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Attachment 3 to LR-N10-0355, Hope Creek Generating Station, Emergency Action Level Comparison Matrix
	ML110050398
Person / Time
Site:	Salem, Hope Creek
Issue date:	10/14/2010
From:	; Public Service Enterprise Group
To:	; Office of Nuclear Reactor Regulation
References
	LR-N10-0355
	Download: ML110050398 (146)
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4 Attachment 3 HCGS EAL Comparison Matrix GENERATING STATION Hope Creek Generating Station EAL Comparison Matrix Draft E -8/12/10 EAL Comparison Matrix OSSI -HCGS Table of Contents Section Page Introduction

1 Comparison Matrix Format ------------------------------------------------------------------------

1 EAL Emphasis Techniques

1 Global Differences

1 Differences and Deviations

3 Category R -Abnormal Rad Levels / Rad Effluent -------------------------------------------------------

21 Category C -Cold Shutdown / Refueling System Malfunction

42 Category D -Permanently Defueled Station Malfunction

68 Category E -Events Related to Independent Spent Fuel Storage Installations-

70 Category F -Fission Product Barrier Degradation

73 Category H -Hazards and Other Conditions Affecting Plant Safety -------------------------------------------

91 Category S -System Malfunction

119 Table 1 -HCGS EAL Categories/Subcategories

5 Table 2 -NEI / HCGS EAL Identification Cross-Reference

6 Table 3 -Summary of Deviations

13 Table 4 -Defined Terms -------------------------------------------------------------------------

14 i ofi EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS Introduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01 Revision 5, Methodology for Development of Emergency Action Levels, and the HCGS ICs, Mode Applicability and EALs. This document provides a means of assessing HCGS differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of HCGS EAL bases and lists of source document references are given in the EAL Technical Bases Document.

It is, therefore, advisable to reference the EAL Technical Bases Document for background information while using this document.Comparison Matrix Format The lCs and EALs discussed in this document are grouped according to NEI 99-01 Recognition Categories.

Within each Recognition Category, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:

NEI EAL/IC identifier

NEI EAL/IC wording* HCGS EAL/IC identifier

HCGS EAL/IC wording* Description of any differences or deviations EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents.

NEI 99-01 Revision 5 (ADAMS Accession Number ML080450149) is the source document for the NEI EALs; the HCGS EAL Technical Bases Document for the HCGS EALs.The print and paragraph formatting conventions summarized below guide presentation of the HCGS EALs. Space restrictions in the EAL table of this document sometimes override this guidance in cases when following the guidance would introduce undesirable complications in the EAL layout." Words or acronyms that are both uppercase and bold are defined terms." EAL threshold values and table references are bold but are not uppercase.

EAL words or acronyms that are not threshold values and not defined terms may be emphasized by using uppercase print." Bold font, uppercase and underscore are used for logic terms, and quantifiers such as any, all, both, etc.Global Differences The differences listed below generally apply throughout the set of EALs. The global differences do not decrease the effectiveness of the intent of NEI 99-01 Revision 5.1. The NEI phrase "Notification of Unusual Event" has been changed to"Unusual Event" to reduce EAL-user reading burden.2. The generic term "Emergency Director" has been replaced with the term "Emergency Coordinator" as the site specific title used at SGS and HCGS.3. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability.

For example, NEI lists all IC HU1 Example EALs under one IC. The corresponding HCGS EALs appear as unique EALs (e.g., HU1.1 through HU1.5).4. HCGS Operating Modes are Operational Conditions (OPCONs).OPCON identifiers (numbers/letter) modify the NEI 99-01 mode applicability names as follows: 1 -Power Operations, 2 -Startup, 3 -Hot Shutdown, 4 -Cold Shutdown, 5 -Refuel, D -Defueled.

NEI 99-01defines Defueled as follows: "All reactor fuel removed from reactor pressure vessel. (Full core off load during refueling or extended outage)." 5. NEI 99-01 uses words for phrases such as greater than, less than, greater than or equal to, etc. in the wording of ICs and example EALs. To reduce EAL-user reading burden and for consistency with plant procedures, HCGS has adopted use of the symbols >, >, < and< in place of the NEI 99-01 modifiers.

1 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS 6. NEI EALs that include a time interval such as "15 minutes or longer" are expressed as conditional phrases "AND [interval]

minutes have elapsed (Note 3)" to ensure the associated interval is not obscured by the EAL wording. (Some format variations are adopted to maintain proper syntax.) The parenthetical reference to a note directs the EAL-user to the appropriate NEI note concerning interpretation of the time interval.7. EAL notes are numbered to facilitate referencing in the EAL matrix.8. The NEI phrase "RPV/RCS water level" has been changed to "RPV level" for constancy with HCGS EOPs and other operating procedures.

9. The NEI definition of the Containment barrier represents the Primary Containment (PC) barrier in a BWR Mk 1/11. When referring to the Containment barrier, Containment is used in the HCGS EALs.10. IC/EAL identification:

NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in turn, are grouped in "Recognition Categories." The Recognition Categories, however, are so broad and the IC descriptions are so varied that an EAL is difficult to locate in a timely manner when the EAL-user must refer to a set of EALs with the NEI organization and identification scheme. The NEI document clearly states that the EAL/IC/Recognition Category scheme is not intended to be the plant-specific EAL scheme for any plant, and appropriate human factors principles should be applied to development of an EAL scheme that helps the EAL-user make timely and accurate classifications.

HCGS endeavors to improve upon the NEI EAL organization and identification scheme to enhance usability of the plant-specific EAL set. To this end, the HCGS IC/EAL scheme includes the following features: a. Division of the NEI EAL set into three groups: o EALs applicable under all plant operating modes (OPCONs) -This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes -This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Startup, or Power Operations mode.o EALs applicable only under cold operating modes -This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refuel or Defueled mode.The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition.

This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

b. Within each of the above three groups, assignment of EALs to categories/subcategories

-Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user.Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds.

The HCGS EAL categories/subcategories and their relationship to NEI Recognition Categories are listed in Table 1.c. Unique identification of each EAL -Four characters comprise the EAL identifier as illustrated in Figure 1.Figure 1 -EAL Identifier EAL Identifier XXX.X Category (R, H, E, C, S, F) -Sequential number within subcategory/classification Emergency classification (G, S, A, U) Subcategory number (1 if no subcategory)

The first character is a letter associated with the category in which the EAL is located. The second character is a letter associated with the emergency classification level (G for General Emergency, S for Site Area Emergency, A 2 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS for Alert, and U for Unusual Event). The third character is a number associated with one or more subcategories within a given category.

Subcategories are sequentially numbered beginning with the number "1". If a category does not have a subcategory, this character is assigned the number "1". The fourth character is a number preceded by a period for each EAL within a subcategory.

EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the number "1 ".The EAL identifier is designed to fulfill the following objectives:

o Uniqueness

-The EAL identifier ensures that there can be no confusion over which EAL is driving the need for emergency classification.

o Speed in locating the EAL of concern -When the EALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user to the location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assists ERO responders (who may not be in the same facility as the Emergency Coordinator) to find the EAL of concern in a timely manner without the need for a word description of the classification threshold.

o Possible classification upgrade -The category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.Note that the NEI 99-01 identifier only identifies the IC, not the specific example EAL threshold.

The NEI scheme, therefore, does not fulfill the above objectives which are desirable in facilitating timely and accurate emergency classification.

Table 2 lists the HCGS ICs and EALs that correspond to the NEI ICs/Example EALs when the above EAL/IC organization and identification scheme is implemented.

Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" Supplements 1 and 2, a difference is an EAL change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the HCGS EAL. A deviation is an EAL change in which the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the HCGS proposed EAL.Administrative changes that do not actually change the textual content are neither differences nor deviations.

Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.

The following are examples of differences:

Choosing the applicable EAL based upon plant type (i.e., BWR vs.PWR).* Using a numbering scheme other than that provided in NEI 99-01 that does not change the intent of the overall scheme.* Where the NEI 99-01 guidance specifically provides an option to not include an EAL if equipment for the EAL does not exist at HCGS (e.g., automatic real-time dose assessment capability)." Pulling information from the bases section up to the actual EAL that does not change the intent of the EAL.* Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.* Using synonymous wording (e.g., greater than or equal to vs. at or above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)* Adding HCGS equipment/instrument identification and/or noun names to EALs.3 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSIHCGS" Changing the format of the EALs to conform to the HCGS EAL convention (e.g., numbering individual EALs, re-ordering individual EALs within an IC that does not affect the logic, etc.)." Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.* Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., the IC and/or EAL continues to: o Classify at the correct classification level.o Logically integrate with other EALs in the EAL scheme.o Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions).

The following are examples of deviations:

Use of altered mode applicability.

Altering key words or time limits.* Changing words of physical reference (protected area, safety-related equipment, etc.).Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the logic of Fission Product Barrier ICs.Changing a Fission Product Barrier from a Loss to a Potential Loss or vice-versa.

Not using NEI 99-01 definitions.

The intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01.Differences due to plant types are permissible (BWR or PWR).Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained.

Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL: o Does not classify at the classification level consistent with NEI 99-01.o Is not logically integrated with other EALs in the EAL scheme.o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).

The "Difference/Deviation Justification" columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the HCGS IC/EAL wording. An explanation that justifies the reason for each difference is then provided.

If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability.

In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01 Revision 5. A summary list of HCGS EAL deviations from NEI 99-01 is given in Table 3.4 of 143 EAL Comparison Matrix OSSI HCGS Table 1 -HCGS EAL Categories/Subcategories HCGS EALs NEI Category Subcategory Recognition Category Group: Any Operating Mode: R -Abnormal Rad Release / Rad Effluent 1 -Offsite Rad Conditions Abnormal Rad Levels/Radiological 2 -Onsite Rad Conditions/Fuel Pool Effluent Events 3 -CR/CAS Rad E -ISFSI Spent Fuel Transit & Storage Events Related to Independent Spent Fuel Storage Installations H -Hazards & Other Conditions Affecting 1 -Natural & Destructive Phenomena Hazards and Other Conditions Affecting Plant Safety 2 -Fire or Explosion Plant Safety 3 -Hazardous Gas 4 -Security 5 -Control Room Evacuation 6 -EC Judgment Group: Hot Conditions:

S -System Malfunction 1 -Loss of AC Power System Malfunction 2 -Loss of DC Power 3 -ATWS / Criticality 4 -Inability to Reach or Maintain Shutdown Conditions 5 -Instrumentation 6 -Communications 7 -Fuel Clad Degradation 8 -RCS Leakage F -Fission Product Barrier Degradation None Fission Product Barrier Degradation Group: Cold Conditions:

C -Cold Shutdown / Refuel System 1 -Loss of AC Power Cold Shutdown./

Refueling System Malfunction 2 -Loss of DC Power Malfunction 3 -RPV Level 4 -RCS Temperature 5 -Communications 6 -Inadvertent Criticality 5 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table 2 -NEI / HCGS EAL Identification Cross-Reference NEI Hope Creek Generating Station Example Category and Subcategory EAL EAL RU1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RU1.1 RU1.2 RU1 2 N/A N/A RU1 3 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RU1.3 RU1 4 N/A N/A RU1 5 N/A N/A RU2 1 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RU2.1 Pool Events RU2 2 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RU2.2 Pool Events RA1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RA1.1 RA1.2 RAI 2 N/A N/A RA1 3 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RA1.3 RA1 4 N/A N/A RA1 5 N/A N/A RA2 1 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RA2.2 Pool Events 6 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS NEI Hope Creek Generating Station IC Example Category and Subcategory EAL EAL RA2 2 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RA2.1 Pool Events RA3 1 R -Abnormal Rad Release / Rad Effluent, 2 -CR/CAS Rad RA3.1 RS1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.1 RS1 2 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.2 RS1 3 N/A N/A RSI 4 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.3 RG1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.1 RG1 2 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.2 RG1 3 N/A N/A RG1 4 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.3 CUl 1, 2 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CU3.1 CU2 1 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CU3.3 CU2 2 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CU3.2 CU3 1 C -Cold SD/ Refuel System Malfunction, 1 -Loss of AC Power CU1.1 CU4 1 C -Cold SD/ Refuel System Malfunction, 4 -RCS Temperature CU4.1 CU4 2 C -Cold SD/ Refuel System Malfunction, 4 -RCS Temperature CU4.2 CU6 1, 2 C -Cold SD/ Refuel System Malfunction, 5 -Communications CU5.1 CU7 1 C -Cold SD/ Refuel System Malfunction, 2 -Loss of DC Power CU2.1 7 of 143 EAL Comparison Matrix OSSI HCGS NEI Hope Creek Generating Station Example Category and Subcategory EAL EAL CU8 1 C -Cold SD/ Refuel System Malfunction, 6 -Inadvertent Criticality CU6.1 CU8 2 N/A N/A CA1 1 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CA3.1 CA1 2 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CA3.2 CA3 1 C -Cold SD/ Refuel System Malfunction, 1 -Loss of AC Power CA1.1 CA4 1, 2 C -Cold SD/ Refuel System Malfunction, 4 -RCS Temperature CA4.1 CS1 1, 2 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CS3.1 CS1 3 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CS3.2 CG1 1 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CG3.1 CG1 2 C -Cold SD/ Refuel System Malfunction, 3 -RPV Level CG3.2 D-AU1 N/A N/A D-AU2 D-SU1 D-HU1 D-HU2 D-HU3 D-AA1 D-AA2 D-HA1 D-HA2 EU1 1 E- ISFSI EU1.1 8 of 143 EAL Comparison Matrix 0531 HCGS EAL Comparison Matrix OSSI HCGS NEI Hope Creek Generating Station IC Example Category and Subcategory EAL EAL FU1 1 F -Fission Product Barriers 2 or 3 points FA1 1 F -Fission Product Barriers 4 or 5 points FS1 1 F -Fission Product Barriers 6 -11 points FG1 1 F -Fission Product Barriers 12 or 13 points HU1 1 H -Hazards, 1 -Natural & Destructive Phenomena HU1.1 HU1 2 H -Hazards, 1 -Natural & Destructive Phenomena HU1.2 HU1 3 H -Hazards, 1 -Natural & Destructive Phenomena HU1.4 HU1 4 H -Hazards, 1 -Natural & Destructive Phenomena HU1.3 HU1 5 H -Hazards, 1 -Natural & Destructive Phenomena HU1.5 HU2 1 H -Hazards, 2 -Fire or Explosion HU2.1 HU2 2 H -Hazards, 2 -Fire or Explosion HU2.2 HU3 1 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HU3.1 HU3 2 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HU3.2 HU4 1,2, 3 H -Hazards, 4 -Security HU4.1 HU5 1 H -Hazards, 6 -EC Judgment HU6.1 HA1 1 H -Hazards, 1 -Natural & Destructive Phenomena HA1.1 HA1 2 H -Hazards, 1 -Natural & Destructive Phenomena HA1.2 HA1 3 H -Hazards, 1 -Natural & Destructive Phenomena HA1.4 9 of 143 EAL ompriso Marix 551HCG EAL Comparison Matrix OSSI HCGS NEI Hope Creek Generating Station IC Example Category and Subcategory EAL EAL HAl 4 H -Hazards, 1 -Natural & Destructive Phenomena HA1.3 HA1 5 H -Hazards, 1 -Natural & Destructive Phenomena HA1.6 HA1 6 N/A N/A HA2 1 H -Hazards, 2 -Fire or Explosion HA2.1 HA3 1 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HA3.1 HA4 1, 2 H -Hazards, 4 -Security HA4.1 HA5 1 H -Hazards, 5 -Control Room Evacuation HA5.1 HA6 1 H -Hazards, 6 -EC Judgment HA6.1 HS2 1 H -Hazards, 5 -Control Room Evacuation HS5.1 HS3 1 H -Hazards, 6 -EC Judgment HS6.1 HS4 1 H -Hazards, 4 -Security HS4.1 HG1 1, 2 H -Hazards, 4 -Security HG4.1 HG2 1 H -Hazards, 6 -EC Judgment HG6.1 SUl 1 S -System Malfunction, 1 -Loss of AC Power SU1.1 SU2 1 S -System Malfunction, 3 -Inability to Reach or Maintain Shutdown SU3.1 Conditions SU3 1 S -System Malfunction, 5 -Instrumentation SU5.1 SU4 1 S -System Malfunction, 7 -Fuel Clad Degradation SU7.1 SU4 2 S -System Malfunction, 7 -Fuel Clad Degradation SU7.2 10 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS NEI Hope Creek Generating Station IC Example Category and Subcategory EAL EAL SU5 1, 2 S -System Malfunction, 8 -RCS Leakage SU8.1 SU6 1,2 S -System Malfunction, 6 -Communications SU6.1 SU8 1 (BWR) S -System Malfunction, 3 -ATWS / Criticality SU3.1 SU8 1 (PWR) N/A N/A SA2 1 S -System Malfunction, 3 -ATWS / Criticality SA3.1 SA4 1 S -System Malfunction, 5 -Instrumentation SA5.1 SA5 1 S -System Malfunction, 1 -Loss of AC Power SA1.1 SS1 1 S -System Malfunction, 1 -Loss of AC Power SS1.1 SS2 1 S -System Malfunction, 3 -ATWS / Criticality SS3.1 SS3 1 S -System Malfunction, 2 -Loss of DC Power SS2.1 SS6 1 S -System Malfunction, 5 -Instrumentation SS5.1 SG1 1 S -System Malfunction, 1 -Loss of AC Power SG1.1 SG2 1 S -System Malfunction, 3 -ATWS / Criticality SG3.1 11 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS NEI 99-01 HCGS Barrier Threshold EAL FC Loss 1 FB3-L FC Loss 2 FB1-L FC Loss 4 FB2-L FC Loss 6 FB4-L FC P-Loss 2 FB1-P FC P-Loss 6 FB2-P RCS Loss 1 RB2-L RCS Loss 2 RB1-L RB3-L RCS Loss 3 RB4-L RB4-L RCS Loss 6 RB5-L RB1-P RCS P-Loss 3 RB2-P RB2-P RCS P-Loss 6 RB3-P CB1-L CMT Loss 1 CB2-L CB2-L CB3-L CMT Loss 3 CB4-L CB5-L CMT Loss 6 CB6-L CB2-P CMT P-Loss 1 CB3-P CR4-P CMT P-Loss 2 CR1-P CMT P-Loss 4 CR5-P CMT P-Loss 6 CB6-P 12 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSI HCGS Table 3 -Summary of Deviations NEI HCGS IC Example EAL EAL Description HU2 1 HU2.1 The generic bases for HU2 example EAL #1 has been revised to clarify when the 15 minute classification time begins (what constitutes a credible notification/report of a fire). For events where only a single fire or smoke detector has alarmed, the 15 minute clock starts once on/near-scene visual confirmation is received.13 of 143 EAL Comparison Matrix OSSI HCGS Table 4 -NEI 99-01 Rev. 5 Defined Terms NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification AFFECTING SAFE SHUTDOWN:

Event in None The NEI term and definition have been deleted because they progress has adversely affected functions that are no longer used in NEI 99-01 and is not used in the Hope are necessary to bring the plant to and Creek EALs.maintain it in the applicable HOT or COLD SHUTDOWN condition.

Plant condition applicability is determined by Technical Specification LCOs in effect.Example 1: Event causes damage that results in entry into an LCO that requires the plant to be placed in HOT SHUTDOWN.

HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is not"AFFECTING SAFE SHUTDOWN." Example 2: Event causes damage that results in entry into an LCO that requires the plant to be placed in COLD SHUTDOWN.

HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is"AFFECTING SAFE SHUTDOWN." BOMB: Refers to an explosive device BOMB: Refers to an explosive device suspected None suspected of having sufficient force to of having sufficient force to damage plant systems damage plant systems or structures.

or structures.

CIVIL DISTURBANCE:

A group of persons CIVIL DISTURBANCE:

A group of persons None violently protesting station operations or violently protesting station operations or activities activities at the site. at the site.CONFINEMENT BOUNDARY:

The barrier(s)

CONFINEMENT BOUNDARY:

is the barrier(s)

The term "is" has been added to the beginning of the HCGS between areas containing radioactive between areas containing radioactive substances definition for clarity.substances and the environment, and the environment and includes the multi-purp se aniser MPC and fo th pur ose of The phrase "and the environment and includes the multi-purposecanister______and,_fortepurposesofIpurpose canister (MPC) and, for the purposes of this EAL, 14 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification this EAL, the associated cask shielding.

the associated cask shielding" CONTAINMENT CLOSURE: The site specific CONTAINMENT CLOSURE: Is the procedurally The NEI phrase "...The site specific..." has been replaced procedurally defined actions taken to secure defined actions taken to secure the Containment with "...is the..." because it is commonly understood that this containment (primary or secondary for BWR) (Primary or Secondary) and its associated definition of Containment Closure applies to HCGS and not and its associated structures, systems, and structures, systems, and components as a another site.components as a functional barrier to fission functional barrier to fission product release under product release under existing plant existing plant conditions.

conditions.

EXPLOSION:

A rapid, violent, unconfined EXPLOSION:

A rapid, violent, unconfined None combustion, or catastrophic failure of combustion, or catastrophic failure of pressurized/energized equipment that imparts pressurized/energized equipment that imparts energy of sufficient force to potentially energy of sufficient force to potentially damage damage permanent structures, systems, or permanent structures, systems, or components.

components.

EXTORTION:

An attempt to cause an action None The NEI term and definition have been deleted because they at the station by threat of force. are no longer used in NEI 99-01 and is not used in the Hope Creek EALs.FAULTED: (PWRs) in a steam generator, the None The NEI term and definition have been deleted because they existence of secondary side leakage that apply only to PWRs. HCGS is a BWR.results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized.

