NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 2 of 4
Text
FISSION PRODUCT BARRIER ICS/EALS INOne 39 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~~HGI: INITIATING CONDITIONS
..Difference
/ Deviation
/ Justification None THRSHOLDS NET199-01 Rev 6 Farley (1) a. A HOSTILE ACTION is occurring or has occurred within (1) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific the PROTECTED AREA as reported by the site security security shift supervision), force.AND AND b. EITHER of the following has occurred:
- b. EITHER of the following has occurred: 1. ANY of the following safety functions cannot be I. ANY of the following safety functions cannot be controlled or maintained, controlled or maintained.
- Reactivity control 0 Reactivity control* Core cooling [PWR] / RPV water level [BWR] S Core cooling* RCS heat removal
- RCS heat removal OR OR 2. Damage to spent fuel has occurred or is 2. Damage to spent fuel has occurred or is IMMINENT.
IMMINENT.Difference I Deviation I Justification Difference:
Site specific information provided.40 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HG7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (I) Other conditions exist which in the judgment of the Emergency (I) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or IMLMINENT substantial core degradation or involve actual or IMIMINENT substantial core degradation or melting melting with potential for loss of containment integrity or HOSTILE with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the Protective Action Guideline exposure levels offsite for more than the immediate site area. immediate site area.Difference I Deviation
/ Justification None 41 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift PROTECTED AREA as reported by the site security force.supervision).
Difference I Deviation I Justification Difference:
Site specific information provided.42 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HS6: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An event has resulted in plant control being transferred (1) a. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown from the control room to the remote shutdown panel.panels and local control stations).
AND AND b. Control of ANY of the following key safety functions is not b. Control of ANY of the following key safety functions is not reestablished within 15 minutes reestablished within (site-specific number of minutes).
- Reactivity control* Reactivity control
- Core cooling* Core cooling [PWR] / RPV water level [BWR] 0 RCS heat removal* RCS heat removal Difference
/ Deviation I Justification Difference:
Site specific information provided.43 HAZARDANDOHER:
CONDITIOTNS AFFECTINGPLNTSAEYCSEL H57: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public, effective access to equipment needed for the protection of the public.Any releases are not expected to result in exposure levels which Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the exceed EPA Protective Action Guideline exposure levels beyond the site boundary, site boundary.Difference
/ Deviation
/ Justification None 44 HAZARDANDOHER:
CONDTITIONS AFFECTINGPLNTSAEYCSAL HAl: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. attack threat within 30 minutes.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) A HOSTILE ACTION is occurring or has occurred within the (I1) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific OWNER CONTROLLED AREA as reported by the site security security shift supervision), force.(2) A validated notification from NRC of an aircraft attack threat within (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. 30 minutes of the site.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.45 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA5: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: into any Table Hi plant rooms or areas: (site-specific list of plant rooms or areas with entry-related Table HI mode applicability identified)
Mode Room Name Room Number AND Electrical Penetration Room 334,333,347/
- b. Entry into the room or area is prohibited or impeded. 2334,2333,2347 3 Hallway Outside Filter Room 3 12,332/1A.2A MCC areas 23 12,2332 Sample Room and Primary CHM labs 323, 324/______2323, 2324 Sample Room and Primary CHM labs 323, 324/4 2323, 2324 RHR Hx Room 128/_______2128 AND b. Entry into the room or area is prohibited or impeded.Difference I Deviation
/ Justification Differences:
Site specific information provided.46 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) An event has resulted in plant control being transferred from the (1) An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control room to the remote shutdown panel.control stations).
Difference
/ Deviation I Justification Difference:
Site specific information provided.47 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Other conditions exist which, in the judgment of the Emergency (1) Other conditions exist which, in the judgment of the emergency Director, indicate that events are in progress or have occurred which director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline limited to small fractions of the EPA Protective Action Guideline exposure levels, exposure levels.Difference
/ Deviation
/ Justification None 48 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HUI: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) A SECURITY CONDITION that does not involve a HOSTILE (1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).
ACTION as reported by the site security force.(2) Notification of a credible security threat directed at the site. (2) Notification of a credible security threat directed at FNP.(3) A validated notification from the NRC providing information of an (3) A validated notification from the NRC providing information of an aircraft threat, aircraft threat.Difference
/ Deviation
/ Justification Difference:
EAL Threshold (2); replaced 'the site' with FNP.Justification:
Editorial change -clearly identifies that threat is directed against the Farley site.Difference:
Site specific information provided.49 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU2: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Seismic event greater than Operating Basis Earthquake (OBE) as (1) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: indicated by seismic switch activation with the seismic system (site-specific indication that a seismic event met or exceeded OBE computer indicating EITHER of the following:
limits)
- Cumulative Absolute Velocity (CAV) greater than 0.160 g-sec AND Spectral Accelaration greater than 0.200g* Cumulative Absolute Velocity (CAV) greater than 0.160 g-sec AND Spectral Velocity greater than 15.240 cm/sec Difference I Deviation
/ Justification Difference:
Site specific information provided.
See VIS Seismic ARP -FNP-I(2)-ARP-I.12.
