 0 EXPLOSION* (site-specific hazards)
Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:
b. EITHER of the following:
Event damage has caused indications of degraded I. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.
The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference I Deviation I Justification 65 SYSTEM MALFUNCTIONS ICS/EALS Difference:
No additional site specific hazards identified.
Justification:
Site personnel have determined that no additional site specific hazards are applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 EAL Threshold (l)b uses numbers to identify the two threshold conditions.
Vogtle EAL Threshold (l)b uses bullets.Justification:
Editorial change for clarity. This change does not affect the EAL threshold.
66 SSTEM MNTALFUNGCODTIONS ISEL SUl: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) Loss of ALL offsite AC power capability to (site-specific (1) Loss of ALL offsite AC power capability to BOTH. l(2)AA02 AND emergency buses) for 15 minutes or longer. 1 (2)BA03 for 15 minutes or longer.Table S2 Unit I Unit 2 Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRA 2NXRA Reserve Auxiliary Transformer Reserve Auxiliary Transformer 1NXRB 2NXRB Standby Auxiliary Transformer Standby Auxiliary Transformer ANXRA ANXRB Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 Emergency Buses Drawing.67 SYSTEM MALFUNCTIONS ICS/EALS SUJ2: INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle UNPLANNED loss of Control Room indications for 15 minutes or longer. UNPLANNED loss of Control Room indications for 15 minutes or longer.Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.(1) a.An UNPLANNED event results in the inability to monitor one or more of the following parameters fromn within the Control Room for 15 minutes or longer.[BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment In-Core/Core Exit Pressure Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Steam Generator Temperature Auxiliary or Emergency Feed Water Flow Reactor Power RCS Level RCS Pressure In-Core/Core Exit Temperature Wide Range Level in at least one steam generator Steam Generator Main or Auxiliary Feed Water Flow Difference
/ Deviation I Justification 68 SYSTEM MALFUNCTIONS ICS/EALS Difference:
Justification:
Difference:
Justification:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Vogtle specifies use of Wide Range Level indication.
Site determination that Wide Range Level indication is applicable to this EAL threshold.
NEI 99-0 1 Rev 6 does not specifiy Steam Generator Main Feed Water Flow. Vogtle specifies use of Main Feed Water or Auxiliary Feed Water Flow indications.
Site determination that Main feed water flow is also applicable to this EAL threshold.
69 SSTEM MNALFUNGCODTIONS ISEL SU3~ INITIATING CONDITIONS NEI 99-01 Rev 6 Vogtle Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits.Difference I Deviation
/ Justification None ThRESHOLDS NE1 99-01 Rev 6 Vogtle-t (1) (Site-specific radiation monitor) reading greater than (site-specific value).(2) Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
(1) RE-48000 reading greater than 5.0 p.Ci/gm.(2) RCS coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits as indicated by ANY of the following:
Dose Equivalent 1-131 greater than 1 ttCi/gm for greater than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Dose Equivalent 1-131 greater than Technical Specification figure 3.4.16-1 limits RCS specific activity greater than 100/s pCi/gm gross radioactivity Difference
/ Deviation
/ Justification Difference:
EAL Threshold (2) -Revised wording including table with conditions that meet the EAL threshold.
Justification:
Editorial change to clearly indicate Technical Specification limits to plant personnel.
Intent of NE! 99-01 Rev 6 EAL Threshold (2) is still met with this change.Difference:
Site specific information provided for EAL Thresholds (1) and (2). See VI8 Rad Monitor Calculation (RE-48000) and V19 TS 3.4.1.6 RCS Activity.70 SYSTEM MALFUNCTIONS ICS/EALS SU4: INITIATING CONDITIONS DifrecI Deviation
/ Justification THRSHOLDS NE1 99-01 Rev 6 Vogtle (1) RCS unidentified or pressure boundary leakage greater than (site- (1) RCS unidentified or pressure boundary leakage greater than 10 gpm specific value) for 15 minutes or longer, for 15 minutes or longer.(2) RCS identified leakage greater than (site-specific value) for 15 (2) RCS identified leakage greater than 25 gpm for 15 minutes or minutes or longer. longer.(3) Leakage from the RCS to a location outside containment greater (3) Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer. than 25 gpm for 15 minutes or longer.Difference I Deviation I Justification Difference:
Site specific value is not used for EAL Thresholds (1) and (2). See V20 TS 3.4.13 RCS Operational Leakage.Justification:
VEGP Tech Spec leak rate is less than identified threshold values. Per Developer Notes the identified values are used.71 SYSTEM MALFUNCTIONS ICS/EALS SUS5: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Vogtle (1) a. An automatic (trip [PWR] / scram [BWRJ) did not (1) a. An automatic trip did not shutdown tbe reactor.shutdown the reactor. AND AND b. A subsequent manual action taken at the reactor control b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.consoles is successful in shutting down the reactor.(2) a. A manual trip ([PWR] / scram [BWRJ) did not shutdown (2) a. A manual trip did not shutdown the reactor.the reactor. AND AND b. EITHER of the following:
b. EITHER of the following:
A subsequent manual action taken at the reactor control 1. A subsequent manual action taken at the reactor consoles is successful in shutting down the reactor.control consoles is successful in shutting down the
A subsequent automatic trip is successful in shutting reactor. down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b uses numbers to identify the two threshold conditions.
Vogtle EAL Threshold (2)b uses bullets.Justification:
Editorial change for clarity. This change does not affect the EAL threshold.
72 SYSTEM MALFUNCTIONS ICS/EALS SU6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Vogtle (!) Loss of ALL of the following onsite communication methods: (1) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) In plant telephones (2) Loss of ALL of the following ORO communications methods: Public address system (site-specific list of communications methods) Plant radios sytems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods:{ENN (Emer ency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: ENS on Federal Telecommunications System (FTS)Commercial phones Difference
/ Deviation
/ Justification None 73 SYSTEM MALFUNCTIONS ICS/EALS SU7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOLDS NE1 99-01 Rev 6 Vogtle (!) a. Failure of containment to isolate when required by an (1) a. Failure of containment to isolate when required by an actuation signal, actuation signal.AND AND b. ALL required penetrations are not closed within 15 b. ALL required penetrations are not closed within 1 5 minutes of the actuation signal. minutes of the actuation signal.(2) a. Containment pressure greater than (site-specific pressure).
(2) a. Containment pressure greater than 52 psig.AND AND b. Less than one full train of (site-specific system or b. Less than 4 CTMT fan coolers and one full train of CTMT equipment) is operating per design for 15 minutes or spray is operating per design for 15 minutes or longer.longer.Difference
/ Deviation
/ Justification Difference:
NEI 99-0 1 Rev 6 refers to only one train of a site specific system. Vogtle EAL threshold includes additional components (four CTMT fan coolers) that support CTMT spray to meet this threshold entry condition.
Justification:
Plant design difference.
Difference:
Site specific information provided.
See V2 1 Containment Pressure Information.
74

NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4

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