FIRE: Combustion characterized by heat and FIRE: Combustion characterized by heat and light. None light. Sources of smoke such as slipping drive Sources of smoke such as slipping drive belts or belts or overheated electrical equipment do overheated electrical equipment do not constitute not constitute FIRES. Observation of flame is FIRES. Observation of flame is preferred but is preferred but is NOT required if large NOT required if large quantities of smoke and quantities of smoke and heat are observed, heat are observed.HOSTAGE: A person(s) held as leverage HOSTAGE: A person(s) held as leverage against None against the station to ensure that demands the station to ensure that demands will be met by will be met by the station. the station.15 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification HOSTILE ACTION: An act toward a NPP or HOSTILE ACTION: An act toward Salem or Hope The NEI terms "NPP" and "licensee" have been replaced its personnel that includes the use of violent Creek or its personnel that includes the use of with "Salem or Hope Creek" and "PSEG" to identify the force to destroy equipment, take HOSTAGES, violent force to destroy equipment, take specific entities to which the terms apply.and/or intimidate the licensee to achieve an HOSTAGES, and/or intimidate PSEG to achieve The NEl phrase "owner controlled area" has been changed end. This includes attack by air, land, or water an end. This includes attack by air, land, or water to "OCA" for simplification.

OCA is the approved acronym for using guns, explosives, PROJECTILEs, using guns, explosives, PROJECTILEs, vehicles, owner controlled area.vehicles, or other devices used to deliver or other devices used to deliver destructive force.destructive force. Other acts that satisfy the Other acts that satisfy the overall intent may be overall intent may be included.

HOSTILE included.

HOSTILE ACTION should not be ACTION should not be construed to include construed to include acts of civil disobedience or acts of civil disobedience or felonious acts felonious acts that are not part of a concerted that are not part of a concerted attack on the attack on Salem or Hope Creek. Non-terrorism-NPP. Non-terrorism-based EALs should be based EALs should be used to address such used to address such activities (i.e., this may activities (i.e., this may include violent acts include violent acts between individuals in the between individuals in the OCA).owner controlled area).HOSTILE FORCE: One or more individuals HOSTILE FORCE: One or more individuals who None who are engaged in a determined assault, are engaged in a determined assault, overtly or by overtly or by stealth and deception, equipped stealth and deception, equipped with suitable with suitable weapons capable of killing, weapons capable of killing, maiming, or causing maiming, or causing destruction.

destruction.

IMMINENT:

Mitigation actions have been IMMINENT:

Mitigation actions have been The NEI sentence "Where IMMINENT timeframes are ineffective, additional actions are not ineffective, additional actions are not expected to specified, they shall apply" has been replaced with the expected to be successful, and trended be successful, and trended information indicates phrase "...within approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (unless a different information indicates that the event or that the event or condition will occur within time is specified)" to provide a reasonable estimate of the condition will occur. Where IMMINENT approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (unless a different time is duration over which trended information should be timeframes are specified, they shall apply. specified).

forecasted.

This is a clarification of the NEI 99-01 definition and is consistent with previous training provided to Emergency Coordinators at Hope Creek.INTRUSION:

A person(s) present in a None The NEI term and definition have been deleted because they specified area without authorization.

are no longer used in NEI 99-01 and is not used in the Hope Discovery of a BOMB in a specified area is Creek EALs.indication of INTRUSION into that area by a HOSTILE FORCE.16 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification INDEPENDENT SPENT FUEL STORAGE INDEPENDENT SPENT FUEL STORAGE None INSTALLATION (ISFSI): A complex that is INSTALLATION (ISFSI): A complex that is designed and constructed for the interim designed and constructed for the interim storage storage of spent nuclear fuel and other of spent nuclear fuel and other radioactive radioactive materials associated with spent materials associated with spent fuel storage.fuel storage.NORMAL PLANT OPERATIONS:

Activities at NORMAL PLANT OPERATIONS:

Activities at the None the plant site associated with routine testing, plant site associated with routine testing, maintenance, or equipment operations, in maintenance, or equipment operations, in accordance with normal operating or accordance with normal operating or administrative procedures.

Entry into administrative procedures.

Entry into abnormal or abnormal or emergency operating emergency operating procedures, or deviation procedures, or deviation from normal security from normal security or radiological controls or radiological controls posture, is a departure posture, is a departure from NORMAL PLANT from NORMAL PLANT OPERATIONS.

OPERATIONS.

PROJECTILE:

An object directed toward a PROJECTILE:

An object that impacts Salem The NEI phrase "An object directed toward..." has been NPP that could cause concern for its and/or Hope Creek that could cause concern for changed to "An object that impacts..." because continued operability, reliability, or personnel continued operability, reliability, or personnel ROJECTILES can be the result of an event that was not safety. safety. "directed" at the station but still "impacted the station. For Example, if a ship, plane, vehicle, etc. were to explode near the station a PROJECTILE could impact the stations but it was not "directed" at the station.The NEI "NPP" is "Salem and/or Hope Creek" stations.The NEI phrase "...for its continued operability..." has been changed to "...for continued operability..." to make the sentence flow better.PROTECTED AREA: Typically the site PROTECTED AREA (PA): A security controlled The NEI "site specific area" at HCGS is defined by the specific area which normally encompasses all area within the OWNER-CONTROLLED AREA phrase "A security controlled area within the OWNER-controlled areas within the security (OCA) that is enclosed by the security perimeter CONTROLLED AREA (OCA) that is enclosed by the security PROTECTED AREA fence. fence and monitored by intrusion detection perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper systems." security clearance and is controlled at the Security The NEI phrase "...encompasses all controlled areas within Center. the.. fence" has been deleted because the above description 17 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification of "site specific area" provides a more detailed definition that plant operators can better relate to.The sentence "Access to the PA requires proper security clearance and is controlled at the Security Center" is added clarification the plant operators can better relate to.RUPTURED: (PWRs) in a steam generator, None The NEI term and definition have been deleted because they existence of primary-to-secondary leakage of apply only to PWRs. HCGS is a BWR.a magnitude sufficient to require or cause a reactor trip and safety injection.

SABOTAGE:

Deliberate damage, mis- SABOTAGE:

Deliberate damage, mis-alignment, None alignment, or mis-operation of plant or mis-operation of plant equipment with the intent equipment with the intent to render the to render the equipment inoperable.

Equipment equipment inoperable.

Equipment found found tampered with or damaged due to malicious tampered with or damaged due to malicious mischief may not meet the definition of mischief may not meet the definition of SABOTAGE until this determination is made by SABOTAGE until this determination is made security supervision.

by security supervision.

SECURITY CONDITION:

Any Security Event SECURITY CONDITION:

ANY Security Event as None as listed in the approved security contingency listed in the approved security contingency plan plan that constitutes a threat/compromise to that constitutes a threat/compromise to site site security, threat/risk to site personnel, or a security, threat/risk to site personnel, or a potential potential degradation to the level of safety of degradation to the level of safety of the plant. A the plant. A SECURITY CONDITION does not SECURITY CONDITION does not involve a involve a HOSTILE ACTION. HOSTILE ACTION.SIGNIFICANT TRANSIENT:

An SIGNIFICANT TRANSIENT:

An UNPLANNED The NEI phrase "...event involving one or more of the UNPLANNED event involving one or more of event based on EC judgment, but includes as a following..." has been changed to "...event based on EC the following:

(1) automatic turbine runback minimum any one of the following:

(1) Reactor judgment, but includes as a minimum any one of the greater than 25% thermal reactor power, (2) Scram, (2) Electrical Load Rejection

> 25%, (3) following..." because to allow for EC judgment in determining electrical load rejection greater than 25% full Thermal Reactor Power Reduction

> 25%, (4) if a SIGNIFICANT TRANSIENT has occurred.

At times a electrical load, (3) Reactor Trip, (4) Safety ECCS Injection, or (5) Thermal Power Oscillations number of minor events that occur at the same time could Injection Activation, or (5) thermal power greater than 10%. result in conditions equal to a SIGNIFICANT TRANSIENT.

oscillations greater than 10%. The NEI phrase "(1) automatic turbine runback greater than 25% thermal reactor power" has been changed to "(3)18 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification Thermal Reactor Power Reduction

> 25%" because BWRs are not equipped with automatic turbine runbacks.The NEI phrase "(2) electrical load rejection greater than 25% full electrical load" has been changed to "(2) Electrical Load Rejection

> 25%" because it is clear from the context of the phrase that the percentage load rejection is in relation to the full electrical load.The NEI phrase "(4) Safety Injection Activation" has been changed to "(4) ECCS Injection" to use terminology common to a BWR.The NEI phrase "(3) Reactor Trip" has been changed to "(1)Reactor Scram" to use terminology common to a BWR.STRIKE ACTION: A work stoppage within the None The NEI term and definition have been deleted because they PROTECTED AREA by a body of workers to are no longer used in NEI 99-01 and is not used in the Hope enforce compliance with demands made on Creek EALs.(site specific).

The STRIKE ACTION must threaten to interrupt NORMAL PLANT OPERATIONS.

UNISOLABLE:

A breach or leak that cannot UNISOLABLE:

A breach or leak that cannot be The phrase "from the Control Room" has been added to the be promptly isolated.

promptly isolated from the Control Room. HCGS definition to emphasize the meaning of "promptly." In accordance with NEI basis discussion of example EALs using the term "UNISOLABLE," prompt isolation attempts include automatic isolation and manual action in the Control Room to close isolation valves.UNPLANNED:

A parameter change or an UNPLANNED:

A parameter change or an event None event that is not the result of an intended that is not the result of an intended evolution and evolution and requires corrective or mitigative requires corrective or mitigative actions.actions.VALID: An indication, report, or condition, is VALID: An indication, report, or condition, is None considered to be VALID when it is verified by considered to be VALID when it is verified by (1)(1) an instrument channel check, (2) an instrument channel check, (2) indications on indications on related or redundant indicators, related or redundant indicators, or (3) by direct 19 of 143 EAL Comparison Matrix OSSI HCGS NEI Term and Definition HCGS Term and Definition Difference/Deviation Justification or (3) by direct observation by plant observation by plant personnel, such that doubt personnel, such that doubt related to the related to the indicator's operability, the indicator's operability, the condition's condition's existence, or the report's accuracy is existence, or the report's accuracy is removed. Implicit in this definition is the need for removed. Implicit in this definition is the need timely assessment.

for timely assessment.

VISIBLE DAMAGE: Damage to equipment or VISIBLE DAMAGE: Damage to equipment or None structure that is readily observable without structure that is readily observable without measurements, testing, or analysis.

Damage measurements, testing, or analysis.

Damage is is sufficient to cause concern regarding the sufficient to cause concern regarding the continued operability or reliability of the continued operability or reliability of the affected affected structure, system, or component.

structure, system, or component.

Example Example damage includes:

deformation due damage includes:

deformation due to heat or to heat or impact, denting, penetration, impact, denting, penetration, rupture, cracking, rupture, cracking, and paint blistering.

Surface and paint blistering.

Surface blemishes (e.g., paint blemishes (e.g., paint chipping, scratches) chipping, scratches) should not be included.should not be included.VITAL AREAS: Typically any site specific VITAL AREAS: Typically any site specific areas, None areas, normally within the PROTECTED normally within the PROTECTED AREA, that AREA, that contains equipment, systems, contains equipment, systems, components, or components, or material, the failure, material, the failure, destruction, or release of destruction, or release of which could directly which could directly or indirectly endanger the or indirectly endanger the public health and public health and safety by exposure to radiation.

safety by exposure to radiation.

20 of 143 EAL Comparison Matrix OSSI HCGS Category R Abnormal Rad Levels / Rad Effluent 21 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording and Mode HCGS HCGS IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Any release of gaseous or liquid RU1 Any release of gaseous or liquid Deleted reference to RETS. ODCM limits provide the HCGS radioactivity to the environment radioactivity to the environment site-specific Radiological Effluent Technical Specifications.

greater than 2 times the greater than 2 times the ODCM for 60 Radiological Effluent Technical minutes or longer Specifications/ODCM for 60 OPCON: All minutes or longer.MODE: All NEI Exl Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #VALID reading on ANY of the RUI.1 VALID gaseous monitor reading > Gaseous release is emphasized in this EAL to be consistent following radiation monitors Table R-1 column "UE" with the NEI basis, which states "Some sites may find it greater than the reading shown AND advantageous to address gaseous and liquid releases with for 60 minutes or longer: separate initiating conditions and EALs." (site specific monitor list and > 60 minutes have elapsed (Note 2) The NEI phrase "VALID reading on ANY of the following threshold values) Note 2: The Emergency Coordinator radiation monitors greater than the reading shown ..." has Note: The Emergency Director should NOT wait until the been replaced with "VALID gaseous monitor reading > Table should not wait until the applicable time has elapsed, R-1 column "UE"..." applicable time has elapsed, but but should declare the event

The HCGS radiation monitors that detect radioactivity should declare the event as soon as soon as it is determined effluent release to the environment are listed in Table as it is determined that the that the release duration has R-1.release duration has exceeded, exceeded, or will likely or will likely exceed, the exceed, the applicable time. In ciUE, Alert, SAE and GE thresholds for all HCGS applicable time. In the absence of the absence of data to the continuously monitored gaseous release pathways are data to the contrary, assume that contrary, assume that the listed in Table R-1 to consolidate the information in a the release duration has release duration has single location and, thereby, simplify identification of exceeded the applicable time if exceeded the applicable time the thresholds by the EAL user.an ongoing release is detected if an ongoing release is The value shown in Table R-1 column "UE" for and the release start time is detected and the release start gaseous release points represents two times the unknown. time is unknown. ODCM release limit. The sum of the gaseous release point readings is specified to address the possibility of elevated radioactivity release simultaneously occurring 22 of 143 EAL Comparison Matrix OSSI HCGS NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL i ifrneDvato utfcto at multiple locations.

An asterisk note "For high alarm conditions on offgas pretreatment monitor 9RX621 or 9RX622, refer to EAL SU7.1" has been added to Table R-1. An offgas pretreatment radiation monitor alarm is an abnormal radiological condition and can be reasonably associated with Category R EALs. It is placed in the System Malfunction category to conform to NEI 99-01 guidance, however. The note helps direct the EAL user to the EAL applicable to abnormal offgas radiation.

2 VALID reading on any effluent RU1.2 ANY VALID liquid monitor reading > Liquid release is emphasized in this EAL to be consistent monitor reading greater than 2 Table R-1 column "UE" with the NEI basis, which states "Some sites may find it times the alarm setpoint advantageous to address gaseous and liquid releases with established by a current AND separate initiating conditions and EALs." radioactivity discharge permit for _> 60 minutes have elapsed (Note 2) The NEI phrase "VALID reading on any effluent monitor 60 minutes or longer. Note 2: The Emergency Coordinator reading greater than 2 times the alarm setpoint established Note: The Emergency Director should NOT wait until the by a current radioactivity discharge permit ..." has been should not wait until the applicable time has elapsed, replaced with "ANY VALID liquid monitor reading > Table R-applicable time has elapsed, but but should declare the event 1 column "UE"...." should declare the event as soon as soon as it is determined The HCGS radiation monitors that detect radioactivity as it is determined that the that the release duration has effluent release to the environment are listed in Table R-1.release duration has exceeded, exceeded, or will likely UE, Alert, SAE and GE thresholds for all HCGS continuously or will likely exceed, the exceed, the applicable time. In monitored release pathways are listed in Table R-1 to applicable time. In the absence of the absence of data to the consolidate the information in a single location and, thereby, data to the contrary, assume that contrary, assume that the simplify identification of the thresholds by the EAL user.the release duration has release duration has exceeded the applicable time if exceeded the applicable time The values shown in Table R-1 column "UE" for the liquid an ongoing release is detected if an ongoing release is release points represent two times the ODCM release limits.and the release start time is detected and the release start unknown. time is unknown.3 Confirmed sample analyses for RU1.3 Confirmed sample analyses for The NEI phrase "greater than 2 times (site specific RETS gaseous or liquid releases gaseous or liquid releases indicate values)" has been changed to "> Table R-2 column "UE"..." indicates concentrations or concentrations or release rates > The values shown in Table R-2 column "UE", consistent with release rates greater than 2 times Table R-2 column "UE" the NEI bases, represent 2 times ODCM 3/4.11.1/2 (site specific RETS values) for 60 23 of 143 EAL Comparison Matrix OSSI HCGS NEl Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL ftEAL #minutes or longer. AND concentrations.

Note: The Emergency Director -60 minutes have elapsed (Note 2)should not wait until the applicable time has elapsed, but Note 2: The Emergency Coordinator applcabl tim ha elasedbutshould NOT wait until the should declare the event as soon should ti lathe as it is determined that the applicable time has elapsed, release duration has exceeded, but should declare the event orewlease dutio exce eded, tas soon as it is determined or will likely exceed, theththerlaedaiohs applicable time. In the absence of that the release duration has data to the contrary, assume that exceeded, or will likely the release duration has exceed, the applicable time. In exceeded the applicable time if the absence of data to the an ongoing release is detected contrary, assume that the and the release start time is release duration has unknown. exceeded the applicable time if an ongoing release is detected and the release start time is unknown.4 VALID reading on perimeter N/A N/A Deleted NEI Example EAL #4 because the plant is not radiation monitoring system equipped with a perimeter radiation monitoring system. This greater than 0.10 mR/hr above threshold is properly addressed by the radiation monitors normal* background sustained for listed in Table R-1 and dose assessment capabilities.

60 minutes or longer [for sites having telemetered perimeter monitors]* Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.5 VALID indication on automatic N/A N/A Deleted NEI Example EAL #5 because the plant is not real-time dose assessment equipped with real-time dose assessment.

This threshold is capability greater than (site- properly addressed by the radiation monitors listed in Table specific value) for 60 minutes or R-1 and dose assessment capabilities.

longer [for sites having such 24 of 143 EAL Comparison Matrix OSSI HCGS Table R-1 Effluent Monitor Classification Thresholds*

Release Point Monitor GE SAE ALERT UE*SPDS -(Total) SPDS Point Offsite Gas Rad Release OR OR SUM of: SUM of: FRVS Vent NG 9RX680 N P V5Ec 5.25Ec 3.OE+06 pCi/sec 3.OE+04 pCi/sec IJCi/sec IpCi/sec" M North Plant Vent o NG 9RX590+ +South Plant Vent 9RX580 NG+ +Hardened Torus Vent NG The lesser of the following thresholds:

Liquid Radwaste ->200X the High Alarm Setpoint 2X the High Alarm Discharge 9RX508 ->5.80E-02 uCi/cc Setpoint o >1.50E-02 uCi/cc -CST discharge only The lesser of the following thresholds:

Cooling Tower 9RX506 -> 200X the High Alarm Setpoint 2X the High Alarm".5 Blowdown Setpoint.2" * >1.64E-03 pCi/cc The lesser of the following thresholds:

> 200X the High Alarm Setpoint TB Circ Water 9RX505 -> 4.80E-04 pCi/cc -for 2X the High Alarm Discharge continuous release Setpoint* >5.80E-02 uCi/cc for batch release* For high alarm conditions on offgas pretreatment monitor 9RX621 or 9RX622, refer to EAL SU7.1 25 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording and Mode HCGS HCGS IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU2 Unplanned rise in plant radiation RU2 UNPLANNED rise in plant radiation None levels levels MODE: All OPCON: All NEI Ex. HCGS HGS EAL Wording NEI Example EAL Wording E AL # Difference/Deviation Justification EAL # EAL #1 a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the The NEI phrase "...a reactor refueling pathway as indicated by drop in a reactor refueling reactor cavity or spent fuel pool (SFP) (site specific level or indication).." has been changed to "the pathway as indicated by (site as indicated by ANY of the following:

reactor cavity or spent fuel pool (SFP) as indicated by ANY of specific level or indication).

the following:

..." for clarification.