50 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU3: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None NET 99-01 Rev 6 Farley (1) A tornado strike within the PROTECTED AREA. (1) A tornado strike within the PROTECTED AREA.(2) Internal room or area flooding of a magnitude sufficient to require (2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode. component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA is impeded (3) Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release), chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to (4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles, prohibit the plant staff from accessing the site via personal vehicles.(5) (Site-specific list of natural or technological hazard events) (5) Sustained hurricane force winds greater than 74 mph forecast to be at the plant site in the next four hours.Difference
/ Deviation
/ Justification Difference:
Site specific information provided for EAL Threshold (5).51 HAZARDANDOHER:
CONDITIOTNS AFFECTINGPLNTSAEYCSAL HU4: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or S Receipt of multiple (more than 1) fire alarms or indications indications
- Field verification of a single fire alarm S Field verification of a single fire alarm AND AND b. The FIRE is located within ANY Table H2 rooms or areas.b. The FIRE is located within ANY of the following plant (2) a. Receipt of a single fire alarm (i.e., no other indications of a rooms or areas: FIRE).(site-specific list of plant rooms or areas) AND (2) a. Receipt of a single fire alarm (i.e., no other indications of a b. The FIRE is located within ANY of the Table H2 rooms or FIRE). areas.AND AND b. The FIRE is located within ANY of the following plant c. The existence of a FIRE is not verified within 30-minutes rooms or areas: of alarm receipt.(site-specific list of plant rooms or areas) (3) A FIRE within the plant PROTECTED AREA or ISFSI AND PROTECTED AREA not extinguished within 60-minutes of the c. The existence of a FIRE is not verified within 30-minutes initial report, alarm or indication.
of alarm receipt. (4) A FIRE within the plant PROTECTED AREA or ISFSI (3) A FIRE within the plant or lSFSI [for plants with an lSFSl outside PROTECTED AREA that requires firefighting support by an offsite the plant Protected Area] PROTECTED AREA not extinguished fire response agency to extinguish.
within 60-minutes of the initial report, alarm or indication.
52 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (4) A FIRE within the plant or ISFSI [for plants with an ISFSl outside Table 112 the plant Protected Area] PROTECTED AREA that requires Auxiliary Buildin~g firefighting support by an offsite fire response agency to extinguish.
Diesel Generator IService Water Intake Structure (SWIS)Containment Difference
/ Deviation
/ Justification Differences:
EAL Thresholds (l)b and (2)b -added reference to Table 112 instead of listing areas separately for each threshold.
Justification:
Human factors consideration
-applicable rooms are the same for each threshold.
Placing these rooms into one table and referencing the table simplifies the process for identifying applicable rooms.Differences:
EAL Thresholds (3) and (4) -added PROTECTED AREA after plant.Justification:
Clarifies plant areas that are applicable to these EAL thresholds.
Differences:
Added Table 112 with applicable site specific room listing.53 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU7: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems monitoring are expected unless further degradation of safety systems occurs. occurs.Difference I Deviation
/ Justification None 54 SYSTEM MALFUNCTIONS SGI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses). 4160V ESF busses 1I(2)F ANDj 1 (2)G.AND AND b. EITHER of the following:
- b. EITHER of the following:
- Restoration of at least one AC emergency bus in less
- Restoration of at least one AC emergency bus in less than (site-specific hours) is not likely. than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.* (Site-specific indication of an inability to adequately
- CORE COOLING CSF -RED conditions met remove heat from the core)Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See VI3 ESF Busses Drawing and VI6 CSFST Information.
55 SYSTEM MALFUNCTIONS SG8: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses) for 15 minutes or longer. 4160V ESF busses l(2)F AND l(2)G for 15 minutes or AND longer.b. Indicated voltage is less than (site-specific bus voltage AND value) on ALL (site-specific Vital DC busses) for 15 b. Indicated voltage is less than 105 VDC on ALL 125 VDC minutes or longer. vital busses for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See VI3 ESF Busses Drawing and V14 DC Voltage Reference.
56 SYSTEM MALFUNCTIONS SSI: INITIATING CONDITIONS None THRESHOLDS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.57 SYSINTEMIALFUNGCODTIONS SSS: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley Inability to shut down the reactor causing a challenge to (core cooling [PWR] Inability to shutdown the reactor causing a challenge to core cooling or RCS I RPV water level [BWR]) or RCS heat removal, heat removal.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley a. An automatic or manual (trip [PWR] / scram [BWR]) did +(I)not shutdown the reactor.AND b. All manual actions to shut down the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* (Site-specific indication of an inability to adequately remove heat from the core)* (Site-specific indication of an inability to adequately remove heat from the RCS)(1)a. An automatic or manual trip did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* Core Cooling CSF -RED conditions met* Heat Sink CSF -RED conditions met Difference:/
Deitioe Jsteificifrainpoie.SeV6CFTIfration.
Difference:
Site specific information provided.
See V16 CSFST In formation.
58 SYSTEM MALFUNCTIONS SS8: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Indicated voltage is less than (site-specific bus voltage value) on (1) Indicated voltage is less than 105 VDC on ALL 125 VDC vital ALL (site-specific Vital DC busses) for 15 minutes or longer, busses for 15 minutes or longer.Difference I Deviation
/ Justification Difference:
Site specific information provided.
See V14 DC Voltage Reference.