During the fuel transfer AND Annunciator D1-A5 (FUEL phase of refueling operations, the fuel pool gates are removed b. VALID Area Radiation POOL LEVEL HI/LO) and the reactor cavity is in direct communication with the spent fuel pool. Therefore the refueling pathway is defined by Monitor reading rise on (site

Reactor Water Level the reactor cavity and SFP.specific list). Shutdown Range Indicator LI- The "site specific" indications are low SFP or cavity level 4605-B21 alarms, reactor cavity level instrument or visual observation,* Visual observation (local or local or remote (cameras).

remote) The "site-specific" radiation monitors are those located on the AND refuel floor because radiation levels in this area is likely to be affected by the loss of inventory from the refueling cavity, and VALID area radiation monitor reading spent fuel pool.rise on ANY of the following:

Spent Fuel Storage Pool Area (9RX707)* New Fuel Criticality A Rad (9RX612)* New Fuel Criticality B Rad (9RX613)o Temporary Refueling Bridge ARM 27 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSI HCGS Table R-2 Effluent Sample Classification Thresholds Release Point Sample ALERT UE NG 7.10E-01 pCi/cc 7.10E-03 pCi/cc FRVS Vent 1-131 8.20E-04 pCi/cc 8.20E-06 pCi/cc 0 NG 1.52E-01 pCi/cc 1.52E-03 pCi/cc 0North Plant Vent (D 1-131 1.80E-04 pCi/cc 1.80E-06 pCi/cc (U Su NG 1.44E-02 pCi/cc 1.44E-04 pCi/cc South Plant Vent 1-131 1.68E-05 pCi/cc 1.68E-07 pCi/cc Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Liquid Radwaste Discharge Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1'S Cooling Tower Blowdown Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 0"-J TB Circ Water Discharge Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 Unmonitored Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 26 of 143 EALComarion atrx OSI CG EAL Comparison Matrix OSSI HCGS 2 UNPLANNED VALID Area RU2.2 UNPLANNED VALID area radiation The term "indicate a..." has been deleted for proper English.Radiation Monitor readings or monitor readings or survey results rise The NEI asterisks and note have been changed to Note 7.survey results indicate a rise by by a factor of 1,000 over normal levels Numbering this information facilitates referencing in the EAL a factor of 1000 over normal* (Note 7) matrix.levels. Note 7: Normal levels can be*Normal levels can be considered as the considered as the highest The NEI term "twenty-four" has been replaced with Arabic highest reading in the past twenty-four numerals for clarification.

hours excluding the current peak value, reading in the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months excluding the current peak value 28 of 143 EAL Comparison Matrix OSSI HCGS HOGS NEI IC# NEI IC Wording IC#s HCGS IC Wording Difference/Deviation Justification IC#(s)AA1 Any release of gaseous or liquid RA1 Any release of gaseous or liquid Deleted reference to RETS. ODCM limits provide the HCGS radioactivity to the environment radioactivity to the environment site-specific Radiological Effluent Technical Specifications.

greater than 200 times the greater than 200 times the ODCM for Radiological Effluent Technical 15 minutes or longer Specifications/ODCM for 15 minutes or longer. OPOON: All MODE: All NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 VALID reading on ANY of the RA1.1 VALID gaseous monitor reading > Gaseous release is emphasized in this EAL to be consistent following radiation monitors Table R-1 column "ALERT" with the NEI basis, which states ""Some sites may find it greater than the reading shown advantageous to address gaseous and liquid releases with for 15 minutes or longer: AND separate initiating conditions and EALs." (site specific monitor list and _ 15 minutes have elapsed (Note 2) The NEI phrase "VALID reading on ANY of the following threshold values) Note 2: The Emergency Coordinator radiation monitors greater than the reading shown ..." has Note: The Emergency Director should NOT wait until the been replaced with "VALID gaseous monitor reading > Table should not wait until the applicable time has elapsed, R-1 column "ALERT"..." applicable time has elapsed, but but should declare the event

The HCGS radiation monitors that detect radioactivity should declare the event as soon as soon as it is determined effluent release to the environment are listed in Table R-as it is determined that the that the release duration has 1.release duration has exceeded, exceeded, or will likely or will likely exceed, the exceed, the applicable time. In UE, Alert, SAE and GE thresholds for all HOGS applicable time. In the absence of the absence of data to the continuously monitored gaseous release pathways are data to the contrary, assume that contrary, assume that the listed in Table R-1 to consolidate the information in a the release duration has release duration has single location and, thereby, simplify identification of the exceeded the applicable time if exceeded the applicable time thresholds by the EAL-user.an ongoing release is detected if an ongoing release is The value shown in Table R-1 column "Alert" for and the release start time is detected and the release start gaseous release points represents two hundred times unknown. time is unknown. the ODCM release limits. The sum of the gaseous release point readings is specified to address the possibility of elevated radioactivity release 29 of 143 EAL Comparison Matrix 0551 HCGS simultaneously occurring at multiple locations.

2 VALID reading on any effluent RAlI .2 ANY VALID liquid monitor reading > The NEI phrase "VALID reading on any effluent monitor monitor reading greater than 200 Table R-1 column "ALERT" reading greater than 200 times the alarm setpoint established times the alarm setpoint ADby a current radioactivity discharge permit .."has been established by a current ADreplaced with "ANY VALID liquid monitor reading > Table R-1 radioactivity discharge permit for >- 15 minutes have elapsed (Note 2) column "ALERT" ..15 minutes or longer. Note 2: The Emergency Coordinator Liquid release is emphasized in this EAL to be consistent with Note: The Emergency Director should NOT wait until the the NEI basis, which states "Some sites may find it should not wait until the applicable time has elapsed, advantageous to address gaseous and liquid releases with applicable time has elapsed, but but should declare the event separate initiating conditions and EALs." should declare the event as soon as soon as it is determined The HCGS radiation monitors that detect radioactivity effluent as it is determined that the that the release duration has release to the environment are listed in Table R-1. UE, Alert, release duration has exceeded, exceeded, or will likely SAE and GE thresholds for all HCGS continuously monitored or will likely exceed, the exceed, the applicable time. In release pathways are listed in Table R-1 to consolidate the applicable time. In the absence of the absence of data to the information in a single location and, thereby, simplify data to the contrary, assume that contrary, assume that the identification of the thresholds by the EAL user.the release duration has release duration has The values shown in Table R-1 column "Alert" represent two exceeded the applicable time if exceeded the applicable time an ongoing release is detected if an ongoing release is hundred times the ODCM release limits.and the release start time is detected and the release start unknown. time is unknown.3 Confirmed sample analyses for RAII .3 Confirmed sample analyses for The NEI phrase "greater than 200 times (site specific RETS gaseous or liquid releases gaseous or liquid releases indicate values)" has been changed to '5 Table R-2 column indicates concentrations or concentrations or release rates > "ALERT"...

release rates greater than 200 Table R-2 column "ALERT" The values shown in Table R-2 column "UE", consistent with times (site specific RETS values) AND the NEI bases, represent 200 times ODCM 3/4.11.1/2 for 15 minutes or longer. concentrations.

Note: The Emergency Director 15 minutes have elapsed (Note 2)should not wait until the Note 2: The Emergency Coordinator applicable time has elapsed, but should NOT wait until the should declare the event as soon applicable time has elapsed, as it is determined that the but should declare the event release duration has exceeded, as soon as it is determined or will likely exceed, the that the release duration has applicable time. In the absence of exceeded, or will likely data to the contrary, assume that exceed, the applicable time. In the release duration has the absence of data to the _____________________________

30 of 143 EAL Comparison Matrix OSSI HCGS exceeded the applicable time if contrary, assume that the an ongoing release is detected release duration has and the release start time is exceeded the applicable time unknown. if an ongoing release is detected and the release start time is unknown.4 VALID reading on perimeter radiation monitoring system reading greater than 10.0 mR/hr above normal* background for 15 minutes or longer. [for sites having telemetered perimeter monitors]* Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.N/A N/A Deleted NEI Example EAL #4 because the plant is not equipped with a perimeter radiation monitoring system. This threshold is properly addressed by the radiation monitors listed in Table R-1 and dose assessment capabilities.

VALID indication on automatic N/A N/A Deleted NEI Example EALs #5 because the plant is not real-time dose assessment equipped with and real-time dose assessment.

This threshold capability indicating greater than is properly addressed by the radiation monitors listed in Table (site specific value) for 15 R-1 and dose assessment capabilities.

minutes or longer. [for sites having such capability]

31 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS HCGS NEI IC# NEI IC Wording IC#(s) HCGS IC Wording Difference/Deviation Justification AA2 Damage to irradiated fuel or RA2 Damage to irradiated fuel or loss of Replaced the term "Reactor Vessel" with "RPV" as this is the loss of water level that has water level that has or will resulted in common terminology for BWRs.resulted or will result in the the uncovering of irradiated fuel outside uncovering of irradiated fuel the RPV outside the reactor vessel. OPCON: All MODE: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 A water level drop in the reactor RA2.2 A water level drop in the reactor cavity The NEI phrase "fuel transfer canal" has been deleted. The refueling cavity, spent fuel pool or spent fuel pool that will result in HCGS reactor cavity is separated from the spent fuel pool by or fuel transfer canal that will irradiated fuel becoming uncovered the fuel pool gates and bellows seal. This design does not result in irradiated fuel becoming have a fuel transfer canal. During the fuel transfer phase of uncovered.

refueling operations, the fuel pool gates are removed and the reactor cavity is in direct communication with the spent fuel pool.2 A VALID alarm or (site specific RA2.1 Damage to irradiated fuel or loss of Reordered the wording of the EAL to clarify that the increased elevated reading) on ANY of the water level (uncovering irradiated fuel radiation levels are the result of damage or uncovering of following due to damage to outside the RPV) that causes a VALID irradiated fuel.irradiated fuel or loss of water high alarm on ANY of the following Incorporated the IC wording to clarify that the EAL threshold is level. radiation monitors:

based on uncovering irradiated fuel outside the RPV.(site specific radiation monitors)

Spent Fuel Storage Pool Area The NEI phrase "VALID alarm" has been changed to "VALID (9RX707) high alarm" because it is the high alarm signal associated with"New Fuel Criticality A Rad the listed radiation monitors that warns of elevated radiation (9RX612) levels anticipated if spent fuel were to become uncovered.

The listed radiation monitors represent the site-specific

New Fuel Criticality B Rad euvlns (9RX613)equivalents.

(9RX61 3)" Refuel Floor Exhaust Duct Rad Channel A (9RX627)" Refuel Floor Exhaust Duct Rad 32 of 143 omparison Matrix EAL Cmparson atri0OSS HOGS Channel B (9RX628)*Refuel Floor Exhaust Duct Rad Channel C (9RX629)33 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)AA3 Rise in radiation levels within the RA3 Rise in radiation levels within the None facility that impedes operation of facility that impedes operation of systems required to maintain systems required to maintain plant plant safety functions.

safety functions MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL #1 Dose rate greater than 15 mR/hr RA3.1 Dose rates > 15 mR/hr in the Control The NEI phrase "ANY of the following areas requiring in ANY of the following areas Room (9RX710) continuous occupancy to maintain plant safety functions: (site requiring continuous occupancy specific area list)" has been changed to "the Control Room to maintain plant safety (9RX71 0)" because the only continuously occupied area at functions:

HCGS needed to maintain plant safety functions is the Control Room. The HCGS RadWaste Control Room is not required to (site specific area list) be continuously occupied in order to maintain plant safety functions.

Security alarm stations are located in the Salem Generating Station and are addressed in the Salem EALs.9RX710 monitors area radiation level in the Control Room.There is no permanently installed CAS area radiation monitor that may be used to assess this EAL threshold.

34 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification lO#(s)AS1 Off-site dose resulting from an RS1 Offsite dose resulting from an actual or None actual or IMMINENT release of imminent release of gaseous gaseous radioactivity greater radioactivity greater than 100 mRem than 100 mrem TEDE or 500 TEDE or 500 mRem thyroid CDE for mrem Thyroid CDE for the actual the actual or projected duration of the or projected duration of the release release. OPCON: All MODE: All NEI Ex. NEl Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 VALID reading on ANY of the RS1.1 VALID gaseous monitor reading > The NEI phrase "VALID reading on ANY of the following following radiation monitors Table R-1 column "SAE" radiation monitors greater than the reading shown ..." has greater than the reading shown AND been replaced with "VALID gaseous monitor reading > Table for 15 minutes or longer: R-1 column "SAE"..." (site-specific list) Dose assessment results are NOT

The HCGS radiation monitors that detect radioactivity available effluent release to the environment are listed in Table R-The Emergency Director should not wait until the applicable time AND 1.has elapsed, but should declare > 15 minutes have elapsed (Note 1)

UE, Alert, SAE and GE thresholds for all HCGS the event as soon as it is continuously monitored gaseous release pathways are determined that the condition will Note 1: If dose assessment results listed in Table R-1 to consolidate the information in a likely exceed the applicable time. are available, declaration single location and, thereby, simplify identification of the If dose assessment results are should be based on dose thresholds by the EAL-user.available, declaration should be assessment (EAL RS1.2)based on dose assessment instead of gaseous monitor g The value shown in Table R-1 column "SAE" for instead of radiation monitor values. Do NOT delay gaseous release points represents 10% of the EPA PAG values. Do not delay declaration declaration awaiting dose for gaseous release. The sum of the gaseous release awaiting dose assessment assessment results. point readings is specified to address the possibility of results. elevated radioactivity release simultaneously occurring The Emergency Coordinator at multiple locations.

should NOT wait until the applicable time has elapsed, The condition "AND Dose assessment results are NOT but should declare the event available" has been added to the plant EAL to emphasize the 35 of 143 EAL Comparison Matrix OSSI HCGS as soon as it is determined importance dose assessment results and use of this EAL.that the condition will likely The first and second sentences of the note have been exceed the applicable time. reversed and "(EAL RS1.2)" has been added to the note to emphasize the importance of dose assessment results.2 Dose assessment using actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the site boundary.RS1.2 Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA)The NEI phrase "doses greater than 100 mrem TEDE or 500 mrem thyroid CDE" has been changed to "TEDE 4-day dose >4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem" because the TEDE 4-day dose (output of PSEG dose assessment model -MIDAS) assumes a 4 hr release duration.

To obtain the approximate dose for a projected release condition of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+02 mRem correspond directly to a TEDE dose rate value of 100 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mRem correspond directly to an CDE dose rate value of 500 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The NEI phrase "site boundary" has been replaced with"MINIMUM EXCLUSION AREA (MEA)." The MEA is the boundary used in the MIDAS dose assessment program that most closely approximates the site are boundary.

For Hope Creek the MEA is 0.56 miles.VALID perimeter radiation N/A N/A Deleted NEI Example EAL #3 because the plant is not monitoring system reading equipped with a perimeter radiation monitoring system. This greater than 100 mR/hr for 15 threshold is properly addressed by the radiation monitors minutes or longer. [for sites listed in Table R-1 and dose assessment capabilities.

having telemetered perimeter monitors]Field survey results indicate RS1.3 Field survey results indicate closed Split the example into two logical conditions separated by the closed window dose rates window dose rates > 100 mRem/hr "OR" logical connector for usability.

greater than 100 mR/hr expected expected to continue for > 1 hr at or The NEI abbreviation "R" has been replaced with the plant to continue for 60 minutes or beyond the PROTECTED AREA term "Rem" to agree with units of measure given in the EPA longer; or analyses of field BOUNDARY PAGs.survey samples indicate thyroid CDE greater than 500 mrem for The NEI phrase "one hour" has been abbreviated "1 hr" to 36 of 143 EAL Comparison Matrix 0381 HOGS EAL Comparison Matrix OSSI HCGS one hour of inhalation, at or beyond the site boundary.OR Analyses of field survey samples indicate 1-131 concentration

> 3.85E-07 [iCi/cc at or beyond the PROTECTED AREA BOUNDARY reduce EAL-user reading burden.The NEI phrase "thyroid CDE greater than 500 mrem for one hour of inhalation" has been changed to "1-131 concentration

>3.85E-07 pCi/cc" because the Iodine-1 31 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 500 mRem/hr for I-131.The NEI phrase "site boundary" has been changed to "the PROTECTED AREA BOUNDARY" because it is the only definable and accessible location to obtain field survey dose rate readings or to obtain field samples. The Salem/Hope Creek site is situated on Artificial Island, bordered by the Delaware River on one side and marshy wetlands on the other sides. Neither the defined Site Boundary nor the Minimum Exclusion Area boundary (used in lieu of the Site Boundary for the purpose of dose assessment) would be accessible to offsite field survey teams. Onsite survey teams dispatched to the Protected Area boundary would be the most practical location for detection of adverse radiological conditions at or beyond the site boundary.L _______ .1 ________________________________

1 ___________________________________________________

37 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)AG1 Off-site dose resulting from an RG1 Offsite dose resulting from an Deleted the words "...using actual meteorology." The use of actual actual or IMMINENT release of actual or imminent release of meteorology is only applicable to example EAL #2. Example EAL #1 gaseous radioactivity greater gaseous radioactivity greater than is based on annual average meteorology.

This is consistent with IC than 1000 mrem TEDE or 5000 1,000 mRem TEDE or 5,000 AS1.mrem Thyroid CDE for the mRem thyroid CDE for the actual actual or projected duration of or projected duration of the the release using actual release meteorology.

OPCON: All MODE: All NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 VALID reading on ANY of the RG1.1 VALID gaseous monitor reading > The NEI phrase "VALID reading on ANY of the following radiation following radiation monitors Table R-1 column "GE" monitors greater than the reading shown ..." has been replaced with greater than the reading shown "VALID gaseous monitor reading > Table R-1 column "GE"..." for 15 minutes or longer: AND f The HCGS radiation monitors that detect radioactivity (site specific monitor list and Dose assessment results are NOT effluent release to the environment are listed in Table R-1.threshold values) available t UE, Alert, SAE and GE thresholds for all HCGS The Emergency Director should AND continuously monitored gaseous release pathways are not wait until the applicable time > 15 minutes have elapsed (Note listed in Table R-1 to consolidate the information in a single has elapsed, but should declare 1) location and, thereby, simplify identification of the the event as soon as it is thresholds by the EAL-user.determined that the condition Note 1: If dose assessment will likely exceed the applicable results are available, The value shown in Table R-1 column "GE" for gaseous time. If dose assessment results declaration should be release points represents 100% of the EPA PAG for are available, declaration should based on dose gaseous release. The sum of the gaseous release point be based on dose assessment assessment (EAL RG1.2) readings is specified to address the possibility of elevated instead of radiation monitor instead of gaseous radioactivity release simultaneously occurring at multiple values. Do not delay declaration monitor values. Do NOT locations.

awaiting dose assessment delay declaration awaiting The condition "AND Dose assessment results are NOT available" results. dose assessment results.'

has been added to the plant EAL to emphasize the importance dose The Emergency assessment results and use of this EAL.38 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Coordinator should NOT The first and second sentences of the note have been reversed and wait until the applicable

"(EAL RG1.2)" has been added to the note to emphasize the time has elapsed, but importance of dose assessment results.should declare the event as soon as it is determined that the condition will likely exceed the applicable time.2 Dose assessment using actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond the site boundary.KU1 .Z Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+03 mRem or Thyroid CDE dose > 2.OE+04 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA)The NEI phrase "doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE" has been changed to "TEDE 4-day dose >4.OE+03 mRem or Thyroid CDE dose > 2.OE+04 toRem" because the dose assessment output (from MIDAS) on the SSCL is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration.

To obtain the approximate dose for a projected release condition of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the TEDE 4-day dose value would need to be divided by 4.A TEDE 4-Day Dose > 4.OE+03 mRem correspond directly to a TEDE dose rate value of 1000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose >2.OE+04 mRem correspond directly to an CDE dose rate value of 5000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The NEI phrase "site boundary" has been replaced with "MINIMUM EXCLUSION AREA (MEA)." The MEA is the boundary used in the MIDAS dose assessment program that most closely approximates the site are boundary.

For Hope Creek the MEA is 0.56 miles.3 VALID perimeter radiation N/A N/A Deleted NEI Example EAL #3 because the plant is not equipped monitoring system reading with a perimeter radiation monitoring system. This threshold is greater than 1000 mR/hr for 15 properly addressed by the radiation monitors listed in Table R-1 and minutes or longer. [for sites dose assessment capabilities.

having telemetered perimeter monitors]4 Field survey results indicate RG1.3 Field survey results indicate closed Split the example into two logical conditions separated by the "OR" closed window dose rates window dose rates > 1000 logical connector for usability.

greater than 1000 mR/hr 39 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS expected to continue for 60 minutes or longer; or analyses of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation, at or beyond site boundary.mRem/hr expected to continue for> 1 hr at or beyond the PROTECTED AREA BOUNDARY OR Analyses of field survey samples indicate 1-131 concentration>

3.85E-06 pCi/cc at or beyond the PROTECTED AREA BOUNDARY The NEI abbreviation "R" has been replaced with the plant abbreviation "Rem" to agree with units of measure given in the EPA PAGs.The NEI phrase "thyroid CDE greater than 5000 mrem for one hour of inhalation" has been changed to "1-131 concentration

> 3.85E-06 p.Ci/cc" because the Iodine-1 31 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 5000 mRem/hr for 1-131.The NEI phrase "site boundary" has been changed to "the PROTECTED AREA BOUNDARY" because it is the only definable and accessible location to obtain field survey dose rate readings or to obtain field samples. The Salem/Hope Creek site is situated on Artificial Island, bordered by the Delaware River on one side and marshy wetlands on the other sides. Neither the defined Site Boundary nor the Minimum Exclusion Area boundary (used in lieu of the Site Boundary for the purpose of dose assessment) would be accessible to offsite field survey teams. Onsite survey teams dispatched to the Protected Area boundary would be the most practical location for detection of adverse radiological conditions at or beyond the site boundary.40 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Category C Cold Shutdown I Refueling System Malfunction 41 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification lC#(s)CUl RCS Leakage CU3 Unplanned loss of RPV The IC has been changed from "RCS Leakage" to "Unplanned loss MODE: Cold Shutdown inventory of RPV inventory" to align with NEI generic IC CU2. The example OPCON: 4 -Cold Shutdown EALs of NEI CU1 manifest RCS leakage through loss of RPV inventory conditions.

The intent of the two ICs is identical.