59 SSAINTEMIALFUNGCODTIONS SAl: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Difference I Deviation
/ Justification THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 1 5 minutes or longer.AND b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.(1) a. AC power capability to BOTH 4160V ESF busses I(2)F AND I(2)G is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.Table SI Unit 1 Unit 2 Start-up Aux XFMR 1 A Start-up Aux XFMR 2A Start-up Aux XFMR lB Start-up Aux XFMR 2B Diesel Generator 1I-2A Diesel Generator 1 -2A Diesel Generator 1 B Diesel Generator 2B Diesel Generator 1 C Diesel Generator IC Diesel Generator 2C Diesel Generator 2C Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.60 SSA2NTEMIALFUNGCODTIONS 5A2: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An UNPLANNED event results in the inability to monitor (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the one or more of the following parameters from within the Control Room for 15 minutes or longer. Control Room for 15 minutes or longer.[ BWR parameter list] [PWR parameter list] Reactor Power Reactor Power Reactor Power RCS Level RCS Pressure RPV Water Level RCS Level In-Core/Core Exit Temperature RPV Pressure RCS Pressure Wide RangRe Level in at least one steam [generator Primary Containment In-Core/Core Exit Steam Generator Auxiliary or Emerg:ency Feed Water Flow Pressure Temperature Suppression Pool Level Levels in at least (site- AND specific number) steam generators
- b. ANY of the following transient events in progress.Suppression Pool Steam Generator Auxiliary 0 Automatic or manual runback greater than 25%Temperature or Emergency Feed Water thermal reactor power Flow 0 Electrical load rejection greater than 25% full electrical load AND S Reactor trip 0 ECCS actuation b. ANY of the following transient events in progress.61 SYSTEM MALFUNCTIONS
- Automatic or manual runback greater than 25%thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor scram [BWR] / trip [PWR]* EGGS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Farley specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 includes (SI) after ECCS. Farley does not include (SI) after ECCS.Justification:
Site preference, does not detract or affect EAL determination.
62 SYSTEM MALFUNCTIONS SA5: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Automatic or manual (trip [PWRJ / scram [BWR]) fails to shut down the Automatic or manual trip fails to shutdown the reactor, and subsequent reactor, and subsequent manual actions taken at the reactor control consoles manual actions taken at the reactor control consoles are not successful in are not successful in shutting down the reactor, shutting down the reactor.Difference I Deviation
/ Justification None THRESHOLDS NE199-01 Rev 6 Farley (1) a. An automatic or manual (trip [PWR] / scram [BWR]) did (1) a. An automatic or manual trip did not shutdown the reactor.not shutdown the reactor.AND AND b. Manual actions taken at the reactor control consoles are not b. Manual actions taken at the reactor control consoles are not successful in shutting down the reactor.successful in shutting down the reactor.Difference I Deviation I Justification None 63 SYSTEM MALFUNCTIONS SA9: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake) 0 Seismic event (earthquake)
- Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE S FIRE* EXPLOSION 0 EXPLOSION* (site-specific hazards) 0 Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:
- b. EITHER of the following:
- Event damage has caused indications of degraded I. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.
- The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference
/ Deviation
/ Justification Difference:
No additional site specific hazards identified.
Justification:
Site personnel have determined that no additional site specific hazards are applicable to this EAL threshold.
64 SYSTEM MALFUNCTIONS SUI: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley Loss of all offsite AC power capability to emergency buses for 15 minutes or Loss of all offsite AC power capability to emergency buses for 15 minutes or longer, longer.Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Loss of ALL offsite AC power capability to (site-specific (1) Loss of ALL offsite AC power capability to BOTHj 4160V ESF emergency buses) for 15 minutes or longer, busses l(2)F AN l(2)G for 15 minutes or longer.Table $2 IUniti 1 Unit 2 Start-up Aux XFMR 1 A Start-up Aux XFMR 2A Start-up Aux XFMR lB Start-up Aux XFMR 2B Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.65 SYSTEM MALFUNCTIONS SU2: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley UNPLANNED loss of Control Room indications for 15 minutes or longer. UNPLANNED loss of Control Room indications for 15 minutes or longer.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley 4 (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.(1) a.[BWR parameter list] [P WR parameter list]Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment In-Core/Core Exit Pressure Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Steam Generator Temperature Auxiliary or Emergency__________________Feed Water Flow An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Contr'ol Room for 15 minutes or longer.Reactor Power RCS Level RCS Pressure In-Core/Core Exit Temperature Wide Range Level in at least one steam generator Steam Generator Auxiliary or Emergency Feed Water Flow Difference
/ Deviation
/ Justification Difference:
NE! 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Farley specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
66 SSU3NTEMIALFUNGCODTIONS 5133: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits.Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley 1-(1) (Site-specific radiation monitor) reading greater than (site-specific value).(2) Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
(1) RCS coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits as indicated by ANY of the following:
Dose Equivalent 1-131 greater than 0.5 [iCi/gm for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Dose Equivalent I-131 greater than Technical Specification figure 3.4.16-1.IF less than 20% power, THEN use the Dose Equivalent I-131 20% power limit on Technical Specification figure 3.4.16-1 RCS gross specific activity greater than ltCi/gm.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (1) is not included in the Farley EAL scheme.Justification:
Plant design difference.
Farley does not have radiation monitors that survey reator coolant system.Difference:
Renumbered NEI 99-01 Rev 6 EAL Threshold (2) to (1) for Farley and revised wording including table with conditions that meet the EAL threshold.
See VI9 RCS Activity Tech Spec.Justification:
Editorial change to clearly indicate Technical Specification limits to plant personnel.