This allows the HCGS-related EAL to be numbered with the other loss of inventory based EALs CU2.2 and CU2.3 which are derived from generic IC CU2.NEI E NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #RCS leakage results in the CU3.1 RCS leakage results in the +12.5 in. is the site specific low RPV level RPS actuation setpoint.inability to maintain or restore inability to maintain or restore RPV level greater than (site RPV level > +12.5 in.specific low level RPS actuation setpoint) for 15 minutes or longer. [BWR] _ 15 minutes have elapse Note: The Emergency (Note 3)Director should not wait until Note 3: The Emergency the applicable time has Coordinator should elapsed, but should declare the NOT wait until the event as soon as it is applicable time has determined that the condition elapsed, but should will likely exceed the applicable declare the event as time. soon as it is determined that the condition will likely exceed the applicable time.42 of 143 EAL Comparison Matrix OSSI HCGS 1 RCS leakage results in the N/A N/A The PWR portion of the NEI EAL has not been implemented because inability to maintain or restore HCGS is a BWR.level within (site specific pressurizer or RCS/RPV level target band) for 15 minutes or longer. [PWR]43 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CU2 UNPLANNED loss of RCS/RPV CU3 UNPLANNED loss of RPV The NEI acronym "RCS/RPV" has been replaced with "RPV" to use inventory inventory terminology commonly accepted at BWRs.MODE: Refueling OPCON: 5 -Refueling NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #UNPLANNED RCS/RPV level CU3.3 UNPLANNED RPV level drop as +217.5 in. is the indicated level corresponding to the elevation of the drop as indicated by either of the indicated by EITHER of the RPV flange.following:

following:

The NEI phrase "RCS level band.. .when the RCS/RPV level band is* RCS/RPV water level o RPV level drop below the established below the RPV flange" has been changed to "planned drop below the RPV RPV flange level of +217.5 RPV level band (when RPV level is being controlled below the RPV flange for 15 minutes or in. > 15 minutes (Notes 3 flange) for a given (planned) evolution" for clarification..

longer when the and 8) Note 8 has been added to ensure classification requirements due to RCS/RPV level band is the radiological consequences of a loss of inventory are addressed.

established above the o RPV level drop below the RPV flange. planned RPV level band* RCS/RPV water level RPV level drop below the drop below the RCS planned RPV level band level band for 15 (when RPV level is being minutes or longer when controlled below the RPV the RCS/RPV level band flange) for a given (planned)is established below the evolution

> 15 minutes RPV flange. (Notes 3 and 8)Note: The Emergency Director Note 3: The Emergency should not wait until the Coordinator should NOT applicable time has wait until the applicable elapsed, but should time has elapsed, but declare the event as should declare the event soon as it is determined as soon as it is that the condition will determined that the likely exceed the condition will likely applicable time. exceed the applicable 44 of 143 EAL Comparison Matrix OSSI HCGS time.Note 8 Loss of inventory in the refueling pathway may raise radiation levels.Consider classification under EAL RU2.1.2 RCS/RPV level cannot be CU3.2 RPV level CANNOT be The NEI phrase "with a loss of..." has been changed to "AND a loss monitored with a loss of monitored of..." for clarification.

RCS/RPV inventory as indicated AND Table C-i lists the site-specific sumps and tank level conditions that by an unexplained level rise in (site specific sump or tank). A loss of RPV inventory as could be indicative of a loss of inventory from the RPV. Drywell indicated specic unvexplyaind equipment and floor drain sump level rise is the normal method of indicated by ANY unexplained monitoring and calculating leakage from the RPV. With RHR System C-1 (Note 8) operating in the Shutdown Cooling mode, an unexplained rise in suppression pool level could be indicative of RHR valve Note 8 Loss of inventory in the misalignment or leakage. Visual observation of leakage from refueling pathway may systems connected to the RCS in areas outside the Primary raise radiation levels. Containment that cannot be isolated could be indicative of a loss of Consider classification RPV inventory.

under EAL RU2.1. Note 8 has been added to ensure classification requirements due to the radiological consequences of a loss of inventory are addressed.

45 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table C-1 RPV Leakage Indications

Drywell equipment drain sump level rise* Drywell floor drain sump level rise* Reactor Building equipment drain sump level rise" Reactor Building floor drain sump level rise* Suppression pool level rise* Observation of RCS leakage that is UNISOLABLE 46 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification AC power capability to emergency busses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in station blackout MODE: Cold Shutdown, Refueling Cul AC power capability to vital buses reduced to a single power source for 15 minutes or longer such that ANY additional single failure would result in complete loss of AC power to vital buses OPCON: 4 -Cold Shutdown, 5 -Refueling"Vital buses" is equivalent to the NEI phrase "emergency buses." The term "station blackout" was replaced with "complete loss of AC power to vital buses" as this describes the intended condition leading to the Alert threshold in CA1.1. Station Blackout is not an operationally defined term for loss of all AC to vital buses.NEI Ex. NIEapeELWrig HOGS HG A odn ENEI Example EAL Wording HCGS EAL Wording Difference/Deviation Justification EAL T EAL #a. AC power capability to (site CU1.1 Loss of 4.16 KV Vital Bus Power 4.16 KV vital buses are the HCGS emergency buses.specific emergency busses) Sources (Offsite and Onsite) The NEI phrase "AC power capability to (site specific emergency reduced to a single power which results in the availability of busses) reduced to a single power source" has been changed to source for 15 minutes or only one 4.16 KV Vital Bus "Loss of 4.16 KV Vital Bus Power Sources (Offsite and Onsite) which longer Power Source (Offsite or Onsite) results in the availability of only one 4.16 KV Vital Bus Power Source AND AND (Offsite or Onsite)" to reflect the specific HCGS vital power b. Any additional single power > 15 minutes have elapsed configuration.

source failure will result in (Note 3) The AND logic used in NEI 99-01 is improper as the second station blackout.

condition is not a separate condition of equal weight but rather a Note 3: The Emergency qualifier of the first. The threshold statement has been reworded to Note: The Emergency Director Coordinator should NOT properly reflect the intent.should not wait until the wait until the applicable applicable time has time has elapsed, but Station Blackout is not an operationally defined term for loss of all elapsed, but should should declare the event AC to vital buses.declare the event as as soon as it is soon as it is determined determined that the that the condition will condition will likely likely exceed the exceed the applicable applicable time. time.47 of 143 EAL Comparison Matrix OSSI HCGS 48 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)UNPLANNED loss of decay heat CU4 UNPLANNED loss of decay heat None removal capability with irradiated removal capability with irradiated fuel in the RPV fuel in the RPV MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling NEI Ex. HOGS HG A odn NEI Example EAL Wording HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 UNPLANNED event results in CU4.1 An UNPLANNED Loss of Decay The NEI phrase "UNPLANNED event results in" has been changed RCS temperature exceeding the Heat Removal functions to "An UNPLANNED Loss of Decay Heat Removal functions AND" Technical Specification cold for clarification.

According to the NEI IC and basis discussion, the shutdown temperature limit. Aevent of interest involves the loss of decay heat removal capability.

ROS Temperature has risen to> 200'F is the HCGS Technical Specification cold shutdown 200OF temperature limit and has been added for clarification.

The NEI phrase "... exceeding the Technical Specification cold shutdown temperature limit" has been replaced with " has risen to >2001F" for simplification.

200'F is universally understood to be the HCGS Technical Specification cold shutdown temperature limit.2 Loss of all RCS temperature and CU4.2 An UNPLANNED Loss of Decay The phrase ""An UNPLANNED Loss of Decay Heat Removal RCS/RPV level indication for 15 Heat Removal functions functions AND" has been added for clarification.

According to the minutes or longer. AND NEI IC and basis discussion, the event of interest involves the loss Note: The Emergency Director of decay heat removal capability.

should not wait until the Loss of BOTH of the following:

Reformatted the NEI EAL to improve readability.

applicable time has

All RCS Temperature elapsed, but should indication declare the event as soon as it is determined

° All RPV level indication that the condition will AND likely exceed the applicable time. > 15 minutes have elapsed (Note 3)49 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.50 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CU6 Loss of all On-site or Off-site CU5 Loss of all onsite or offsite None communications capabilities communications capabilities MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling, Defueled Refueling, D -Defueled NEI Ex. NEI Example EAL Wording HCGS HOGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of all of the following on-site CU5.1 Loss of all Table C-4 Onsite CU5.1 implements Example EALs #1 and #2. These were communication methods affecting communication methods affecting combined for improved usability.

the ability to perform routine the ability to perform routine The NEI example EALs specify site-specific lists of onsite and operations:

operations offsite communications methods. The HCGS EAL lists these (site specific list of OR methods in Table C-4 for simplification.

communications methods) Loss of all Table 0-4 Offsite 2 Loss of all of the following off-site communication methods affecting communication methods affecting the ability to perform offsite the ability to perform offsite notifications notifications: (site specific list of communications methods)51 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table C-4 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics)

X Station Radio System X................................................

........ .................

............................

...............

.................

........................................

...... ..................................................

................

............

.............

.........

...............

Nuclear Emergency Telephone System X (NETS)Centrex Phone System (ESSX) X NRC (ENS) X 52 of 143 EAL Comparison Matrix OSSI HCGS HCGS NEI IC# NEI IC Wording C#(s) HCGS IC Wording Difference/Deviation Justification CU7 Loss of required DC power for CU2 Loss of required DC power for None 15 minutes or longer 15 minutes or longer MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling NEl Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Less than (site specific bus CU2.1 Loss of ANY of the following The NEI phrase "Less than.. .on required..

busses..." has been voltage indication) on required Vital 125 V DC Power Channel replaced with "Loss of ANY of the following Vital 125 V DC Power (site specific Vital DC busses) combinations as indicated by Channel combinations as indicated by Voltage < 108 V DC" per for 15 minutes or longer. Voltage < 108 V DC: Technical Specifications for DC power capabilities in Modes 4 and 5.Note: The Emergency

Channel A and Channel B 108 VDC is the site-specific bus voltage.Director should not wait The listed 125 VDC Power Channels are the site-specific vital DC until the applicable time

Channelr , Channel C buses. Technical Specifications define the required power channels has elapsed, but should (either bus) and Channel and combinations of power channels.

These have been added to the declare the event as D (either bus) HCGS EAL for clarification.

soon as it is determined

Channel B, Channel C that the condition will (either bus) and Channel likely exceed the D (either bus)applicable time.AND> 15 minutes have elapsed (Note 3)Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable 53 of 143 EAL Comparison Matrix OSSI HCGS I I I Itime.54 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CU8 Inadvertent criticality CU6 Inadvertent criticality None MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling EL # NEI Example EAL Wording EAL HCGS EAL Wording Difference/Deviation Justification NE Eapl ALWrdn EAL#1 UNPLANNED sustained positive period observed on nuclear instrumentation. (BWR)CU6.1 UNPLANNED sustained positive period observed on nuclear instrumentation None-F 4 1 UNPLANNED sustained positive startup rate observed on nuclear instrumentation. (PWR)N/A N/A NEI PWR Example EAL #1 has not been implemented because it applies only to PWR plants. HCGS is a BWR.55 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CA1 Loss of RCS/RPV inventory CA3 Loss of RPV inventory The acronym "RCS" is not included to use terminology familiar to a MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -BWR.Refueling Refueling NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #Loss of RCS/RPV inventory as CA3.1 RPV compensated level < -38 The NEI phrase "Loss of RCS inventory as indicated by..." has been indicated by level less than (site in. deleted (two places) because it is obvious from the low-low ECCS specific level), actuation setpoint water level (-38 in.) that inventory in the RCS has been lost. This change has been made to reduce EAL-user reading[Low-Low ECCS actuation burden and thereby promote timely and accurate emergency setpoint /Level 2 (BWR)J classifications.

The remainder of the plant EAL clearly associates the[Bottom ID of the RCS loop threshold parameters with the inventory in the RPV.(PWR)] The term "compensated" has been added to the HCGS EAL to ensure readings from RPV water level instrumentation are properly adjusted for off-calibration conditions.

In cold conditions, SPDS provides compensated readings and compensation curves are included in the Integrated Operating procedures to help correlate an indicated RPV level reading to actual RPV level.HCGS is a BWR and is not equipped with the PWR RCS loop hot leg penetration.

2 RCS/RPV level cannot be CA3.2 RPV level CANNOT be The acronym "RCS" is not included to use terminology familiar to a monitored for 15 minutes or monitored for > 15 minutes with BWR.longer with a loss of RCS/RPV a loss of RPV inventory as inventory as indicated by an indicated by ANY~ unexplained Table C-i lists the site-specific sumps and tank level conditions that unexplained level rise in (site RCS leakage indication, Table could be indicative of a loss of inventory from the RPV. Drywell unexplained levl orise tnkC (siee i , Tequipment and floor drain sump level rise is the normal method of specific sump or tank). C-11 (Note 3) monitoring and calculating leakage from the RPV. With RHR System Note:The Emergency Director Note 3: The Emergency operating in the Shutdown Cooling mode, an unexplained rise in should not wait until the Coordinator should suppression pool level could be indicative of RHR valve misalignment applicable time has NOT wait until the or leakage. Visual observation of leakage from systems connected to elapsed, but should applicable time has the RCS in areas outside the Primary Containment that cannot be 56 of 143 EAL Comparison Matrix OSSI HCGS declare the event as soon elapsed, but should isolated could be indicative of a loss of RPV inventory.

as it is determined that the declare the event as condition will likely exceed soon as it is determined the applicable time. that the condition will likely exceed the applicable time.Table C-1 RPV Leakage Indications" Drywell equipment drain sump level rise* Drywell floor drain sump level rise* Reactor Building equipment drain sump level rise* Reactor Building floor drain sump level rise* Suppression pool level rise* Observation of RCS leakage that is UNISOLABLE 57 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CA3 Loss of all Off-site and all On- CA1 Loss of all offsite and all onsite "Vital buses" is equivalent to the NEI phrase "emergency buses." Site AC power to emergency AC power to vital buses for 15 busses for 15 minutes or longer. minutes or longer MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling, Defueled Refueling, D -Defueled NEI Ex. HCGS EAL # NEI Example EAL Wording EAL # HCGS EAL Wording Difference/Deviation Justification 1 Loss of all Off-Site and all On- CAl.1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has Site AC Power to (site specific Offsite) to all 4.16 KV Vital been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses) for 15 Buses simplification.

minutes or longer. AND 4.16 KV vital buses are the HCGS emergency buses.Note: The Emergency Director should not wait until the _> 15 minutes have elapsed applicable time has (Note 3)elapsed, but should Note 3: The Emergency declare the event as Coordinator should NOT soon as it is determined wait until the applicable that the condition will time has elapsed, but likely exceed the should declare the event applicable time. as soon as it is determined that the condition will likely exceed the applicable time.58 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification lC#(s)CA4 Inability to maintain plant in cold CA4 Inability to maintain plant in cold None shutdown.

shutdown MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL#~Dfeec/eito utfcto 1 An UNPLANNED event results CA4.1 An UNPLANNED event results NEI Example EALs #1 and #2 have been implemented in one EAL in RCS temperature greater than in RCS temperature

> 200OF for for simplification and to help ensure proper escalation from EALs (site specific Technical

> Table C-3 duration CU4.1 and CU4.2.Specification cold shutdown OR NEI example table has been represented in Table C-3. HCGS is a temperature limit) for greater BWR; therefore, all PWR only requirements (reduced inventory) than the specified duration on An UNPLANNED event results have not been deleted.table. in RPV pressure increase > 10 psig due to a loss of RCS The NEI phrase "... greater than (site specific Technical Specification cooling cold shutdown temperature limit)... " has been replaced with ">200'F." 200'F is the HCGS Technical Specification cold shutdown 2 An UNPLANNED event results temperature limit.in RCS pressure increase greater than 10 psi due to a loss A 10-psi RCS pressure increase is readable in the Control Room on of RCS cooling. (PWR-This EAL PI-5824A (0 -50 psig), PI-5824B (0 -50 psig) and PI-R605-C32 (0 -does not apply in Solid Plant 1200 psig).conditions.)

59 of 143 EAL Comparison Matrix NEI Example Table: OSSI HCGS Table: RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact (but not RCS Reduced Inventory N/A 60 minutes, fPWR])Not intact or RCS Established 20 minutes-Reduced Inventory Not Established 0 minutes (PWR)If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

HCGS Table: Table C-3 RCS Heatup Duration Thresholds RCS Integrity CONTAINMENT CLOSURE Duration threshold Intact NOT Applicable 60 minutes **NOT Intact Established 20 minutes **NOT Intact NOT Established 0 minutes** IF a Decay Heat Removal System is placed in operation within the duration threshold and RCS Temperature is lowering, THEN this EAL is NOT Applicable 60 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CS1 Loss of RCS/RPV inventory CS3 Loss of RPV inventory affecting The acronym "RCS" is not included to use terminology familiar to a affecting core decay heat core decay heat removal BWR.removal capability, capability MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling NEI Ex. HOGS HG A odn EAL E NEI Example EAL Wording EAL HCGS EAL Wording Difference/Deviation Justification

1. With CONTAINMENT CS3.1 CONTAINMENT CLOSURE CS3.1 implements Example EALs #1 and #2. These were combined CLOSURE not established, NOT established AND RPV for improved usability.

This allows the third NEI example EAL to be RCS/RPV level less than (site compensated level < -44 in. labeled CS3.2, which then makes all of the "level cannot be specific level), Omonitored" EALs in the RPV Level subcategory the second EAL in[F below OR each classification level.CONTAINMENT CLOSURE The acronym "RCS" is not included to use terminology familiar to a RCS loop (PWR)] established AND RPV BWR.[6" below the low-low ECCS compensated level < -161 in.actuation setpoint (BWR)] The term "compensated" has been added to the HCGS EAL to ensure readings from RPV water level instrumentation are properly 2 2. With CONTAINMENT adjusted for off-calibration conditions.

In cold conditions, SPDS CLOSURE established, provides compensated readings and compensation curves are RCS/RPV level less than (site included in the Integrated Operating procedures to help correlate an specific level for TOAF). indicated RPV level reading to actual RPV level.HCGS is a BWR and is not equipped with the PWR RCS loop setpoint.-44 in. is six inches below the low-low ECCS actuation setpoint (-38 in.).-161 in. is the top of active fuel.3 RCS/RPV level cannot be CS3.2 RPV level CANNOT be The acronym "RCS" is not included to use terminology familiar to a monitored for 30 minutes or monitored for _> 30 minutes with BWR.longer with a loss of RCS/RPV a loss of RPV inventory as The NEI phrase "UNPLANNED level rise in (site specific sump or inventory as indicated by ANY of indicated by EITHER of the tank)" has been changed to "ANY unexplained RPV leakage 61 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS the following:

(Site specific radiation monitor) reading greater than (site specific value)." Erratic Source Range Monitor Indication.

UNPLANNED level rise in (site specific sump or tank).Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.following (Note 3): " Erratic Source Range Monitor indication" ANY unexplained RPV leakage indication, Table C-1 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.indication, Table C-I" to facilitate listing the indications in a table consistent with CU3.2, CA3.2 and CG3.2.The NEI 99-01 example EALs include the use of radiation monitor readings corresponding to those expected for core uncovery in the Refueling Mode (vessel head removed).

HCGS containment high range area radiation monitors are designated RE-4825A and RE-4825B and are located in the drywell at 145' elevation.

The bottom of the RPV is at elevation 115' 3" and the top of active fuel is at elevation 145' 8". These monitors cannot, therefore, sense the loss of water shielding above the core as would be required to determine if core uncovery is occurring.

The generic bases states that the use of radiation monitoring as an EAL input may not be appropriate for some BWRs. Consistent with the NEI bases, these HCGS monitors cannot be utilized for this purpose because of their location relative to the top of active fuel.Additionally, no other installed high range radiation monitoring system exists that can be utilized for the function.

However, HCGS does have extensive redundant RPV level monitoring capability available to assess core uncovery in the Refueling Mode. However, consistent with indicators used in the EALs derived from generic IC CS1, unexplained RPV leakage indications in Table C-1 have been incorporated as other site specific indicators of inventory loss.Table C-1 lists the site-specific sumps and tank level conditions that could be indicative of a loss of inventory from the RPV. Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV. With RHR System operating in the Shutdown Cooling mode, an unexplained rise in suppression pool level could be indicative of RHR valve misalignment or leakage. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a loss of RPV inventory.

62 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSI HCGS Table C-1 RPV Leakage Indications" Drywell equipment drain sump level rise* Drywell floor drain sump level rise" Reactor Building equipment drain sump level rise* Reactor Building floor drain sump level rise* Suppression pool level rise* Observation of RCS leakage that is UNISOLABLE 63 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)CG1 Loss of RCS/RPV inventory CG3 Loss of RPV inventory affecting The acronym "RCS" is not included to use terminology familiar to a affecting fuel clad integrity with fuel clad integrity with BWR.containment challenged Containment challenged MODE: Cold Shutdown, OPCON: 4 -Cold Shutdown, 5 -Refueling Refueling NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. RCS/RPV level less than (site CG3.1 RPV compensated level < -161 in. The acronym "RCS" is not included to use terminology familiar to a specific level for TOAF) for 30 for > 30 min. (Note 3) BWR.minutes or longer. AND -161 in. is the top of active fuel.AND ANY Containment Challenge The term "compensated" has been added to the HCGS EAL to b. ANY containment challenge indication, Table C-2 ensure readings from RPV water level instrumentation are properly indication (see Table): adjusted for off-calibration conditions.

In cold conditions, SPDS Note 3: The Emergency provides compensated readings and compensation curves are Table: Containment Challenge Coordinator should NOT included in the Integrated Operating procedures to help correlate Indications wait until the applicable an indicated RPV level reading to actual RPV level.time has elapsed, but e CUhod declarsed, tet Table C-2 lists the Containment Challenge indications." CONTAINMENT CLOSURE should declare the event not established.

as soon as it is determined The NEI threshold

"(Site specific explosive mixture) inside" (Site specific explosive that the condition will likely containment" has been changed to "> 6% H 2 and -> 5% 02 in mixture) inside containment, exceed the applicable time. Drywell or Torus". The BWROG EPGs/SAGs specifically define the* UNPLANNED rise in limits associated with explosive mixtures in terms of deflagration containment pressure concentrations of hydrogen and oxygen inside the drywell and" Secondary containment torus.radiation monitor reading The NEI phrase "Secondary Containment radiation monitors above above (site specific value). {site-specific}

value (BWR only)" has been changed to "Any[BWR only] Reactor Bldg rad level > 1000 times normal" to agree with the syntax employed in the HCGS EOP Flowchart 103 definition of the Note: The Emergency Director Maximum Safe Operating radiation level. This is consistent with should not wait until the the NEI 99-01 IC CG1 basis which states "the site-specific applicable time has radiation monitor values should be based on the EOP "maximum elapsed, but should safe values" because these values are easily recognizable and 64 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS declare the event as soon have an emergency basis." as it is determined that the condition will likely exceed the applicable time.2 a. RCS/RPV level cannot be monitored with core uncovery indicated by ANY of the following for 30 minutes or longer." (Site specific radiation monitor) reading greater than (site specific setpoint).

Erratic source range monitor indication

UNPLANNED level rise in (site specific sump or tank)." [Other site specific indications]

AND b. ANY containment challenge indication (see Table): Table: Containment Challenge Indications

CONTAINMENT CLOSURE not established.

(Site specific explosive mixture) inside containment.

UNPLANNED rise in containment pressure" Secondary containment radiation monitor reading above (site specific value).[BWR only]CG3.2 RPV level CANNOT be monitored for ? 30 minutes with core uncovery indicated by EITHER of the following (Note 3): " Erratic Source Range Monitor indication" ANY unexplained RPV leakage indication, Table C-1 AND ANY Containment Challenge indication, Table C-2 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.The NEI 99-01 example EALs include the use of radiation monitor readings corresponding to those expected for core uncovery in the Refueling Mode (vessel head removed).

HCGS containment high range area radiation monitors are designated RE-4825A and RE-4825B and are located in the drywell at 145' elevation.

The bottom of the RPV is at elevation 115' 3" and the top of active fuel is at elevation 145' 8". These monitors cannot, therefore, sense the loss of water shielding above the core as would be required to determine if core uncovery is occurring.

The generic bases states that the use of radiation monitoring as an EAL input may not be appropriate for some BWRs. Consistent with the NEI bases, these HCGS monitors cannot be utilized for this purpose because of their location relative to the top of active fuel.Additionally, no other installed high range radiation monitoring system exists that can be utilized for the function.

However, HCGS does have extensive redundant RPV level monitoring capability available to assess core uncovery in the Refueling Mode.However, consistent with indicators used in the EALs derived from generic IC CG1, unexplained RPV leakage indications in Table C-1 have been incorporated as other site specific indicators of inventory loss.Table C-1 lists the site-specific sumps and tank level conditions that could be indicative of a loss of inventory from the RPV.Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV. With RHR System operating in the Shutdown Cooling mode, an unexplained rise in suppression pool level could be indicative of RHR valve misalignment or leakage. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a loss of RPV inventory.

Table C-2 lists the Containment Challenge indications.

The NEI threshold

"(Site specific explosive mixture) inside 65 of 143 EAL Comparison Matrix OSSIHCGS Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.containment" has been changed to "Indications of > 6% H 2 and >5% 02 in Drywell or Torus". The BWROG EPGs/SAGs specifically define the limits associated with explosive mixtures in terms of deflagration concentrations of hydrogen and oxygen inside the drywell and torus.The NEI phrase "Secondary Containment radiation monitors above{site-specific}

value (BWR only)" has been changed to "Any Reactor Bldg rad level > 1000 times normal" to agree with the syntax employed in the HCGS EOP Flowchart 103 definition of the Maximum Safe Operating radiation level. This is consistent with the NEI 99-01 IC CG1 basis which states "the site-specific radiation monitor values should be based on the EOP "maximum safe values" because these values are easily recognizable and have an emergency basis."__________________

J U __________________________________________________________________

4 66 of 143 EAL Comparison Matrix 0331 HOGS EAL Comparison Matrix OSSI HCGS Table C-1 RPV Leakage Indications" Drywell equipment drain sump level rise" Drywell floor drain sump level rise o Reactor Building equipment drain sump level rise o Reactor Building floor drain sump level rise o Suppression pool level rise o Observation of RCS leakage that is UNISOLABLE Table C-2 Containment Challenge Indications" CONTAINMENT CLOSURE NOT established

Indications of __ 6% H 2 and 2! 5% 02 in Drywell or Torus* UNPLANNED rise in Drywell pressure* ANY Reactor Bldg rad level > 1000 times normal 67 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Category D Permanently Defueled Station Malfunction 68 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(S)D-AU1 Recognition Category D N/A N/A NEI Recognition Category D ICs and EALs are applicable only to D-AU2 Permanently Defueled Station permanently defueled stations.

HCGS is not a defueled station.D-SU1 Malfunction D-HU1 D-HU2 D-HU3 D-AA1 D-AA2 D-HA1 D-HA2 69 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Category E Events Related to Independent Spent Fuel Storage Installations 70 of 143 EAL Comparison Matrix OSSI HCGS HCGS NEI IC# NEI IC Wording IC(s) HCGS IC Wording Difference/Deviation Justification E-HU1 Damage to a loaded cask EU1 Damage to a loaded.cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: N/A OPCON: Mode Not:Applicable NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL U 1 Damage to a loaded cask EU1.1 Damage to a Multi Purpose The NEI phrase "loaded CONFINEMENT BOUNDARY" has been CONFINEMENT BOUNDARY.

Canister (MPC) .changed to "Multi Purpose Canister (MPC) CONFINEMENT CONFINEMENT " BOUNDARY as indicated by on-contact radiation readings > 600 mR/hr (gamma + neutron) on the surface of the spent fuel cask, BOUNDARY as indicated by excluding the air ventsOR > 60 mR/hr (gamma + neutron) on the on-contact radiation rýeadings top of the spent fuel cask.".> 600 mRlhr (gamma +neutron) on the surface of the As provided in the Holtec HI-STORM 100 System Certificate of spent fuel cask, excluding the Compliance (CoC), Appendix A (Technical Specifications), Section air vents, OR > 60 mIRlhr 5.7.4 contains radiation values for the cask that should not be (gamma + neutron) on the exceeded.

Under Amendment

5, the highest allowable radiation top of the spent fuel cask. level on contact with the HI-STORM 100 cask body is 300 mR/hr on the side of the cask and 30 mR/hr on the top of the cask. Keeping in line with NEI. guidance that a UE is warranted for radiation conditions at a level of twice the Technical Specification value, 600 mR/hr and 60 mR/hr are being used as the EAL threshold radiation levels.The threshold values are sufficiently above nominal radiation levels of the CONFINEMENT BOUNDARY that radiation levels above this EAL threshold would indicate significant damage to the CONFINEMENT BOUNDARY.No releases of radioactive material requiring offsite response or monitoring are expected because the seal-welded spent fuel canister (part of the CONFINEMENT BOUNDARY) is designed to remain intact under all normal, off-normal, and credible accident conditions of onsite transport and storage at the ISFSI, according to 71 of 143 EAL Comparison Matrix OSSI HCGS Holtec licensing documents.

Postulated problems associated with the dry cask storage system include those caused by natural phenomena or accidents caused by human error/equipment malfunctions which affect the storage system. Generally speaking, the limiting impacts to the system include loss of~shielding capability and loss of fuel canister integrity.

The loss of shielding would result in higher direct radiation to the environment, while the loss of fuel canister integrity results in a release of radioactive materials from the Multi-Purpose Canister (MPC) within the cask to the environment.

However, the particular dry storage system used at the PSEG Nuclear ISFSI is a robust seal-welded, canister-based system that is designed to remain leak-tight under all normal, off-normal and postulated accident conditions.

Therefore, effluent release from the storage system is not a credible condition.

In addition, because the amount of radioactive material inside the dry storage system is fixed, the source term never increases over time and, in fact, decreases over time due to radioactive decay.The effect on cask shielding effectiveness under off-normal and accident conditions is evaluated in Chapter 11 of the HI-STORM FSAR. Only one event resulted in a slight loss of the cask shielding effectiveness that was caused by the postulated accident conditions evaluated for a fire. A very small percentage of the cask exterior concrete was estimated to be degraded, which did not result in any significant projected increase in dose rates. No release of radioactive material from the MPC is projected for any off-normal or accident event.________ I _______________________________

I _________

I _____________________________

I. __________________________________________________________

72 of 143 EAL Comparison Matrix 0531 HOGS EAL Comparison Matrix 0SSI HCGS Category F Fission Product Barrier Degradation 73 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)FU1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of Containment of Containment MODE: Power Operation, Hot OPCON: 1 -Power Operations, 2 Standby, Startup, Hot Shutdown -Startup, 3 -Hot Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL#1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of Containment of Containment NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)FA1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of EITHER Fuel Clad OR RCS of either Fuel Clad or RCS MODE: Power Operation, Hot OPCON: 1 -Power Operations, 2 Standby, Startup, Hot Shutdown -Startup, 3 -Hot Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of EITHER Fuel Clad OR RCS of either Fuel Clad or RCS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)FS1 Loss or Potential Loss of ANY None Loss or potential loss of ANY two See discussion of point system in Table 4.Two Barriers barriers MODE: Power Operation, Hot OPCON: 1 -Power Operations, 2 74 of 143 EAL Comparison Matrix OSSI HCGS Standby, Startup, Hot Shutdown -Startup, 3 -Hot Shutdown NEI Ex. NEl Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss or Potential Loss of ANY None Loss or potential loss of ANY two The condition "OR Potential loss of 2 barriers with the loss of the 3rd Two Barriers barriers barrier" has been added for clarification.

OR See discussion of point system in Table 4.Potential loss of 2 barriers with the loss of the 3rd barrier NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IO#(S)FG1 Loss of ANY Two Barriers AND None Loss of ANY two barriers AND See discussion of point system in Table 4.Loss or Potential Loss of Third loss or potential loss of third Barrier barrier MODE: Power Operation, Hot OPCON: 1 -Power Operations, 2 Standby, Startup, Hot Shutdown -Startup, 3 -Hot Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of ANY Two Barriers AND None Loss of ANY two barriers See discussion of point system in Table 4.Loss or Potential Loss of Third Barrier AND Loss or potential loss of third barrier 75 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS Table 4 -Classification of Fission Product Barriers with the Point System A point system is used to determine the Emergency Classification Level based on the Fission Product Barrier Table. Each Fission Product Barrier Loss and Potential Loss threshold is assigned a point value as noted below.Points Barrier Degradation Fuel Clad Loss RCS Loss Fuel Clad Potential Loss RCS Potential Loss 3 Containment Loss 2 Containment Potential Loss Classification instructions:

1. Review all columns of the Fission Product Barrier Table and identify which need further review.2. For each of the three barriers, determine the EAL with the highest point value. No more than one EAL should be selected for each barrier.3. Add the point values for the three barriers.4. Classify based on the point value sum as follows: If the sum ECG is: Classify as: EAL Att#UNUSUAL ANY loss or ANY potential EVENT loss of Containment I ANY loss or ANY potential 4, 5 ALERT loss of either Fuel Clad or 2 RCS Loss or potential loss of ANY SITE AREA two barriers 3 6-11 EMERGENCY OR Potential loss of 2 barriers with the loss of the 3rd 76 of 143 EAL Comparison Matrix OSSI HCGS barrier Loss of ANY two barriers 12,13 GENERAL AND 4 EMERGENCY Loss or potential loss of third barrier 5. Implement the appropriate ECG Attachment.

6. Continue to review the Fission Product Barrier Table for changes that could result in emergency escalation or de-escalation 77 of 143 EAL Comparison Matrix OSSI HCGS Hope Creek -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier FPB Category Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)RPV Level FB1-P FB1-L RB1-L CB1-P RPV level CANNOT be Primary Containment RPV level CANNOT be Primary Containment restored and maintained Flooding is required as restored and maintained Flooding is required as above indicated by EITHER of above indicated by EITHER of-161 in. the following:

-161 in. the following:

OR

RPV level CANNOT OR

RPV level CANNOT RPV level CANNOT be be restored and none RPV level CANNOT be be restored and RO~e none determined maintained above determined maintained above-185 in. -185 in.* RPV level CANNOT

RPV level CANNOT be determined AND be determined AND it it is determined that is determined that core damage is core damage is occurring occurring RPV I Drywell RB2-L CB2-P CB1-L Pressure / Drywell pressure > 1.68 Drywell pressure > 62 Drywell pressure rise Temperature psig due to RCS psig and rising followed by a rapid leakage unexplained drop in H 2 & 02 Levels Drywell pressure CB3-P CB2-L Indications of >- 6% H 2 Drywell pressure none none none and ? 5% 02 in Drywell response NOT or Torus consistent with LOCA conditions CB4-P RPV pressure and suppression pool temperature CANNOT be maintained below the HCTL (EOP Curve SPT-P)78 of 143 EAL Comparison Matrix OSSI HCGS Hope Creek -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier FPB 1-Category Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)RCS Leakage, Leak Isolation, PC Venting none none RBI-P RCS leakage> 50 gpm inside the drywell RB2-P UNISOLABLE primary system leakage outside primary containment (after isolation from the Control Room has or should have been attempted) as indicated by exceeding EITHER of the following: " ANY EOP 103 Reactor Bldg room temperature Table 1, Column 1" ANY EOP 103 Reactor Bldg local rad monitoring alarm RB3-L VALID isolation signal exists with an UNISOLABLE Break outside primary containment (after isolation from the Control Room has or should have been attempted) in ANY of the following systems: " Main steam line" HPCI steam line" RCIC steam line" RWCU" Feedwater RB4-L Emergency RPV Depressurization is required none CB3-L UNISOLABLE primary system leakage outside primary containment (after isolation from the Control Room has or should have been attempted)

AND Direct downstream pathway to the environment exists........................

CB4-L Intentional primary containment venting per EOPs 79 of 143 EAL Comparison Matrix OSSIHCGS Hope Creek -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier FPB Category Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)CB5-L UNISOLABLE primary system leakage outside primary containment (after isolation from the Control Room has or should have been attempted) as indicated by exceeding EITHER of the following: " ANY EOP 103 Reactor Bldg room temperature Table 1, Column 2" ANY Reactor Bldg rad level > 1000 times normal I + I Radiation none FB2-L ANY DAPA Radiation Monitor reading EITHER of the following: " With drywell sprays,? 2000 Rlhr" Without drywell sprays, >- 4000 Rlhr FB3-L Coolant activity > 300 pCi/gm dose equivalent 1-131 CBS-P ANY DAPA Radiation Monitor reading EITHER of the following: " With drywell sprays,>10,000 R/hr" Without drywell sprays, 2! 20,000 R/hr none none i none EC FB4-P FB4-L RB3-P RB5-L CB6-P CB6-L Judgment ANY condition in the ANY condition in the ANY condition in the ANY condition in the ANY condition in the ANY condition in the opinion of the opinion of the opinion of the opinion of the opinion of the opinion of the Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator that indicates potential that indicates loss of the that indicates potential that indicates loss of the that indicates potential that indicates loss of the loss of the Fuel Clad Fuel Clad barrier loss of the RCS barrier RCS barrier loss of the Containment Containment barrier barrier barrier 80 of 143 EAL Comparison Matrix OSSI HCGS Fuel Clad Fission Product Barrier Degradation Thresholds NEI HCGS NEI NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss Primary Coolant Activity FB3-L Primary coolant activity > 300 > 300 pCi/gm dose equivalent 1-131 is the site specific coolant 1 Level pCi/gm dose equivalent 1-131 activity.A. Primary coolant activity greater than (site-specific value).FC Loss Reactor Vessel Water Level FB1-L Primary Containment Flooding is EOPs 101, 101A, 206 and 206A specify the requirements for 2 A. RPV water level cannot be required as indicated by EITHER primary containment flooding, which is accomplished by entry to the restored and maintained of the following:

SAGs when core cooling is severely challenged.

EOP flowchart above (site specific RPV 9 RPV level CANNOT be symbols containing the phrase "SAG entry is required" signal this water level corresponding to restored and maintained requirement.

These EOPs provide instructions to ensure adequate the requirement for primary above -185in. core cooling by maintaining RPV water level above prescribed limits containment flooding), or operating sufficient RPV injection sources when level cannot be* RPV level CANNOT be determined.

Primary containment flooding (SAG entry) is required determined AND it is when: determined that core damage RPV level cannot be restored and maintained above -185 in.: is occurring The Minimum Steam Cooling RPV Water Level (MSCRWL) is the lowest RPV water level at which the covered portion of the reactor core will generate sufficient steam to preclude any clad temperature in the uncovered portion of the core from exceeding 1500'F.RPV level cannot be determined and it is determined that core damage is occurring.

The above EOP conditions represent a challenge to core cooling and are the minimum values to assure core cooling without further degradation of the clad.FC Loss N/A N/A N/A 3 81 of 143 EAL Comparison Matrix OSSI HCGS NEI HCGS FPB NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss Primary Containment FB2-L ANY DAPA Radiation Monitor The term "ANY" has been added to ensure that classification is not 4 Radiation Monitoring reading EITHER of the following:

delayed because the threshold is not indicated on both DAPA radiation monitors.A. Primary containment e With drywell sprays, radiation monitor reading 2! 2000 R/hr Threshold values with and without drywell sprays have been greater than (site specific provided because the methodology for core damage assessment value). ? Without drywell sprays, utilizes nomograms with and without drywell sprays._> 4000 R/hr Core damage analysis indicates that a reactor coolant activity of 300 pCi/gm Dose Equivalent Iodine-1 31 (DEI) corresponds to 4% clad damage. 4% clad damage is indicated by a Drywell Atmosphere Post Accident (DAPA) reading of approximately 2000 R/hr at 1 hr after shutdown (the most conservative) with drywell spray in service, and approximately 4000 R/hr at 1 hr after shutdown with drywell spray not in service.FC Loss Other (Site-Specific)

N/A Other site-specific indications of Fuel Clad loss have not been 5 Indications identified.

A. (site specific ) as applicable FC Loss Emergency Director FB4-L ANY condition in the opinion of None 6 Judgment the Emergency Coordinator that A. Any condition in the opinion indicates loss of the Fuel Clad of the Emergency Director barrier that indicates Loss of the Fuel Clad Barrier FC Primary Coolant Activity N/A N/A P-Loss 1 Level Not Applicable.

82 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS NEI HOGS NEI NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Reactor Vessel Water Level FB1-P RPV level CANNOT be restored -161 in. is the RPV water level corresponding to the top of active P-Loss 2 A. RPV water level cannot be and maintained above fuel.restored and maintained

-161 in. The NEI phrase "or cannot be determined" has been changed to above (site specific RPV OR "OR RPV level CANNOT be determined" for clarification.

water level corresponding to the top of active fuel) or RPV level CANNOT be cannot be determined, determined FC N/A N/A N/A P-Loss 3 FC Primary Containment N/A N/A P-Loss 4 Radiation Monitoring Not Applicable FC Other (Site-Specific)

N/A N/A Other site-specific indications of Fuel Clad potential loss have not P-Loss 5 Indications been identified.

A. (site specific ) as applicable FC Emergency Director FB2-P ANY condition in the opinion of None P-Loss 6 Judgment the Emergency Coordinator that A. Any condition in the opinion indicates potential loss of the of the Emergency Director Fuel Clad barrier that indicates Potential Loss of the Fuel Clad Barrier 83 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS RCS Fission Product Barrier Degradation Thresholds NEI NEI IC Wording HOGS HCGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS Primary Containment RB2-L Drywell pressure > 1.68 psig 1.68 psig is the HCGS Primary Containment (PC) high pressure Loss 1 Pressure due to RCS leakage scram setpoint.A. Primary containment pressure greater than (site specific value) due to RCS leakage.RCS Reactor Vessel Water Level RB1-L RPV level CANNOT be -161 in. is the RPV water level corresponding to the top of active Loss 2 A. RPV water level cannot be restored and maintained above fuel.restored and maintained

-161 in. The NEI phrase "or cannot be determined" has been changed to above (site specific RPV OR "OR RPV level CANNOT be determined" for clarification.

water level corresponding to the top of active fuel) or RPV level CANNOT be cannot be determined, determined RCS RCS Leak Rate RB3-L VALID isolation signal exists The NEI threshold

"(Site-specific)

Indication of an unisolable Main Loss 3 A. (site specific Indication of an with an UNISOLABLE Break Steamline...break" has been changed to "VALID isolation signal UNISOLABLE Main outside primary containment exists with an UNISOLABLE Break outside primary Steamline, HPCI, Feedwater, (after isolation from the Control containment.. .in ANY of the following systems:.. .Main steam RWCU, or RCIC break) Room has or should have been line... HPCI steam line.. .RCIC steam line... RWCU... Feedwater" to attempted) in ANY of the clarify NEI intent.B. Emergency RPV following systems: The parenthetical phrase "after isolation from the Control Room* Main steam line has or should have been attempted" has been added to the HCGS EAL to emphasize the meaning of "promptly" as stated in the NEI" HPCI steam line definition of UNISOLABLE.

In accordance with NEI basis" RCIC steam line discussion, prompt isolation attempts include automatic isolation and manual action in the Control Room to close isolation valves." RWCU" Feedwater 84 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI HOGS FPB NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification FPB# FP13 #(s)RB4-L Emergency RPV None Depressurization is required RCS Primary Containment N/A None This RCS Loss has been deleted. Radiation levels indicative of the Loss 4 Radiation Monitoring dispersal of reactor coolant activity at the Technical Specification A. Primary containment limit (-0.1% clad damage) are so low that they cannot be read on radiation monitor reading the DAPA radiation monitors.

These monitors are equipped with a greater than (site specific source that ensures an onscale reading. The radiation levels value), equivalent to the NEI 99-01 threshold would be offscale-low or masked by the check source. There are no other radiation monitors that can be used for this purpose.Due to the inability of the DAPA radiation monitors to distinguish between a cloud of released RCS gases and shine from the reactor vessel and adjacent piping/components, this RCS Loss is being omitted as permitted by NEI 99-01. Other indications of RCS leakage are being used. It should be recognized that DAPA exceeding 2000 R/hr would most likely occur due to core uncovery as RPV water level decreases below the top of active fuel. This condition will result in appropriate escalation to a SAE in the Fission Product Barrier Table, and hence the use of DAPA is not needed to detect a loss of RCS barrier.RCS Other Site-Specific Indications N/A N/A Other site-specific indications of RCS loss have not been Loss 5 A. (site specific) as applicable identified.