67 SYSTEM MALFUNCTIONS SU4: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) RCS unidentified or pressure boundary leakage greater than (site- (1) RCS unidentified or pressure boundary leakage greater than 10 gpm specific value) for 15 minutes or longer. for 15 minutes or longer.(2) RCS identified leakage greater than (site-specific value) for 15 (2) RCS identified leakage greater than 25 gpm for 15 minutes or minutes or longer. longer.(3) Leakage from the RCS to a location outside containment greater (3) Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer. than 25 gpm for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific value is not used for EAL Threshlds (1) and (2). See V20 RCS Leakage Tech Spec.Justification:
FNP Tech Spec leak rate is less than identified EAL threshold values. Per Developer Notes the identified values are used.68 SYSTEM MALFUNCTIONS SU5: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An automatic (trip [PWR] / scram [BWR]) did not (1) a. An automatic trip did not shutdown the reactor.shutdown the reactor. AND AND b. A subsequent manual action taken at the reactor control b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.consoles is successful in shutting down the reactor. (2) a. A manual trip did not shutdown the reactor.(2) a. A manual trip ([PWR] / scram [BWR]) did not shutdown AND the reactor. b. EITHER of the following:
AND
- A subsequent manual action taken at the reactor control b. EITHER of the following:
consoles is successful in shutting down the reactor.A subsequent automatic trip is successful in shutting 1. A subsequent manual action taken at the reactor control down the reactor.consoles is successful in shutting down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.Difference
/ Deviation
/ Justification None 69 SSTEM MALFUATNGCODTIONS SU6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Loss of ALL of the following onsite communication methods: (I) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) [In plant telephonesI (2) Loss of ALL of the following ORO communications methods:I{
Public address systemI (site-specific list of communications methods) Plant radio systems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods: SENN (Emergency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: ENS on Federal Telecommunications System (FTS)Commercial phones Difference
/ Deviation
/ Justification Difference:
Site specific information provided.70 SUJ7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. Failure of containment to isolate when required by an (1) a. Failure of containment to isolate when required by an actuation signal. actuation signal.AND AND b. ALL required penetrations are not closed within 15 b. ALL required penetrations are not closed within 15 minutes of the actuation signal. minutes of the actuation signal.(2) a. Containment pressure greater than (site-specific pressure).
(2) a. Containment pressure greater than 27 psig.AND AND b. Less than one full train of (site-specific system or b. Less than one CTMT fan cooler and one full train of equipment) is operating per design for 15 minutes or CTMT spray is operating per design for 15 minutes or longer, longer.Difference
/Deviation
/ Justification Difference:
Site specific information provided for EAL threshold (2)a. See V21 Containment Spray Initiation Setpoint.Difference:
NEI 99-01 Rev 6 EAL threshold (2)b. refers to only one train of a site specific system. Farley EAL threshold includes additional components (one CTMT fan cooler) that support CTMT spray to meet this threshold entry condition.
Justification:
Plant design difference.
71 Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Units 1 and 2 License Amendment Request for Changes to Emergency Action Level Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant Enclosure 2 Hatch Deviations and Differences Matrix NEI 99-01 Rev 6 Deviations and Differences Edwin I. Hatch Nuclear Plant -Units I and 2 Table of Contents Generic Differences..............................................................
RGI: Initiating Conditions
.....................................................
2 RG2: Initiating Conditions
.....................................................
3 RS 1: Initiating Conditions
......................................................
4 RS2: Initiating Conditions
......................................................
5 RA1: Initiating Conditions
.....................................................
6 RA2: Initiating Conditions
.....................................................
8 RA3: Initiating Conditions
....................................................
10 RUI: Initiating Conditions
....................................................
11 RU2: Initiating Conditions
....................................................
12 CGl: Initiating Conditions
....................................................
13 CS 1: Initiating Conditions.....................................................
16 CAl: Initiating Conditions
....................................................
18 CA2: Initiating Conditions
....................................................
19 CA3: Initiating Conditions....................................................
20 CA6: Initiating Conditions....................................................
22 CUl: Initiating Conditions....................................................
24 CU2: Initiating Conditions....................................................
25 CU3: Initiating Conditions....................................................
26 CU4: Initiating Conditions....................................................
27 CU5: Initiating Conditions....................................................
28 E-HU1 : Initiating Conditions
...............
.................................
29 BWR Fission Product Barrier Matrix -Initiating Conditions/Thresholds..
31 1. RCS Activity ....................................................
31 2. RPV Water Level................................................
32 3. Not Applicable
..................................................
33 4. Primary Containment Radiation
...............................
35 5. Other Indications................................................
35 6. Emergency Director Judgment.................................
36 HGl: Initiating Conditions....................................................
37 HG7: Initiating Conditions....................................................
38 HS1l: Initiating Conditions
....................................................
39 HS6: Initiating Conditions
....................................................
40 HS7: Initiating Conditions
....................................................
41 HAl: Initiating Conditions....................................................
42 HAS: Initiating Conditions....................................................
43 HA6: Initiating Conditions....................................................
44 HA7: Initiating Conditions....................................................
45 HUl: Initiating Conditions....................................................
46 HU2: Initiating Conditions....................................................
47 HU3: Initiating Conditions....................................................
48 HU4: Initiating Conditions....................................................
49 HU7: Initiating Conditions....................................................
51 SG1: Initiating Conditions.....................................................
52 SG8: Initiating Conditions
....................................................
53 SS1: Initiating Conditions
.....................................................
54 SS5: Initiating Conditions
.....................................................
55 SS8: Initiating Conditions.....................................................
56 SAl: Initiating Conditions
....................................................
57 SA2: Initiating Conditions
....................................................
58 SA5: Initiating Conditions
....................................................
60 SA9: Initiating Conditions
....................................................
61 SUI : Initiating Conditions
....................................................
63 SU2: Initiating Conditions
....................................................
64 SU3: Initiating Conditions
....................................................
65 SU4: Initiating Conditions
....................................................
66 SU5: Initiating Conditions
....................................................
67 SU6: Initiating Conditions
....................................................
68 Uspendi A fo the oradoogiale Sieffluent/radeiaitionslve asaporae Uses R for the radiological effluent/radiation level ICs Emergency Classification ICs are presented in ascending order (NOUE -GE) Emergency Classification ICs are presented in descending order (GE -NOUE)BWROG EPG/SAG Revision 3 guidance not included Incorporated EP FAQ 2015-003 and 20 15-004 guidance in EALs and Basis'Direct' release to the environment is not defined in FPB Matrix Basis lnco orated EP FAQ 2015-006 uidance in FPB Matrix Basis Instrument setpoint readings used as threshold values to determine emergency classifications have been verified by Hatch personnel as being within the range of the instrument and clearly and consistently read within the scale of the instrument.
Site specific information is highlighted in yellow.Grey text items to be provided once instrumentation installed.
Site specific information will be added using 50.54(g) process.ODCM is the controlling Radiation Effluent Document.Appendix A -Deleted PWR Acronyms and Abbreviations.
Added additional acronyms as needed.Appendix B -Incorporated Site Specific definitions as appropriate.
ABNORML RADLEVEL INITADIOLGICALNEFFLUNTS CEL RG1: INITIATING CONDITIONS Difference
/ Deviation l Justification None THRESHOLDS NET199-01 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater 1Di1I-P601 (feeding 1DI I-R631, Rx Bldg 2.6 ~iCi/cc than 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond Vent Wide Range)(site-specific dose receptor point). 2DI l-P601 (feeding 2D1 1-R631, Rx Bldg 2.6 jiCi/cc (3) Field survey results indicate EITHER of the following at or beyond Vent Wide Range)(site-specific dose receptor point): Main Stack Accident Range Monitor:* Closed window dose rates greater than 1,000 mR/hr expected to 1Di1l-P007 (feeding 1D1 1-R631, Main Stack 8.1 X 103 iiCi/cc continue for 60 minutes or longer. Wide Range) _______* Analyses of field survey samples indicate thyroid CDE greater (2) Dose assessment using actual meteorology indicates doses greater than 5,000 mrem for one hour of inhalation, than 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the site boundary.(3) Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 1,000 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 5,000 mrem for one hour of inhalation.
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
2 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RG2: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS Difference
/ Deviation I Justification None 3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RSI: INITIATING CONDITIONS Difference
/ Deviation I Justification None NEI 99-01 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater IDl 1-P601 (feeding 1D1 1-R63 l, Rx Bldg 2.6 x 10-' piCi/cc than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond (site- Vent Wide Range)specific dose receptor point). 2D1 l-P601 (feeding 2D1 1-R63 !, Rx Bldg 2.6 x 10" jiCi/cc (3) Field survey results indicate EITHER of the following at or beyond Vent Wide Range)(site-specific dose receptor point): Main Stack Accident Range Monitor:* Closed window dose rates greater than 100 mR/hr expected to 1D D1l-P007 (feeding 1D D1-R631, Main Stack 8.1 X 102 latCi/cc continue for 60 minutes or longer. Wide Range)________
- Analyses of field survey samples indicate thyroid CDE greater (2) Dose assessment using actual meteorology indicates doses greater than 500 mrem for one hour of inhalation.
than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the site boundary.(3) Field survey results indicate EITHtER of the following at or beyond the site boundary:* Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.
Difference I Deviation I Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
4 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RS2: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRSHOLDS Difference I Deviation
/ Justification None 5 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RAI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-0 1 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater 1D1Il-P601 (feeding 1Di11-R631, Rx Bldg 2.6 X 10"2 than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site- Vent Wide Range)specific dose receptor point). 2DI l-P601 (feeding 2DI 1 -R63 1, Rx Bldg 2.6 x 10"2 (3) Analysis of a liquid effluent sample indicates a concentration or Vent Wide Range)release rate that would result in doses greater than 10 mrem TEDE Main Stack Accident Range Monitor: or 50 mrem thyroid CDE at or beyond (site-specific dose receptor 1DI1l-P007 (feeding ID11-R631, Main 8.1 X 10' ptCi/cc point) for one hour of exposure.
Stack Wide Range) _______(4) Field survey results indicate EITHER of the following at or beyond (2) Dose assessment using actual meteorology indicates doses greater (site-specific dose receptor point): than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the site* Closed window dose rates greater than 10 mR/hr expected to boundary.continue for 60 minutes or longer. (3) Analysis of a liquid effluent sample indicates a concentration or* Analyses of field survey samples indicate thyroid CDE greater release rate that would result in doses greater than 10 mrem TEDE than 50 mrem for one hour of inhalation, or 50 mrem thyroid CDE at or beyond the site boundary for one hour of exposure.(4) Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.