RCS Emergency Director Judgment RB5-L ANY condition in the opinion of None Loss 6 A. Any condition in the opinion the Emergency Coordinator that of the Emergency Director indicates loss of the RCS that indicate Loss of the RCS barrier Barrier RCS P- Primary Containment N/A N/A Loss 1 Pressure Not Applicable 85 of 143 EAL Comparison Matrix OSSI HCGS NEI HOGS FPB NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS P- Reactor Vessel Water Level N/A N/A Loss 2 Not applicable RCS P- RCS Leak Rate RB1-P RCS leakage > 50 gpm inside None Loss 3 A. RCS leakage GREATER the drywell THAN 50 gpm inside the RB2-P UNISOLABLE primary system The parenthetical phrase "after isolation from the Control Room drywell leakage outside primary has or should have been attempted" has been added to the HCGS OR containment (after isolation EAL to emphasize the meaning of "promptly" as stated in the NEI B. UNISOLABLE primary from the Control Room has or definition of UNISOLABLE.

In accordance with NEI basis system leakage outside should have been attempted) discussion, prompt isolation attempts include automatic isolation primary containment as as indicated by exceeding and manual action in the Control Room to close isolation valves.indicated by exceeding EITHER of the following:

The entry conditions to EOP flowchart 103 for Reactor Bldg room EITHER of the following:

o ANY EOP 103 Reactor Bldg temperature and local rad monitoring alarms are the HCGS Max a. Max Normal Operating room temperature Table 1, Normal Operating Temperature and Max Normal Area Radiation.

Temperature.

Column 1 OR b. Max Normal Area o ANY EOP 103 Reactor Bldg Radiation.

local rad monitoring alarm RCS P- Primary Containment N/A N/A Loss 4 Radiation Monitoring Not applicable RCS P- Other Site Specific Indications N/A N/A Other site-specific indications of RCS potential loss have not been Loss 5 A. (site specific ) as applicable identified.

RCS P- Emergency Director Judgment RB3-P ANY condition in the opinion of None Loss 6 A. Any condition in the opinion the Emergency Coordinator that of the Emergency Director indicates potential loss of the that indicate Potential Loss RCS barrier of the RCS Barrier 86 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Containment Fission Product Barrier Degradation Thresholds NEI HCGS FPB# NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification

(s)CMT Primary Containment Conditions CB1-L Drywell Pressure rise followed by a The NEI phrase "Primary containment" has been Loss I A. Primary containment pressure rise rapid unexplained drop in Drywell changed to "Drywell" because the instrumentation followed by a rapid unexplained pressure used to monitor primary containment pressure is the drop in primary containment drywell pressure instrumentation.

pressure.

CB2-L Drywell pressure response NOT The NEI phrase "Primary containment" has been OR consistent with LOCA conditions changed to "Drywell" because the instrumentation B. Primary containment pressure used to monitor primary containment pressure is the response not consistent with drywell pressure instrumentation.

LOCA conditions.

CMT Reactor Vessel Water Level N/A N/A Loss 2 Not applicable CMT Primary Containment Isolation CB3-L UNISOLABLE leakage outside primary The NEI phrase "Failure of all valves in any one line to Loss 3 Failure or Bypass containment (after isolation from the close.. .after primary containment isolation signal" has A. Failure of all valves in any one line Control Room has or should have been been changed to "UNISOLABLE leakage outside to close, attempted) primary containment..." By definition, a failure of all AND AND valves in any one line penetrating the primary Direct downstream pathway to the containment to close may produce unisolable leakage environment exists after primary Direct downstream pathway to the outside the primary containment.

containment isolation signal. environment exists The parenthetical phrase "after isolation from the OR Control Room has or should have been attempted" B. Intentional primary containment has been added to the HCGS EAL to emphasize the venting per EOPs. meaning of "promptly" as stated in the NEI definition of OR UNISOLABLE.

In accordance with NEI basis C. UNISOLABLE primary system discussion, prompt isolation attempts include leakage outside primary automatic isolation and manual action in the Control containment as indicated by Room to close isolation valves.exceeding EITHER of the following:

CB4-L Intentional primary containment venting None a. Max Safe Operating per EOPs 87 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSI HCGS NEI HCGS FPB# NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification

(s)Temperature.

CB5-L UNISOLABLE primary system leakage The parenthetical phrase "after isolation from the b. Mx Safe Area Radiation.

outside primary containment (after Control Room has or should have been attempted" isolation from the Control Room has or has been added to the HCGS EAL to emphasize the should have been attempted) as meaning of "promptly" as stated in the NEI definition of indicated by exceeding EITHER of the UNISOLABLE.

In accordance with NEI basis following:

discussion, prompt isolation attempts include" ANY EOP 103 Reactor Bldg room automatic isolation and manual action in the Control temperature Table 1, Column 2 Room to close isolation valves." ANY Reactor Bldg rad level > 1000 The EOP flowchartl 03 Table 1, Column 2, times normal temperatures are the HCGS Max Safe Operating Temperatures.

Reactor Bldg rad levels > 1000 times normal are the HCGS Max Safe Area Radiation levels specified in EOP flowchart 103.CMT Primary Containment Radiation N/A N/A Loss 4 Monitoring Not applicable CMT Other Site Specific Indications N/A N/A Other site-specific indications of Containment loss Loss 5 A. (site specific ) as applicable have not been identified.

CMT Emergency Director Judgment CB6-L ANY condition in the opinion of the None Loss 6 A. Any condition in the opinion of the Emergency Coordinator that indicates Emergency Director that indicates loss of the Containment barrier Loss of the Containment barrier CMT Primary Containment Conditions CB2-P Drywell Pressure > 62 psig and rising The NEI phrase "Primary containment" has been P-Loss A. Primary containment pressure changed to "Drywell" because the instrumentation 1 greater than (site specific value) used to monitor primary containment pressure is the and rising. drywell pressure instrumentation.

OR 62 psig is the primary containment internal design B. Explosive mixture exists inside pressure.88 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS NEI HCGS FPB# NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification

(s)primary containment.

CB3-P Indications of > 6% H 2 and ? 5% 02 in The NEI threshold "Explosive mixture exists" has been OR--C. RPV pressure and suppression pooi Drywell or Torus changed to "Indications of _> 6% H 2 and ? 5% 02 in temRP preraure anno buppesmaintaineDrywell or Torus" for clarification.

The BWROG temperature cannot be maintained EPGs/SAGs specifically define the limits associated below the HCTL. with explosive mixtures in terms of deflagration concentrations of hydrogen and oxygen inside the drywell and suppression chamber.CB4-P RPV pressure and suppression pool Reference to the EOP curve that illustrates the HCTL temperature CANNOT be maintained has been added for clarification.

below the HCTL (EOP Curve SPT-P)CMT Reactor Vessel Water Level CB1-P Primary Containment Flooding is The NEI phrase "Primary containment flooding P-Loss A. Primary containment flooding required as indicated by EITHER of the required" has been changed to include the threshold 2 required following:

values given in EOPs 101, 101A, 206 and 206A that" RPV level CANNOT be restored and specify the requirement for primary containment maintained above -185 in. flooding.

This change is for clarification and consistency with FB1-L." RPV level CANNOT be determined EOP flowchart symbols containing the phrase "SAG AND it is determined that core entry is required" signal the requirement for primary damage is occurring containment flooding.

These EOPs provide instructions to ensure adequate core cooling by maintaining RPV water level above prescribed limits or operating sufficient RPV injection sources when level cannot be determined.

Primary containment flooding (SAG entry) is required when: RPV level cannot be restored and maintained above -185 in.: The Minimum Steam Cooling RPV Water Level (MSCRWL) is the lowest RPV water level at which the covered portion of the reactor core will generate sufficient steam to preclude any clad temperature in the uncovered portion of the core from exceeding 1500'F.89 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS NEI HCGS FPB# NEI IC Wording FPB HCGS FPB Wording Difference/Deviation Justification

(s)* RPV level cannot be determined and it is determined that core damage is occurring.

CMT Primary Containment Isolation N/A N/A P-Loss Failure or Bypass 3 Not applicable CMT Primary Containment Radiation CB5-P ANY DAPA Radiation Monitor reading The term "ANY" has been added to ensure that P-Loss Monitoring EITHER of the following:

classification is not delayed because the threshold is 4 not indicated on both DAPA radiation monitors.A. Primary containment radiation

With drywell sprays, monitor reading greater than (site > 10,000 R/hr Threshold values with and without drywell sprays have specific value), *been provided because the methodology for core 0 Without drywell sprays, damage assessment utilizes nomograms with and> 20,0100 R/hr without drywell sprays.Core damage analysis indicates that 20% clad damage corresponds to a DAPA reading of 10,000 R/hr with drywell sprays and 20,000 R/hr without drywell sprays.CMT Other Site Specific)

Indications N/A N/A Other site-specific indications of Containment potential P-Loss A. (site specific) as applicable loss have not been identified.

5 CMT Emergency Director Judgment CB6-P ANY condition in the opinion of the None P-Loss A. Any condition in the opinion of the Emergency Coordinator that indicates 6 Emergency Director that indicates potential loss of the Containment barrier Potential Loss of the Containment barrier 90 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS Category H Hazards and Other Conditions Affecting Plant Safety 91 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HU1 Natural or destructive phenomena HU1 Natural or destructive phenomena affecting None affecting the PROTECTED AREA the PROTECTED AREA MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Seismic event identified by ANY 2 of the following:

Seismic event confirmed by (site specific indication or method))* Earthquake felt in plant* National Earthquake Center HU1.1 Seismic event identified by ANY two of the following: " Earthquake felt in plant by Control Room Operators" SMA-3 Event Indicator (flag) white on Panel 10C673" National Earthquake Information Center (NEIC) (Note 4)Note 4: The NEIC can be contacted by calling (303) 273-8500.

Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates:

390 27'46" (39.4650) north latitude, 750 32'08" (75.537')

west longitude.

The phrase "by Control Room Operators" has been added for clarification.

The NEI basis defines a felt earthquake as one having been "recognized as an earthquake based on a consensus of control room operators on duty at the time." SMA-3 flag is the HCGS specific method of confirming a felt earthquake.

The NEI phrase "National Earthquake Center" has been changed to "National Earthquake Information Center" to reflect the proper title of this organization.

Note 4 provides guidance for contacting the NEIC and obtaining confirmation of seismic activity at the SGS/HCGS site.Tornado striking within HU1.2 Tornado TOUCHING DOWN within the The NEI term "striking" has been changed to "TOUCHING PROTECTED AREA boundary or PROTECTED AREA DOWN" for clarification and consistency with the NEI high winds greater than (site OR basis definition of "striking." specific mph).The design wind velocities are 108 mph (including a gust Average Wind Speeds > 95 MPH from factor of approximately 1.3) at 30 feet above ground for 92 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS ANY elevation of the Met Tower Seismic Category I structures.

However, wind speed indication is limited to 100 mph in the Control Room so the wind speed threshold has been capped at 95 mph to provide margin to the upper limit of the indicated range.The phrase "Average Wind Speeds.. .from ANY elevation of the Met Tower" has been added to clarify the sources from which wind speed information may be obtained.

The SPDS display provides wind speed readings on a 15-minute average.3 Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in ANY of the following areas: (site specific area list)HU1.4 Visual Observation of Flooding in ANY Table H-1 structures that confirms ANY of the following:

Reactor Building Floor Levels above the Maximum Normal Floor Level (> 1 in.) referenced in EOP 103 / 104, Reactor Building and Radioactive Release Control* Receipt of SSWS Pump Room Flooded Alarm A1-B2 (PUMP ROOM FLOODED)* Greater than 2 in. of water in ANY other area that contains a Safety System(s)AND The Safety Related Equipment is required by Technical Specifications for the present operational condition (OPCON)The HCGS (site-specific) areas of the plant are listed in Table H-i.The NEI phrase "Internal flooding that has the potential to affect safety related equipment..." has been changed to"Visual Observation of Flooding.. .that confirms ANY of the following:

[three bulleted conditions]" to provide explicit criteria by which the EAL-user can assess internal flooding that may affect safety related equipment.

For the purpose of implementing this EAL, levels in the Reactor Building that would require classification under this EAL are defined as the Maximum Normal Floor Level in the EOPs. Exceeding this level in any of the Reactor Building areas would require running all available sump pumps. If level in these areas cannot be lowered to below the 1 in. level, systems discharging into this area are to be isolated, except for systems required to:* Ensure adequate core cooling" Shutdown the reactor* Protect primary containment integrity" Suppress a fire Overhead Annunciator A1-B2 (PUMP ROOM FLOODED)is fed from the following CRID points: D5518, D5519, D5533 and D5534.4 Turbine failure resulting in casing HU1.3 Main Turbine rotating component failures-The NEI phrase "Turbine" has been changed to "Main_penetration or damage to turbine Turbine" to clarify that the EAL does not apply to other 93 of 143 EAL Comparison Matrix OSSIHCGS or generator seals resulting in EITHER of the following:

turbine-driven equipment such as the HPCI and RCIC" Main Turbine casing penetration turbines.The NEI term "failure" has been expanded to "Main" Main Turbine or Generator Seal Turbine rotating component failures" for consistency with Damage the NEI basis that discusses the concerns associated with main turbine rotor failures.5 (Site specific occurrences HU1.5 River level > 99.5' River level greater than 99.5' (+10.5' MSL) is indication of affecting the PROTECTED AREA) OR impending site flood conditions.

River level < 80.0' River level < 80.0' (-9.0'MSL) is indication of approaching loss of the Ultimate Heat Sink.Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Reactor Building* Control/Auxiliary Building* Service Water Intake Structure* Service/Radwaste Building 94 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HU2 FIRE within the PROTECTED HU2 FIRE within the PROTECTED None AREA not extinguished within 15 AREA not extinguished within 15 minutes of detection or minutes of detection or EXPLOSION within the EXPLOSION within the PROTECTED AREA. PROTECTED AREA MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 FIRE not extinguished within 15 HU2.1 FIRE NOT extinguished within 15 The NEI phrase "control room notification or verification of a control minutes of control room minutes of EITHER of the room FIRE alarm" has been reformatted with minor wording changes notification or verification of a following:

for clarification.

control room FIRE alarm in ANY of the following areas:

Control Room The NEI bases has been modified to better define when the 15-notification/report of a FIRE minute EAL Assessment clock starts for (1) cases that include the receipt of nearby independent fire alarms and (2) cases that involve (Site-specific area list) ° Verified FIRE detection only a single alarm where on-scene fire confirmation would be the (Site:-speiiergeacy listr system alarm/actuation threshold used to start the 15-minute EAL assessment clock. This Note: The Emergency Director AND is a potential deviation from NEI 99-01 Revision 5.should not wait until the applicable time has FIRE is located in the Turbine The phrase "...the Turbine Building or ANY Table H-1..." has been elapsed, but should Building or ANY Table H-1 plant added for consistency with the NEI basis that indicates the EAL declare the event as soon structure (Note 3) applies to fires in vital areas or areas immediately adjacent to vital as it is determined that the areas or other significant buildings or areas. Table H-1 lists plant duration has exceeded, or Note 3: The Emergency structures containing safe shutdown systems or components.

These will likely exceed, the Coordinator should NOT are vital areas and areas immediately adjacent to vital areas and applicable time. wait until the applicable other significant buildings and areas.time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.95 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS 2 EXPLOSION within the HU2.2 EXPLOSION within the None PROTECTED AREA. PROTECTED AREA Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Reactor Building" Control/Auxiliary Building* Service Water Intake Structure* Service/Radwaste Building 96 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HU3 Release of toxic, corrosive, HU3 Release of toxic, corrosive, None asphyxiant, or flammable gases asphyxiant or flammable gases deemed detrimental to NORMAL deemed detrimental to NORMAL PLANT OPERATIONS PLANT OPERATIONS MODE: All OPCON: All NEI Ex. HCGS NEI Example EAL Wording HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Toxic, corrosive, asphyxiant or HU3.1 Release of toxic, corrosive, The phrase "(excluding small or incidental releases)" has been flammable gases in amounts that asphyxiant or flammable gas in added to the HCGS EAL for clarification consistent with the EAL have or could adversely affect amounts (excluding small or basis .The NEI basis for this EAL states: "This would preclude small NORMAL PLANT OPERATIONS incidental releases) that have or or incidental releases, or releases that do not impact structures could adversely affect NORMAL needed for plant operation." PLANT OPERATIONS 2 Report by Local, County or State HU3.2 Notification by Local, County, or The NEI term "Report" has been replaced with "Notification" for Officials for evacuation or State Officials for evacuation or consistency with use of the term "Notification" in EALs HU4.1 and sheltering of site personnel based sheltering of site personnel HA4.1.on an offsite event based on an off-site gas release The NEI phrase "offsite event" has been replaced with "off-site gas event that includes toxic, release event that includes toxic, corrosive, asphyxiant, or corrosive, asphyxiant, or flammable gas" to clarify the type of events intended to be classified flammable gas under this EAL by the NEI IC wording and NEI basis discussion.

97 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HU4 Confirmed SECURITY HU4 Confirmed SECURITY None CONDITION or threat which CONDITION or threat which indicates a potential degradation indicates a potential degradation in the level of safety of the plant in the level of safety of the plant MODE: All OPCON: All NEI Ex. NEl Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL #A SECURITY CONDITION that HU4.1 A SECURITY CONDITION that The NEI Example EALs have been combined in one plant EAL.does NOT involve a HOSTILE does NOT involve a HOSTILE ~doesNOTinvlvea HSTIE dos NT ivole aHOSILE The "Security Shift Supervision" is the Security Operations ACTION as reported by the (site ACTION as reported by the Serity sifSeri specific security shift supervision)

Security Operations Supervisor Supervisor or designee.or designee (Note 9) The NEI phrase "A credible.. .security threat notification" has been 2 A credible site specific security OR changed to "Receipt of a CREDIBLE/ACTUAL THREAT...

-threat notification (determined by security in accordance with SY-AA-101-1 32, "Threat Receipt of a Assessment")" for clarification.

Threats are evaluated by security 3 A validated notification from NRC CREDIBLE/ACTUAL THREAT per Threat Assessment, SY-AA-101-132.

providing information of an to Salem or Hope Creek station Changed the NEI phrase "site specific" to "Salem or Hope Creek aircraft threat -(determined by security in station" to clarify the intent of the EAL as described in the NEI accordance with SY-AA-101-basis.132, "Threat Assessment")(Note 9) Added the phrase "Salem/Hope Creek" to the third threshold to clarify the intent of the EAL as described in the NEI basis and for OR consistency with the use of "site-specific" in the second NEI A VALIDATED notification from Example EAL.NRC providing information of a Added Note 9 to provide guidance to implement immediate security Salem/Hope Creek AIRCRAFT based response actions prior to declaring the security based threat (Note 9) emergency and to obtain critical information of the nature of the NOTE 9: Shift Manager (SM) security event.should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a 98 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSI HCGS security emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event: Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION* If a HOSTILE ACTION, is location the OCA or PA?99 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HU5 Other conditions exist which in the HU6 Other conditions exist which in The NEI abbreviation "NOUE" has been changed to "UNUSUAL judgment of the Emergency the judgment of the Emergency EVENT" for consistency with other EAL terminology associated with Director warrant declaration of a Coordinator warrant declaration the titles of emergency classification levels.NOUE of an UNUSUAL EVENT MODE: All OPCON: All NE! Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in the HU6.1 Other conditions exist which in None judgment of the Emergency the judgment of the Emergency Director indicate that events are Coordinator indicate that events in progress or have occurred are in progress or have occurred which indicate a potential which indicate a potential degradation of the level of safety degradation of the level of safety of the plant or indicate a security of the plant or indicate a security threat to facility protection has threat to facility protection has been initiated.

No releases of been initiated.

NO releases of radioactive material requiring off- radioactive material requiring off-site response or monitoring are site response or monitoring are expected unless further expected unless further degradation of safety systems degradation of safety systems occurs. occurs 100 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HA1 Natural or destructive phenomena HA1 Natural or destructive None affecting VITAL AREAS phenomena affecting vital areas MODE: All OPCON: All NEI Ex. HCGS HG A odn NEI Example EAL Wording HCGS EAL Wording Difference/Deviation Justification EAL# EAL #1 a. Seismic event greater than HA1.1 Actuation of the OBE Seismic The amber Seismic Switch Event Alarm on the Seismic Switch Operating Basis Earthquake Switch (> 0.1 g) as indicated by Power Supply (SP-1) will illuminate at an acceleration equal to or (OBE) as indicated by (site EITHER: exceeding 0.1 g [OBE]. This also annunciates the seismic activity specific seismic alarm C6-C4 (SEISMIC MON PNL C673). Three time-history instrumentation) reading (site Annunciator C6-C4 triaxial acceleration sensors are provided.

These sensors transmit specific OBE limit). (SEISMIC MON PNL electrical signals to the Control Room where they are recorded on AND673) activated magnetic tape. These tapes are analyzed to determine the exact A Amber alarm light on the magnitude of the seismic event and to confirm whether the OBE b. Earthquake confirmed by ANY Seismic Switch Power has been exceeded.of the following:

Supply Drawer Panel The phrase "by Control Room Operators" has been added for* Earthquake felt in plant 10C673 clarification.