6 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
7 ABNORML ADLEVEL /NIRADIOLGICALNEFFLUNTS C/EL RA2: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (1) Uncovery of irradiated fuel in the REFUELING PATHWAY. (1) Uncovery of irradiated fuel in the REFUELING PATHWAY.(2) Damage to irradiated fuel resulting in a release of radioactivity from (2) Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors:
the fuel as indicated by alarms on ANY Table R1 monitors: (site-specific listing of radiation monitors, and the associated Table RI readings, setpoints and/or alarms) Refuel Floor Area Radiation Monitors (3) Lowering of spent fuel pooi level to (site-specific Level 2 value). Unit I Unit 2 1D21-K601 A -Rx Head Laydown Area 2021-K(601 A -Rx Head Laydown Area 1021-K(601 B -Refueling Floor Stairway 2D21-K(601 M -Spent Fuel/Fuel Pool Areas 1D21-K601 D -Refuel Floor 2D21-K(601 E -Dryer/'Separator Pool 1 D21-K601 E -Drywell Shield Plug 2D21-K(611 K -RPV Refuel Floor 228'1 D21-K601 M -Spent Fuel Pool and New Fuel 2D21-K61 1 L1- RPV Refuel Floor 228'Storage area Refuel Floor Ventilation Monitors Exhas2011 1-K635 A-D -Refuel Floor 0xWSep. Vent.~~~~~~~~~~~Exhaust21-K3A--ReulForW/p Vn 8 ABNORMAL RAD) LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS Difference
/ Deviation
/ Justification Difference:
Hatch EAL Threshold (2) incorporates Table RI to identify applicable site specific monitors.Justification:
Editorial change -Human Factors consideration.
Difference:
Site specific information provided.
See V4 Alarm Response Procedure Reference.
9 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RA3: INITIATING CONDITIONS NEI 99-01 Rev 6 Hatch Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Hatch (1) Dose rate greater than 15 mR/hr in ANY of the following areas: (1) Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room I Control Room area radiation monitor 1D21-K600 B or C* Central Alarm Station Central Alarm Station (by survey)* (other site-specific areas/rooms)(2 AnUPANDeetrslsiraaiolvlshtpoibtr (2) An UNPLANNED event results in radiation levels that prohibit or impede UPAccEss to eny TabesHitplant roomstior areaes:tarhbto impede access to any of the following plant rooms or areas:imeeacstonyTbe1pltrosorre: (site-specific list of plant rooms or areas with entry-related mode TbeH apiaiiyietfe)Building Rooms Applicable Modes apiaiiyietfe)Diesel building All All Unit 1/2 130' All Reactor building Unit 1/2 SE Diagonals (RHR) All Unit 1/2 NE Diagonals (RHR) All Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (1) includes applicable areas as bullets and identifies other site-specific areas/rooms.
Hatch Threshold (1) includes applicable areas in table format. in addition, no additional site-specific areas/rooms, other than those identified in first two bullets of NEI 99-01 Rev 6 EAL Threshold (1) are included.
Site specific information provided.
See V5 Alarm Response Procedure Reference
-Control Room Rad Monitor.Justification:
Editorial change -table format used instead of bullets. Hatch personnel have determined that no additional site-specific areas/rooms are applicable to EAL Threshold (1).Difference:
Site specific information provided.
Hatch EAL Threshold (2) incorporates Table H1 to identify applicable site specific rooms/areas.
10 ABNORMAL HAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RUI: INITIATING CONDITIONS NE1 99-01 Rev 6 Hatch Release of gaseous or liquid radioactivity greater than 2 times the (site- Release of gaseous or liquid radioactivity greater than 2 times the ODCM specific effluent release controlling document) limits for 60 minutes or limits for 60 minutes or longer.longer.Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Hatch (1) Reading on ANY effluent radiation monitor greater than 2 times the (1) Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 ODCM limits for 60 minutes or longer: minutes or longer: Reactor Building Vent Normal Range Monitor: (site-specific monitor list and threshold values corresponding to 2 1D11I-K619 A(B)times the controlling document limits) 2D1 1-K636 A(B)(2) Reading on ANY effluent radiation monitor greater than 2 times the Main Stack Normal Range Monitor: alarm setpoint established by a current radioactivity discharge IDi1l-K600 A(B)permit for 60 minutes or longer. Liquid Radwaste Effluent Line Monitor: 1D 11-K604 (3) Sample analysis for a gaseous or liquid release indicates a2D1K0 concentration or release rate greater than 2 times the (site-specific 2eric WaeI SsemEflet6ie0oitr effluent release controlling document) limits for 60 minutes or 1D11I-K605 longer. 2D 11-K605 (2) Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.(3) Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times ODCM limits for 60 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation.
11 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RU2: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (1) a. UNPLANNED water level drop in the REFUELING (1) a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
PATHWAY as indicated by ANY of the following: (site-specific level indications).
[Personnel report of low water level AND ISFP low level alarm annunciator
-Spent Fuel Storage Pool r b. UNPLANNED rise in area radiation levels as indicated by Low 654-022-1/2 ANY of the following radiation monitors.
AND (site-specific list of area radiation monitors)
- b. UNPLANNED rise in area radiation levels as indicated by ANY of the followin~g radiation monitors.ID21-K601 A -Rx Head Laydown Area 1D21-K601 D -Refuel Floor 1ID2I-1-K601 E -Drywell Shield Plug ID21-K601 M -Spent Fuel Pool and New Fuel Storage area 2D21-K601 A -Rx Head Laydown Area 2D21-K601 M -Spent Fuel/Fuel Pool Areas 2D21-K601 E -Dryer/Separator Pool 2D21-K611 K -RPV Refuel Floor 228'2D21-K611I L -RPV Refuel Floor 228'Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V6 SFP Level Low Annunciator and V2 Rad Monitor Calculation.