The NEI basis for IC HU1 defines a felt earthquake as AND one having been "recognized as an earthquake based on a SNational Earthquake Center consensus of control room operators on duty at the time." Control Room indication of Earthquake confirmed by A The NEI phrase "National Earthquake Center" has been changed degraded performance of of the following:

to "National Earthquake Information Center" to reflect the proper systems required for the 9 Earthquake felt in plant by title of this agency.safe shutdown of the plant. Control Room Operators The NEI phrase "systems required for safe shutdown of the plant"" National Earthquake has been changed to "safe shutdown systems." Information Center (NEIC) Note 4 provides guidance for contacting the NEIC and obtaining (Note 4) confirmation of seismic activity at the SGS/HCGS site." Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Note 4: The NEIC can be 101 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS contacted by calling (303) 273-8500.

Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station.Provide the analyst with the following coordinates:

390 27' 46" (39.4650) north latitude, 750 32' 08" (75.5370)west longitude.

I + f +2 Tornado striking or high winds greater than (site specific mph)resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: (site specific structure list)HA1.2 Tornado TOUCHING DOWN within the PROTECTED AREA OR Average Wind Speeds > 95 MPH from ANY elevation of the Met Tower AND Resulting in EITHER of the following:

Control Room indication of DEGRADED PERFORMANCE of a Safety System" VISIBLE DAMAGE to ANY of the plant structures in Table H-1 The NEI term "striking" has been changed to "TOUCHING DOWN" for clarification and consistency with the NEI basis definition of"striking." The design wind velocities are 108 mph (including a gust factor of approximately 1.3) at 30 feet above ground for Seismic Category I structures.

However, wind speed indication is limited to 100 mph in the Control Room so the wind speed threshold has been capped at 95 mph to provide margin to the upper limit of the indicated range.The phrase "Average Wind Speeds.. .from ANY elevation of the Met Tower" has been added to clarify the sources from which wind speed information may be obtained.

The SPDS display provides wind speed readings on a 15-minute average.Table H-1 contains the site specific structure list.The NEI phrase "those safety systems" has been changed to "a Safety System" because it is clear from the introductory phrase"Resulting in..." that the degraded performance applies only to a safety system affected by the tornado or high winds.3 Internal flooding in ANY of the HA1.4 Visual Observation of Flooding The NEI phrase "Internal flooding ..." has been changed to "Visual following areas resulting in an in ANY Table H-1 structures Observation of Flooding.. .that confirms ANY of the following:

electrical shock hazard that that confirms ANY of the [three bulleted conditions]" to provide explicit criteria by which the precludes access to operate or following:

EAL-user can assess internal flooding that may affect safety monitor safety equipment OR 102 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS control room indication of degraded performance of those safety systems: (site specific area list)o Reactor Building Floor Levels above the Maximum Normal Floor Level (> 1 in.)referenced in EOP 103/104, Reactor Building and Radioactive Release Control o Receipt of SSWS Pump Room Flooded Alarm A1-B2 (PUMP ROOM FLOODED)" Greater than 2 in. of water in ANY other area that contains a Safety System(s)AND The Flooding is of a magnitude that results in EITHER of the following: " Indication of DEGRADED PERFORMANCE of a Safety System within a Table H-1 Structure.

An Industrial Safety Hazard (Electrical Shock, High Temp, etc.)resulting in access restrictions to operate or monitor Safety System equipment.

related equipment.

For the purpose of implementing this EAL, levels in the Reactor Building that would require classification under this EAL are defined as the Maximum Normal Floor Level in the EOPs.Exceeding this level in any of the Reactor Building areas would require running all available sump pumps. If level in these areas cannot be lowered to below the 1 in. level, systems discharging into this area are to be isolated, except for systems required to: " Ensure adequate core cooling* Shutdown the reactor* Protect primary containment integrity* Suppress a fire Overhead Annunciator A1-B2 (PUMP ROOM FLOODED) is fed from the following CRID points: D5518, D5519, D5533 and D5534.The HCGS (site-specific) areas of the plant are listed in Table H-1.The NEI phrase "resulting in" has been changed to "AND The Flooding is of a magnitude that results in EITHER of the following" for clarification.

The NEI phrase "an electrical shock hazard" has been changed to"An Industrial Safety Hazard (Electrical Shock, High Temp, etc.)" for clarification and consistency with the NEI basis that explicitly cites electrical shock as only one of many possible industrial safety hazards that could preclude personnel access to operate or monitor equipment.

The NEI phrase "those safety systems" has been changed to"Safety System equipment" because it is clear from the introductory phrase "The Flooding is of a magnitude that results in..." that the degraded performance applies only to safety system equipment affected by flooding.Turbine failure-generated HA1.3 Turbine failure-generated Added "...ANY Table H-1 plant structures" to be consistent with PROJECTILES resulting in VISIBLE PROJECTILES resulting in the generic NEI 99-01 bases that the EAL is intended to address DAMAGE to or penetration of ANY EITHER of the following:

visible damage to structures/equipment "containing functions and of the following structures containing systems required for safe shutdown." Table H-1 is titled "Plant 103 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS safety systems or components OR 0 VISIBLE DAMAGE to or Structures Containing Safe Shutdown Systems or Components." control room indication of degraded penetration of ANY The NEI phrase "those safety systems" has been changed to "safe performance of those safety Table H-1 plant shutdown systems" to be consistent with the NEI bases intent. It is systems: structures clear from the introductory phrase "...resulting in EITHER..." that (site specific structure list) 0 Control Room indication the safety systems of concern are those affected by the projectiles.

of DEGRADED PERFORMANCE of safe shutdown systems 5 Vehicle crash resulting in VISIBLE HA1.6 Vehicle Crash or PROJECTILE The phrase "or PROJECTILE Impact" has been added to the DAMAGE to ANY of the following Impact with or within ANY Table vehicle crash threshold as a "site specific occurrence" allowed by structures containing safety systems H-1 Structure NEI Example EAL #6. Projectiles could be generated from events or components OR control room such as a boat explosion in the river, a compressed gas cylinder indication of degraded performance AND ejected during a vehicle crash, objects jettisoned from aircraft, a of those safety systems: The Vehicle Crash or tornado touching down outside the protected area, etc.PROJECTILE Impact results in Table H-1 contains the site specific structure list.(site specific structure list) of the following:

The NEI phrase "those safety systems" has been changed to "a* Control Room indication of Safety System" to be consistent with the NEI bases intent. It is DEGRADED clear from the introductory phrase "...results in EITHER..." that the occurrences) resulting PERFORMANCE of a safety systems of concern are those affected by the vehicle crash 6 (Site specific touANY re Safety System within or projectile.

in VISIBLE DAMAGE to ANY of theTalH-Stuur following structures containing safety systems or components OR

VISIBLE DAMAGE to ANY control room indication of degraded of the plant structures in performance of those safety Table H-1 systems: (site specific structure list)104 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Reactor Building" Control/Auxiliary Building* Service Water Intake Structure" Service/Radwaste Building 105 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HA2 FIRE or EXPLOSION affecting HA2 FIRE or EXPLOSION in a VITAL The phrase "in a VITAL AREA" has been added to the HCGS IC the operability of plant safety AREA affecting the operability of because safety systems required to establish or maintain safe systems required to establish or plant safety systems required to shutdown are located in vital areas.maintain safe shutdown establish or maintain safe MODE: All shutdown OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL #1 FIRE or EXPLOSION resulting HA2.1 FIRE in ANY Table H-1 plant The NEI EAL wording has been changed to agree with the IC in VISIBLE DAMAGE to ANY of structure affecting the operability wording which expresses concern for the operability of safety the following structures of plant safety systems required to systems instead of visible damage or degraded performance.

containing safety systems or establish or maintain safe The duration of a fire has been increased to 15 minutes or more for icationent Of deg trae roconsistency with EAL HU2.1 in which a fire extinguished within 15 indication of degraded AND minutes is not detrimental and does not require emergency performance of those safety classification.

systems: 2! 15 minutes have elapsed (Note (site specific structure list) 3) Vital Areas of concern during a fire or explosion are listed in Table Note 3: The Emergency H-1 plant structures.

Coordinator should NOT Note 3 has been added for consistency with other EALs that specify wait until the applicable a timing duration.time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.HA2.2 EXPLOSION in ANY Table H-1 The example EAL has been broken into two separate EALs plant structure affecting the addressing fire and explosions consistent with the HU2.1 and HU2.2 operability of plant safety systems thresholds.

required to establish or maintain The NEI EAL wording has been changed to agree With the IC 106 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS own wording which expresses concern for the operability of safety systems instead of visible damage or degraded performance.

Vital Areas of concern during a fire or explosion are listed in Table H-1 plant structures.

Table H-1 Plant Structures Containing Safe Shutdown Systems or ComponentsI" Reactor Building* Control/Auxiliary Building* Service Water Intake Structure" Service/Radwaste Building 107 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification Tc# IC#(s)HA3 Access to a vital area is HA3 Access to a VITAL AREA is None prohibited due to toxic, corrosive, prohibited due to toxic, corrosive, asphyxiant or flammable gases asphyxiant or flammable gases which jeopardize operation of which jeopardize operation of operable equipment required to operable equipment required to maintain safe operations or maintain safe operations or safely safely shutdown the reactor shut down the reactor MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Access to a VITAL AREA is HA3.1 Access to ANY Table H-1 plant Table H-1 provides the site-specific list of structures containing prohibited due to toxic, corrosive, structure is prohibited due to equipment necessary for safe shutdown.asphyxiant or flammable gases toxic, corrosive, asphyxiant, or The NEI phrase "a VITAL AREA" has been replaced with "ANY which jeopardize operation of flammable gases which Table H-1 plant structure" for consistency with other Hazards EALs.systems required to maintain safe jeopardize operation of systems operations or safely shutdown the required to maintain safe reactor. operations or safely shut down Note: If the equipment in the the reactor (Note 5)stated area was already Note 5: If the equipment in the inoperable, or out of service, stated area was already before the event occurred, then inoperable, or out of this EAL should not be declared service, before the event as it will have no adverse impact occurred, then this EAL on the ability of the plant to safely should NOT be declared operate or safely shutdown as it will have NO beyond that already allowed by adverse impact on the Technical Specifications at the ability of the plant to time of the event. safely operate or safely shut down beyond that already allowed by Technical Specifications 108 of 143 EAL Comparison Matrix OSSI HCGS at the time of the event.109 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HA4 HOSTILE ACTION within the OWNER HA4 HOSTILE ACTION within the OWNER None CONTROLLED AREA or airborne attack CONTROLLED AREA or airborne attack threat threat MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 A HOSTILE ACTION is occurring or has HA4.1 A HOSTILE ACTION is occurring or has Example EALs #1 and #2 have been combined into occurred within the OWNER occurred within the OCA as reported by a single EAL for usability.

CONTROLED AREA as reported by the the Security Operations Supervisor or The "Security Shift Supervision" is the Security (site specific security shift supervision), designee (Note 9) Operations Supervisor or designee.OR 2 A validated notification from NRC of an OR The NEI phrase "of the site" has been changed to airliner attack threat within 30 minutes of A VALIDATED notification from NRC of a "away from Salem/Hope Creek" to clarify the intent the site AIRLINER attack threat < 30 minutes of the EAL as described in the NEI basis.away from Salem/Hope Creek (Note 9) Added Note 9 to provide guidance to implement NOTE 9: Shift Manager (SM) should immediate security based response actions prior to implement the Prompt Actions of NC.EP- declaring the security based emergency and to EP.ZZ-0102, EC Response, Attachment obtain critical information of the nature of the 10, prior to classification of a security security event.emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event:* Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION If a HOSTILE ACTION, is location the OCA or PA?110 of 143 EAL Comparison Matrix 031 HCGS HCGS NEI IC# NEI IC Wording IC#(s) HCGS IC Wording Difference/Deviation Justification HA5 Control room evacuation has HA5 Control Room evacuation has been None been initiated initiated MODE: All OPCON: All NEI Ex. HCGS EAL 4 NEI Example EAL Wording EALHCGS EAL Wording Difference/Deviation Justification 1 (Site-specific procedure)

HA5.1 Control Room evacuation has been Reference to plant procedures has been eliminated.

The requires control room evacuation, initiated intent of the EAL is that an evacuation of the Control Room has begun for any reason. This change is addressed in NEI/NRC FAQ #28, 111 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HA6 Other conditions exist which in the HA6 Other conditions exist which in the None judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of an warrant declaration of an ALERT Alert OPCON: All MODE: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in the HA6.1 Other conditions exist which in the None judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are in indicate that events are in progress or progress or have occurred which have occurred which involve an actual or involve an actual or potential potential substantial degradation of the substantial degradation of the level of safety of the plant or a security level of safety of the plant or a event that involves probable life security event that involves threatening risk to site personnel or probable life threatening risk to damage to site equipment because of site personnel or damage to site Hostile Action. ANY releases are equipment because of HOSTILE expected to be limited to small fractions ACTION. Any releases are of the EPA Protective Action Guideline expected to be limited to small exposure levels fractions of the EPA Protective Action Guideline exposure levels.112 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HS2 Control room evacuation has been HS5 Control Room evacuation has been None initiated and plant control cannot initiated and plant control CANNOT be be established established MODE: All OPCON: All NEI x. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL #] NIEal EAL #1 a. Control room evacuation has HS5.1 Control Room evacuation has been 15 minutes is the site-specific interval to establish plant been initiated, initiated control following Control Room evacuation.

AND AND Reference to Note 3 has been added to the HCGS EAL for b. Control of the plant cannot be Control of the plant CANNOT be consistency with other NEI EALs with a timing component.

established within (site established within 15 minutes (Note 3)specific minutes).Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.113 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HS3 Other conditions exist which in HS6 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of a warrant declaration of a SITE AREA Site Area Emergency EMERGENCY MODE: All OPCON: All NEl Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in HS6.1 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are indicate that events are in progress or in progress or have occurred have occurred which involve actual or which involve actual or likely likely major failures of plant functions major failures of plant functions needed for protection of the public or needed for protection of the HOSTILE ACTION that results in public or HOSTILE ACTION that intentional damage or malicious acts; (1)results in intentional damage or toward site personnel or equipment that malicious acts; (1) toward site could lead to the likely failure of or; (2)personnel or equipment that could that prevent effective access to lead to the likely failure of or; (2) equipment needed for the protection of that prevent effective access to the public. ANY releases are NOT equipment needed for the expected to result in exposure levels protection of the public. Any which exceed EPA Protective Action releases are not expected to Guideline exposure levels beyond the result in exposure levels which site boundary exceed EPA Protective Action Guideline exposure levels beyond the site boundary 114 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)HS4 HOSTILE ACTION within the HS4 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #A HOSTILE ACTION is occurring HS4.1 A HOSTILE ACTION is occurring or has The "Security Shift Supervision" is the Security Operations or has occurred within the occurred within the PROTECTED AREA Supervisor or designee.PROTECTED AREA as reported as reported by the Security Operations Added Note 9 to provide guidance to implement immediate by the (site security shift Supervisor or designee (Note 9) security based response actions prior to declaring the supervision).

NOTE 9: Shift Manager (SM) should security based emergency and to obtain critical information of implement the Prompt Actions of NC.EP- the nature of the security event.EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event:* Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION* If a HOSTILE ACTION, is location the OCA or PA?115 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(S)HG1 HOSTILE ACTION resulting in HG4 HOSTILE ACTION resulting in loss of None loss of physical control of the physical control of the facility facility OPCON: All MODE: All NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 A HOSTILE ACTION has HG4.1 A HOSTILE ACTION has occurred such The parenthetical examples of safety functions have been occurred such that plant that plant personnel are unable to added the HCGS EAL to clarify the intent of the EAL as personnel are unable to operate operate equipment required to maintain discussed in the NEI basis.equipment required to maintain safety functions (i.e., reactivity control, The NEI phrase "...for a freshly off-loaded reactor core in safety functions.

RPV water level, or decay heat removal) pool " has been deleted. This phrase is not a defined at Salem or Hope Creek (Note 9) condition for HCGS nor is there any relevant guidance for 2 A HOSTILE ACTION has caused failure of Spent Fuel Cooling OR defining such a phrase. The threshold as proposed would require a General Emergency declaration for any hostile Systems and IMMINENT fuel A HOSTILE ACTION has caused failure action resulting in a loss of spent fuel cooling leading to damage is likely for a freshly off- of Spent Fuel Cooling Systems and imminent fuel damage, regardless of the amount of time the loaded reactor core in pool. IMMINENT fuel damage is likely at fuel has been off-loaded.

This change is addressed in Salem or Hope Creek (Note 9) NEI/NRC FAQ #29.NOTE 9: Shift Manager (SM) should The phrase "at Salem or Hope Creek" has been added to the implement the Prompt Actions of NC.EP- two conditions of this EAL for clarification.

EP.ZZ-0102, EC Response, Attachment Added Note 9 to provide guidance to implement immediate 10, prior to classification of a security security based response actions prior to declaring the emergency.

security based emergency and to obtain critical information Key Information to obtain from Security of the nature of the security event.Supervision upon SM notification of a security event:.Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION.If a HOSTILE ACTION, is location 116 of 143 EAL Comparison Matrix OSSI HCGS the OCA or PA?117 of 143 EAL Comparison Matrix OSSI HCGS HOGS NEI IC# NEI IC Wording IC#(s) HCGS IC Wording Difference/Deviation Justification HG2 Other conditions exist which in HG6 Other conditions exist that in the The NEI term "which" has been replaced with "that" for proper the judgment of the Emergency judgment of the Emergency Coordinator grammar.Director warrant declaration of a warrant declaration of GENERAL General Emergency EMERGENCY MODE: All OPCON: All NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL#f 1 Other conditions exist which in HG6.1 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are indicate that events are in progress or in progress or have occurred have occurred which involve actual or which involve actual or IMMINENT substantial core degradation IMMINENT substantial core or melting with potential for loss of degradation or melting with containment integrity or HOSTILE potential for loss of containment ACTION that results in an actual loss of integrity or HOSTILE ACTION physical control of the facility.

Releases that results in an actual loss of can be reasonably expected to exceed physical control of the facility.

EPA Protective Action Guideline Releases can be reasonably exposure levels off-site for more than the expected to exceed EPA immediate site area Protective Action Guideline exposure levels off-site for more than the immediate site area.118 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Category S System Malfunction 119 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU1 Loss of all Off-site AC power to SU1 Loss of all offsite AC power to "Vital buses" is equivalent to the NEI phrase "emergency buses." emergency busses for 15 minutes vital buses for 15 minutes or or longer, longer MODE: Power Operation, Startup, OPCON: 1 -Power Operations, 2 Hot Standby, Hot Shutdown -Startup, 3 -Hot Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL#Loss of all off-site AC power to SUI.1 Loss of all Offsite AC power to all 4.16 KV vital buses are the HCGS emergency buses.(site specific emergency busses) 4.16 KV Vital Buses for 15 minutes or longer. AND Note: The Emergency Director >15 minutes have elapsed (Note should not wait until the 3)applicable time has elapsed, but should Note 3: The Emergency declare the event as soon Coordinator should NOT as it is determined that the wait until the applicable condition has exceeded, time has elapsed, but or will likely exceed, the should declare the event applicable time. as soon as it is determined that the condition will likely exceed the applicable time.120 of 143 EAL Comparison Matrix OSSI HCGS HCGSI NEI IC# NEI IC Wording IC#(s) HCGS IC Wording Difference/Deviation Justification SU2 Inability to reach required SU4 Inability to reach required None shutdown within Technical shutdown within Technical Specification limits Specification limits MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL # ifrneDvato utfcto 1 Plant is not brought to required SU4.1 Plant is NOT brought to required None operating mode within Technical Operational Condition (OPCON)Specifications LCO Action within Technical Specifications Statement Time. LCO action statement time 121 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU3 UNPLANNED loss of safety SU5 UNPLANNED loss of safety None system annunciation or indication system annunciation or indication in the control room for 15 minutes in the Control Room for 15 or longer. minutes or longer MODE: Power Operation, Startup, OPCON: 1 -Power Operations, 2 Hot Standby, Hot Shutdown -Startup, 3 -Hot Shutdown NEI HG Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL #1 .UNPLANNED Loss of greater SU5.1 UNPLANNED loss of > Parts a and b of the NEI example EAL have been introduced with the than approximately 75% of the approximately 75% of Control phrase "UNPLANNED loss of..." for clarification.

following for 15 minutes or Room Overhead Annunciators for "Control Room Overhead Annunciators" are the NEI "Site specific longer: _> 15 minutes (Note 3) control room safety system annunciation." Each Overhead a. (Site specific control room OR Annunciator panel displays multiple annunciators associated with safety system annunciation)

UNPLANNED loss of> safety systems.OR approximately 75% of Control Control Room indicators associated with the listed safety functions b. (Site specific control room Room Indications associated with are the NEI "Site specific control room safety system indication." safety system indication) the following safety functions for >2 HCGS safety systems are designed to fulfill one or more of these 15 minutes (Note 3): safety functions.

Note: The Emergency Director e Reactivity Control should not wait until the applicable time has

RCS Inventory elapsed, but should declare

Decay Heat Removal the event as soon as it is determined that the o Fission Product Barriers condition has exceeded, or Note 3: The Emergency will likely exceed, the Coordinator should NOT applicable time. wait until the applicable time has elapsed, but should declare the event 122 of 143 EAL Comparison Matrix OSSI HCGS as soon as it is determined that the condition will likely exceed the applicable time.123 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU4 Fuel Clad degradation SU7 Fuel clad degradation None MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #(Site specific radiation monitor SU7.1 VALID Offgas Pretreatment The NEI phrase "...radiation monitor readings indicating fuel clad readings indicating fuel clad Radiation Monitor degradation greater than Technical Specification allowable limits" degradation greater than (9RX62119RX622) high alarm has been deleted because it is commonly understood that the Technical Specification Offgas Pretreatment Radiation Monitor high alarm is indicative of allowable limits.) fuel clad degradation associated with the Technical Specification limit.The Offgas Pretreatment Radiation Monitors (9RX621 / 9RX622)sense gamma radiation levels attributable to the noncondensible fission product gases produced in the reactor coolant and transported with steam through the turbine to the condenser.

These instruments take a sample from the sample tap between the fourth and fifth holdup pipe of the Offgas system.Operating Experience at HCGS has demonstrated that reactor coolant activity changes for reasons other than fuel clad degradation can result in temporarily increasing Offgas Pretreatment Radiation Monitor readings.

Such events (e.g., resin intrusion, HWCI system malfunction, etc.) do not require classification under this EAL. For this reason, the EAL begins with the term "valid." The setpoint of the Offgas Pretreatment Radiation Monitor (9RX621/ 9RX622) high alarm is 2.2E+04 mR/hr and ensures that the alarm will actuate prior to exceeding Technical Specification 3.3.7.1 and 3.11.2.7 Offgas System noble gas effluent limit of 3.3E5 pCi/sec.2 (Site specific coolant sample SU7.2 Coolant activity > 4 pCi/gm Dose The specified reactor coolant activity is given in HCGS Technical 124 of 143 EAL Comparison Matrix OSSI HCGS activity value indicating fuel clad degradation greater than Technical Specification allowable limits.)125 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU5 RCS leakage SU8 RCS leakage None MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #Unidentified or pressure SU8.1 UNIDENTIFIED LEAKAGE or SU8.1 implements Example EALs #1 and #2. These were combined boundary leakage greater than PRESSURE BOUNDARY for improved usability.

10 gpm LEAKAGE > 10 gpm (Using 10 The phrase "(Using 10 minute average)" has been added to clarify minute average) (Note 6) the method by which UNIDENTIFIED and PRESSURE BOUNDARY 2 Identified leakage greater than 25 gpm OR LEAKAGE can be determined.

IDENTIFIED LEAKAGE > 25 IDENTIFIED LEAKAGE should ONLY be classified as an UNUSUAL gpm (Averaged over any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EVENT, when the leak rate exceeds 25 gpm when averaged over period) (Note 6) any 24-hour period, regardless of whether or not the leak has been isolated.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average is included as part of the EAL Note 6: See the Fission Product threshold to provide consistency with the Technical Specification limit Barrier Table for possible for IDENTIFIED LEAKAGE.escalation above the UNUSUAL EVENT due to The Hope Creek Technical Specification limit for RCS IDENTIFIED RCSUALe EVENTLEAKAGE is 25 gpm averaged over any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The plant is within Technical Specification as long as this limit is not exceeded and hence an UNUSUAL EVENT is not warranted until the limit is exceeded.This philosophy is consistent with that contained in NEI 99-01 Rev. 5 Section 3, which only requires declaration of an UNUSUAL EVENT when the plant is outside the Technical Specification.

Note 6 has been added to remind the EAL-user to review the Fission Product Barrier Table for possible escalation to higher emergency classifications due to RCS leakage.126 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU6 Loss of all On-site or Off-site SU6 Loss of all onsite or offsite None communications capabilities communications capabilities MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL 4 EAL #1 Loss of all of the following on- SU6.1 Loss of all Table S-2 Onsite SU6.1 implements Example EALs #1 and #2. These were combined site communication methods communication methods affecting for improved usability.

affecting the ability to perform the ability to perform routine The NEI example EALs specify site-specific lists of onsite and offsite routine operations.

operations communications methods. The HCGS EAL lists these methods in (site specific list of OR Table S-2 for simplification.

communications methods) Loss of all Table S-2 Offsite communication methods affecting the ability to perform offsite 2 Loss of all of the following off- notifications site communication methods affecting the ability to perform offsite notifications.(site specific list of communications methods)127 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table S-2 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics)

X Station Radio System X Nuclear Emergency Telephone System X (NETS)Centrex Phone System (ESSX) X NRC (ENS) X 128 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SU8 Inadvertent criticality SU3 Inadvertent criticality None MODE: Hot Standby, Hot OPCON: 3 -Hot Shutdown Shutdown NEI Ex. HOGS HG A odn EI E NEI Example EAL Wording EAL HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 UNPLANNED sustained positive SU3.1 UNPLANNED sustained positive None period observed on nuclear period observed on nuclear instrumentation.

[BWR] instrumentation 1 UNPLANNED sustained positive N/A N/A NEI PWR Example EAL #1 has not been implemented because it startup rate observed on nuclear applies only to PWR plants. HCGS is a BWR.instrumentation.

[PWR]129 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SA2 Automatic Scram (Trip) fails to SA3 Automatic scram fails to shut The NEI term "Trip" has been deleted to use terminology common shutdown the reactor and the down the reactor and the manual to a BWR.manual actions taken from the actions taken from the reactor reactor control console are control console are successful in successful in shutting down the shutting down the reactor reactor OPCON: 1 -Power Operations, 2 MODE: Power Operation, Startup -Startup N~l Ex.HOGS NEI Ex. NEI Example EAL Wording EAL HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. An automatic scram (trip) SA3.1 An automatic scram failed to shut The NEI term "Trip" has been deleted to use terminology common to failed to shutdown the down the reactor a BWR.reactor. AND Following a successful reactor scram, a prompt drop in reactor AND power to subcriticality should occur. This is defined to be at or below Manual scram actions taken at the APRM downscale trip setpoint (4%).b. Manual actions taken at the the reactor control console reactor control console (mode switch, manual scram The NEI phrase "Manual actions" has been changed to "Manual successfully shutdown the pushbuttons, manual ARI scram actions" and the phrase "mode switch, manual scram reactor as indicated by (site actuation) successfully shut pushbuttons or manual ARI actuation" has been added for specific indications of plant down the reactor as indicated by clarification.

shutdown).

reactor power < 4%130 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SA4 UNPLANNED Loss of safety SA5 UNPLANNED loss of safety None system annunciation or indication system annunciation or indication in the control room with EITHER in the Control Room with either (1)(1) a SIGNIFICANT TRANSIENT a SIGNIFICANT TRANSIENT in in progress, or (2) compensatory progress, or (2) compensatory indicators unavailable, indicators unavailable MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI HCGS Ex. NEI Example EAL Wording EAL H HCGS EAL Wording Difference/Deviation Justification EALEL 1 a. UNPLANNED Loss of greater SA5.1 UNPLANNED loss of > Parts a and b of the NEI example EAL have been introduced with than approximately 75% of the approximately 75% of Control the phrase "UNPLANNED loss of..." for clarification.

following for 15 minutes or Room Overhead Annunciators for "Control Room Overhead Annunciators" are the NEI "Site specific longer: 2 15 minutes (Note 3) control room safety system annunciation." Each Overhead (Site specific control room OR Annunciator panel displays multiple annunciators associated with safety speii cUNPLANNED loss of > safety systems.safety system approximately 75% of Control annunciation)

Room Indications associated with Control Room indicators associated with the listed safety functions OR the following safety functions for -> are the NEI "Site specific control room safety system indication."* (Site specific control room 15 minutes (Note 3): HCGS safety systems are designed to fulfill one or more of these safety system indication) safety functions.

b. EITHER of the following:

Reactivity Control Table S-1 provides the list of events that constitute a "significant

A SIGNIFICANT

RCS Inventory transient" as specified in the NEI Section 5.4 definition of significant TRANSIENT in progress

Decay Heat Removal transient.

The NEI Section 5.4 definition of significant transient has* Compensatory indications been changed to reflect BWR-specific requirements:

are unavailable

Fission Product Barriers e Many BWRs have bypass capability

> 25% such that they can Note: The Emergency Director AND handle a 25% full electrical load rejection (i.e., results in no should not wait until the thermal power transient).

Others can only handle as low as a applicable time has EITHER of the following:

10% full electrical load rejection.

HCGS is equipped with* A SIGNIFICANT 22.18% turbine bypass capacity (rounded to 22%). There are 131 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSI HCGS elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.TRANSIENT is in progress, Table S-I* Compensatory indications are NOT available (PPC, CRIDS and SPDS)Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.other events that can cause a 25% power reduction such as recirculation system runbacks.

Any 25% thermal power reduction, regardless of cause, would meet the intent of the significant transient condition.

The BWR equivalent to a Safety Injection Activation is ECCS injection.

This change is being addressed in NEI/NRC FAQ #39.The NEI term "unavailable" has been changed to "NOT available" for clarification.

PPC, CRIDS and SPDS are the plant specific compensatory indications and have been added in parenthesis for clarification.

132 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS Table S-1 SIGNIFICANT TRANSIENTS

Reactor scram o Thermal Power Reduction

> 25%* Electrical Load rejection

> 22%* ECCS injection* Thermal power oscillations

> 10%133 of 143 EAL Comparison Matrix 0551 HCGS EAL Comparison Matrix OSSIHCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SA5 AC power capability to SA1 AC power capability to vital "Vital buses" is equivalent to the NEI phrase "emergency buses." emergency busses reduced to a buses reduced to a single power The term "station blackout" was replaced with "complete loss of AC single power source for 15 source for 15 minutes or longer power to vital buses" as this describes the intended condition leading minutes or longer such that any such that any additional single to the Alert threshold in CA1.1. Station Blackout is not an additional single failure would failure would result in complete operationally defined term for loss of all AC to vital buses.result in station blackout.

loss of AC power to vital buses MODE: Power Operation, OPCON: I -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. EALGS EI NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #a. AC power capability to (site- SA1.1 Loss of 4.16 KV Vital Bus Power 4.16 KV vital buses are the HCGS emergency buses.specific emergency busses) Sources (Offsite and Onsite) The NEI phrase "AC power capability to (site specific emergency reduced to a single power which results in the availability of busses) reduced to a single power source" has been changed to source for 15 minutes or only one 4.16 KV Vital Bus "Loss of 4.16 KV Vital Bus Power Sources (Offsite and Onsite) which longer. Power Source (Offsite or Onsite) results in the availability of only one 4.16 KV Vital Bus Power Source AND AND (Offsite or Onsite)" because to reflect the specific HCGS vital power b. Any additional single power _> 15 minutes have elapsed configuration..

source failure will result in (Note 3) The AND logic used in NEI 99-01 is improper as the second station blackout.

condition is not a separate condition of equal weight but rather a Note: The Emergency Director Note 3: The Emergency qualifier of the first. The threshold statement has been reworded to should not wait until the Coordinator should NOT properly reflect the intent.applicable time has wait until the applicable Station Blackout is not an operationally defined term for loss of all elapsed, but should time has elapsed, but Ato Blabusefo declare the event as should declare the event AC to vital buses.soon as it is determined as soon as it is that the condition has determined that the exceeded, or will likely condition will likely exceeded, ore willlikee exceed the applicable exceed, the applicabletie time. time.134 of 143 EAL Comparison Matrix OSSI HCGS 135 of 143 EAL Comparison Matrix OSSI HCGS HOGS NEI IC# NEI IC Wording IC#(s) HCGS IC Wording Difference/Deviation Justification SS1 Loss of all Off-site and all On- SS1 Loss of all offsite power and all "Vital buses" is equivalent to the NEI phrase "emergency buses." Site AC power to emergency onsite AC power to vital buses busses for 15 minutes or longer, for 15 minutes or longer MODE: Power Operation, OPCON: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of all Off-Site and all On- SS1.1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has Site AC power to (site specific Offsite) to all 4.16 KV Vital been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses) for 15 Buses simplification.

minutes or longer. AND 4.16 KV vital buses are the HCGS emergency buses.Note: The Emergency Director > 15 minutes have elapsed should not wait until the (Note 3)applicable time has elapsed, but should Note 3: The Emergency declare the event as Coordinator should NOT soon as it is determined wait until the applicable that the condition has time has elapsed, but exceeded, or will likely should declare the event exceed, the applicable as soon as it is time. determined that the condition will likely exceed the applicable time.136 of 143 EAL Comparison Matrix OSSI HOGS EAL Comparison Matrix OSSI HCGS NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification Automatic Scram (Trip) fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor MODE: Power Operation, Startup SS3 Automatic scram fails to shut down the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor OPCON: 1 -Power Operations, 2 -Startup The NEI term "Trip" has been deleted to use terminology common to a BWR.-~~~~1 _____________________________________________________

_______________

I ___________________________________________________

I EAL # NEI Example EAL Wording EAL HCGS EAL Wording Difference/Deviation Justification NlEx.# NExmleELWrdn OS OSEL odn 1 a. An automatic scram (trip)failed to shutdown the reactor.AND b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by (site specific indications of reactor not shutdown).

SS3.1 An automatic scram failed to shut down the reactor AND Manual scram actions taken at the reactor control console (mode switch, manual scram pushbuttons, manual ARI do NOT shut down the reactor as indicated by reactor power > 4%The NEI term "Trip" has been deleted to use terminology common to a BWR.The site specific indication of reactor not shutdown is the APRM downscale trip setpoint (4%).The NEI phrase "Manual actions" has been changed to "Manual scram actions" and the phrase "mode switch, manual scram pushbuttons or manual ARI actuation " has been added for clarification.

137 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SS3 Loss of all vital DC power for 15 SS2 Loss of all vital DC power for 15 None minutes or longer minutes or longer MODE: Power Operation, OPCON: 1 -Power Operations, Startup, Hot Standby, Hot 2 -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL #t EAL #t 1 Less than (site specific bus SS2.1 < 108 V DC bus voltage 108 VDC is the site-specific bus voltage.voltage indication) on all (site indication on all Vital 125 V DC 125 VDC Power Channels A, B, C and D are the site-specific vital specific Vital DC busses) for 15 Buses DC buses.minutes or longer. AND Note: The Emergency Director > 15 minutes have elapsed should not wait until the (Note 3)applicable time has elapsed, but should Note 3: The Emergency declare the event as Coordinator should NOT soon as it is determined wait until the applicable that the condition has time has elapsed, but exceeded, or will likely should declare the event exceed, the applicable as soon as it is time. determined that the condition will likely exceed the applicable time.138 of 143 EAL Comparison Matrix 0351 HOGS EAL Comparison Matrix OSSI HCGS NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)Inability to Monitor a SS5 Inability to monitor a None SIGNIFICANT TRANSIENT in SIGNIFICANT TRANSIENT in Progress progress MODE: Power Operation, OPCON: 1 -Power Operations, Startup, Hot Standby, Hot 2 -Startup, 3 -Hot Shutdown Shutdown NEI Ex.EAL #NEI Example EAL Wording HCGS EAL #HCGS EAL Wording Difference/Deviation Justification 1 a. Loss of greater than approximately 75% of the following for 15 minutes or longer:* (Site specific control room safety system annunciation)

OR 0 Site specific control room safety system indication)

AND b. A SIGNIFICANT TRANSIENT in progress AND c. Compensatory indications are unavailable Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the SS5.1 Loss of > approximately 75%of Control Room Overhead Annunciators for 2! 15 minutes (Note 3)OR Loss of > approximately 75%of Control Room Indications associated with the following safety functions for _> 15 minutes (Note 3): " Reactivity Control" RCS Inventory" Decay Heat Removal* Fission Product Barriers AND A SIGNIFICANT TRANSIENT is in progress, Table S-1 AND Compensatory indications are NOT available (PPC, CRIDS Parts a and b of the NEI example EAL have been introduced with the phrase "UNPLANNED loss of..." for clarification."Control Room Overhead Annunciators" are the NEI "Site specific control room safety system annunciation." Each Overhead Annunciator panel displays multiple annunciators associated with safety systems.Control Room indicators associated with the listed safety functions are the NEI "Site specific control room safety system indication." HCGS safety systems are designed to fulfill one or more of these safety functions.

Table S-1 provides the list of events that constitute a "significant transient" as specified in the NEI Section 5.4 definition of significant transient.

The NEI Section 5.4 definition of significant transient has been changed to reflect BWR-specific requirements:

e Many BWRs have bypass capability

> 25% such that they can handle a 25% full electrical load rejection (i.e., results in no thermal power transient).

Others can only handle as low as a 10% full electrical load rejection.

HCGS is equipped with 22.18%turbine bypass capacity (rounded to 22%). There are other events that can cause a 25% power reduction such as recirculation system runbacks.

Any 25% thermal power reduction, regardless of cause, would meet the intent of the 139 of 143 EAL Comparison Matrix 0551 HOGS EAL Comparison Matrix OSSIHCGS condition has exceeded, and SPDS) significant transient condition.

or will likely exceed, the Note 3: The Emergency

The BWR equivalent to a Safety Injection Activation is ECCS applicable time. Coordinator should NOT injection.

wait until the applicable This change is being addressed in NEI/NRC FAQ #39.time has elapsed, but should declare the event The NEI term "unavailable" has been changed to "NOT available" for as soon as it is clarification.

determined that the PPC, CRIDS and SPDS are the plant specific compensatory condition will likely indications and have been added in parenthesis for clarification.

exceed the applicable time.Table S-1 SIGNIFICANT TRANSIENTS

Reactor scram" Thermal Power Reduction

> 25%* Electrical Load rejection

> 22%" ECCS injection* Thermal power oscillations

> 10%140 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SG1 Prolonged loss of all Off-site and SG1 Prolonged loss of all offsite and "Vital buses" is equivalent to the NEI phrase "emergency buses." all On-Site AC power to all onsite AC power to vital emergency busses. buses MODE: Power Operation, OPCON: 1 -Power Operations, Startup, Hot Standby, Hot 2 -Startup, 3 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording HOGS HCGS EAL Wording Difference/Deviation Justification EAL# EAL#1 a. Loss of all off-site and all on- SG1 .1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has site AC power to (site specific Offsite) to all 4.16 KV Vital been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses). Buses simplification.

AND AND 4.16 KV vital buses are the HCGS emergency buses.b. EITHER of the following:

ANY of the following:

The NEI phrase "AND ...EITHER" has been changed to" Restoration of at least "AND.. .ANY" because more than two HCGS conditions are needed one emergency bus in

Restoration of at least one to implement the two bulleted NEI conditions.

less than (site specific Vital Bus in < 4 hrs is NOT hours) is not likely. likely 4 are the "(site-specific)" hours for station blackout coping. The four-h (Site specific Indication of hour interval to restore AC power is based on the blackout coping coitecinuicIngdeg ation of

RPV level CANNOT be analysis performed in conformance with 10 CFR 50.63 and continuing degradation of restored and maintained Regulatory Guide 1.155.core cooling based on Fission Product Barrier above -161 i The NEI phrase "...(Site-Specific Indication of continuing monitoring.)

e RPV level CANNOT be degradation of core cooling based on Fission Product Barrier determined monitoring)" has been replaced with "RPV level CANNOT be restored and maintained above -161 in...RPV level CANNOT be determined" for clarification.

This threshold represents the NEI conditions consistent with the corresponding Fuel Clad barrier Potential Loss and RCS barrier Loss thresholds for RPV water level.141 of 143 EAL Comparison Matrix OSSI HCGS NEI IC# NEI IC Wording HCGS HCGS IC Wording Difference/Deviation Justification IC#(s)SG2 Automatic Scram (Trip) and all SG3 Automatic scram and all manual The NEI term "Trip" has been deleted to use terminology common to manual actions fail to shutdown actions fail to shut down the a BWR.the reactor and indication of an reactor and indication of an extreme challenge to the ability extreme challenge to the ability to cool the core exists to cool the core exists MODE: Power Operation, OPCON: 1 -Power Operations, Startup 2 -Startup NEI Ex. NEI Example EAL Wording HCGS HCGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. An automatic scram (trip) SG3.1 An automatic scram failed to "The NEI term "Trip" has been deleted to use terminology common failed to shutdown the shut down the reactor to a BWR.reactor. AND The site specific indication of reactor not shutdown is the APRM AND All manual actions do NOT shut downscale trip setpoint (4%).b. All manual actions do not down the reactor as indicated by The NEI phrase "exist or have occurred" has been deleted. The shutdown the reactor as reactor power > 4% extreme challenge to core cooling only exists if RPV level cannot be indicated by (site specific AND restored and maintained above the threshold level. The extreme indications of reactor not challenge to heat removal only exists while the threshold limit is shutdown).

EITHER of the following:

exceeded.AND

RPV level CANNOT be The NEI phrase "due to continued power generation" has been c. EITHER of the following restored and maintained deleted because the reason core cooling or heat removal is exist or have occurred due to above -185 in. extremely challenged in an ATWS event is immaterial.

This change exis orhav occrre du tois being addressed in NEI/NRC FAQ #31.continued power generation:

HCTL (EOP Curve SPT-P)* (Site specific indication is exceeded The site specific indication that core cooling is extremely challenged tha (S oe specooif in n is the Minimum Steam Cooling RPV Water Level (MSCRWL).

The that core cooling is MSCRWL is the lowest RPV level at which the covered portion of the reactor core will generate sufficient steam to prevent any clad" (Site specific indication temperature in the uncovered part of the core from exceeding that heat removal is 1500'F. This water level is utilized in the EOPs to preclude fuel extremely challenged.)

damage when RPV level is below the top of active fuel. RPV level below the MSCRWL for an extended period of time without 142 of 143 EAL Comparison Matrix OSSI HCGS EAL Comparison Matrix OSSI HCGS satisfactory core spray cooling could be a precursor of a core melt sequence.The site specific indication that heat removal is extremely challenged is the Heat Capacity Temperature Limit (HCTL). The HCTL is the highest suppression pool water temperature from which Emergency RPV Depressurization will not raise suppression chamber pressure above the Primary Containment Pressure Limit (PCPL), while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.The HCTL is a function of RPV pressure and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant. Plant parameters in excess of the HCTL could be a precursor of primary containment failure. Reference to the EOP curve that illustrates the HCTL has been added for clarification.

143 of 143

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