12 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CGI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOiLDS NE1 99-01 Rev 6 IHatch 13 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS (I) a. (Reactor vesseliRCS
[PWR] or RPV [BWR]) level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table (see below).(2) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:
- (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication
[PWR]* UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
AND c. ANY indication from the Containment Challenge Table (see below).(1) a. RPV level less than -155" (TAF) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table C1.(2) a. RPV level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:
- UNPLANNED level increase in any of the following of sufficient magnitude to indicate core uncovery Dr weel Floor Drain Sumps Reactor Building Floor Drain Sumps IDrywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps Torus Rad Waste Tanks Torus Room Sumps AND c. ANY indication from the Containment Challenge Table C1.* fSecondary CONTAINMENT INTEGRITY is reestablished*pirt exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Containment Challenge Table* CONTAINMENT CLOSURE not established*
- (Explosive mixture) exists inside containment
- UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [B WR]*If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b, first bullet refers to Site Specific radiation monitor readings greater than a site specific value.Hatch EAL Threshold (2)b does not include site specific radiation monitor readings.Justification:
Plant design -Calculation SMNHI-13-021I determined that the Drywell Wide Range Radiation Monitor would be off scale low and Area Radiation Montiors would be off scale high. Therefore, there are no site specific radiation monitors available for use.14 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threshold (2)b places level before increase and includes the applicable components in table format.Justification:
Human factors consideration
-an increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b, last bullet refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Hatch.Justification:
Hatch does not use any other site-specific indications of core uncovery that those already identified in EAL Threshold (2)b.Difference:
Table designator (CI) assigned to Containment Challenge Table.Justification:
Editorial change to clearly identify tables within the document.Difference:
NEI 99-01 Rev 6 Containment Challenge Table lists items in bullet format. Hatch Containment Challenge Table lists items in table format.Justification:
Editorial change -table format does not affect use of the Containment Challenge Table.Difference:
NEI 99-01 Rev 6 Containment Challenge Table identifies CONTAINMENT CLOSURE not established as a containment challenge.
Hatch identifies Secondary CONTAINMENT INTEGRITY NOT established as a containment challenge.
Justification:
Hatch considers Secondary Containment Integrity not established to be equivalent to Containment Closure not established.
Use of this terminology does not affect the EAL threshold where this condition would be used.Difference:
Site specific information provided.
See V7 RPV Level Indications/Display, V9 Component/System References, Vi10 H2 and 02 Concentration, VI 1 Primary Containment Pressure Refernce (> 56 psig), and V1 2 Secondary Containment Rad Monitors.15 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS CSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (I) a. CONTAINMENT CLOSURE not established.
(1) a. Secondary CONTAINMENT INTEGRITY not established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than -41" (6" below the Level 2 actuation (site-specific level). setpoint).
(2) a. CONTAINMENT CLOSURE established.
(2) a. Secondary CONTAINMENT INTEGRITY established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than -155" (TAF).(site-specific level). (3) a. RPV level cannot be monitored for 30 minutes or longer.(3) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot AND be monitored for 30 minutes or longer. b. Core uncovery is indicated by ANY of the following:
AND 0 UNPLANNED level increase in any of the following b. Core uncovery is indicated by ANY of the following:
of sufficient magnitude to indicate core uncovery:* (Site-specific radiation monitor) reading greater than D Drweel Floor Drain Sumps Reactor Building Floor Drain Sumps (site-specific value) I Drywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps* Erratic source range monitor indication
[PWR] Torus Rad Waste Tanks tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
Difference
/ Deviation
/ Justification 16 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Diferece:
NEI 99-01 Rev 6 EAL Thresholds (1)a and (2)a use the term CONTAINMENT CLOSURE. Hatch EAL Thresholds (l)a and (2)a use the term Secondary CONTAINMENT INTEGRITY.
Jusifiatin:Hatch considers Secondary CONTAINMENT INTEGRITY to be equivalent to CONTAINMENT CLOSURE. Use of this terminology does not affect the threshold for these EALs.Diffeence:
NEI 99-01 Rev 6 EAL Threshold (3)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threhsold (3)b places level before increase and includes the applicable components in table format.Jusifiatin:Human factors consideration
-a level increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Diffeence:
NEI 99-01 Rev 6 EAL Threshold (3)b, first bullet refers to Site Specific radiation monitor readings greater than a site specific value.Hatch EAL Threshold (3)b does not include site specific radiation monitor readings.Jusifiatin:Plant design -Calculation SMNH-05-009 determined that the Drywell Wide Range Radiation Monitor would be off scale low and Area Radiation Montiors would be off scale high. Therefore, there are no site specific radiation monitors available for use.Diffeence:
NEI 99-0 1 Rev 6 EAL Threshold (3)b, last bullet refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Hatch.Jusifiatin:Hatch does not use any other site-specific indications of core uncovery that those already identified in EAL Threshold (3)b.Diffeence:
Site specific information provided.
See V8 Level 2 Actuation Setpoint Information, V7 RPV Level Indications/Display, and V9 Component/System Reference.
17 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CA1: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NET199-01 Rev 6 Hatch (1) Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory as (1) Loss of RPV inventory as indicated by level less than -35" (Level 2 indicated by level less than (site-specific level), actuation setpoint).
(2) a. (Reactor vesseliRCS
[PWR] or RPV [BWR]) level cannot (2) a. RPV level cannot be monitored for 15 minutes or longer be monitored for 15 minutes or longer AND AND b. UNPLANNED level increase in any of the following due to b. UNPLANNED increase in (site-specific sump and/or tank) a loss of RPV inventory:
levels due to a loss of (reactor vesseliRCS
[PWR] or RPV D Drweel Floor Drain Sumps Reactor Building Floor Drain Sumps[BWR]) inventory.
I Drywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps Torus Rad Waste Tanks Difference
/ Deviation
/ Justification Difference:
NE1 99-01 Rev 6 EAL Threshold (2)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threshold (2)b places level before increase and includes the applicable components in table format.Justification:
Human factors consideration
-a level increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Difference:
Site specific information provided.
See V8 Level 2 Actuation Setpoint Information and V9 Component/System Reference.
18 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CA2: INITIATING CONDITIONS NEI 99-01 Rev 6 Hatch Loss of all offsite and all onsite AC power to emergency buses for 15 minutes Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer. or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided for IC.Justification:
Terminology difference
-Hatch refers to emergency buses as essential buses..... :THRESHOLD S S NEI 99-01 Rev 6 Hatch (1) Loss of ALL offsite and ALL onsite AC Power to (site-specific (1) Loss of ALL offsite and ALL onsite AC Power to 4160 VAC emergency buses) for 15 minutes or longer. Essential Buses 1/2E, 1/2F, and 112G for 15 minutes or longer.Table S1 Unit I Unit 2 Start-up Aux XFMR IC Start-up Aux XFMR 2C Start-up Aux XFMR 1D Start-up Aux XFMR 2D Diesel Generator 1 A Diesel Generator 2A Diesel Generator lB Diesel Generator 1B Diesel Generator 1C Diesel Generator 2C Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 4160 VAC Essential Buses Information.
19 FISSION PRODUCT BARRIER ICS/EALS INOne 39 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS~~HGI: INITIATING CONDITIONS
..Difference
/ Deviation
/ Justification None THRSHOLDS NET199-01 Rev 6 Farley (1) a. A HOSTILE ACTION is occurring or has occurred within (1) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific the PROTECTED AREA as reported by the site security security shift supervision), force.AND AND b. EITHER of the following has occurred:
- b. EITHER of the following has occurred: 1. ANY of the following safety functions cannot be I. ANY of the following safety functions cannot be controlled or maintained, controlled or maintained.
- Reactivity control 0 Reactivity control* Core cooling [PWR] / RPV water level [BWR] S Core cooling* RCS heat removal
- RCS heat removal OR OR 2. Damage to spent fuel has occurred or is 2. Damage to spent fuel has occurred or is IMMINENT.
IMMINENT.Difference I Deviation I Justification Difference:
Site specific information provided.40 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HG7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (I) Other conditions exist which in the judgment of the Emergency (I) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or IMLMINENT substantial core degradation or involve actual or IMIMINENT substantial core degradation or melting melting with potential for loss of containment integrity or HOSTILE with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the Protective Action Guideline exposure levels offsite for more than the immediate site area. immediate site area.Difference I Deviation
/ Justification None 41 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) A HOSTILE ACTION is occurring or has occurred within the (1) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift PROTECTED AREA as reported by the site security force.supervision).
Difference I Deviation I Justification Difference:
Site specific information provided.42 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HS6: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An event has resulted in plant control being transferred (1) a. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown from the control room to the remote shutdown panel.panels and local control stations).
AND AND b. Control of ANY of the following key safety functions is not b. Control of ANY of the following key safety functions is not reestablished within 15 minutes reestablished within (site-specific number of minutes).
- Reactivity control* Reactivity control
- Core cooling* Core cooling [PWR] / RPV water level [BWR] 0 RCS heat removal* RCS heat removal Difference
/ Deviation I Justification Difference:
Site specific information provided.43 HAZARDANDOHER:
CONDITIOTNS AFFECTINGPLNTSAEYCSEL H57: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public, effective access to equipment needed for the protection of the public.Any releases are not expected to result in exposure levels which Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the exceed EPA Protective Action Guideline exposure levels beyond the site boundary, site boundary.Difference
/ Deviation
/ Justification None 44 HAZARDANDOHER:
CONDTITIONS AFFECTINGPLNTSAEYCSAL HAl: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. attack threat within 30 minutes.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) A HOSTILE ACTION is occurring or has occurred within the (I1) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific OWNER CONTROLLED AREA as reported by the site security security shift supervision), force.(2) A validated notification from NRC of an aircraft attack threat within (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. 30 minutes of the site.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.45 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA5: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas (1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: into any Table Hi plant rooms or areas: (site-specific list of plant rooms or areas with entry-related Table HI mode applicability identified)
Mode Room Name Room Number AND Electrical Penetration Room 334,333,347/
- b. Entry into the room or area is prohibited or impeded. 2334,2333,2347 3 Hallway Outside Filter Room 3 12,332/1A.2A MCC areas 23 12,2332 Sample Room and Primary CHM labs 323, 324/______2323, 2324 Sample Room and Primary CHM labs 323, 324/4 2323, 2324 RHR Hx Room 128/_______2128 AND b. Entry into the room or area is prohibited or impeded.Difference I Deviation
/ Justification Differences:
Site specific information provided.46 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) An event has resulted in plant control being transferred from the (1) An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control room to the remote shutdown panel.control stations).
Difference
/ Deviation I Justification Difference:
Site specific information provided.47 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HA7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Other conditions exist which, in the judgment of the Emergency (1) Other conditions exist which, in the judgment of the emergency Director, indicate that events are in progress or have occurred which director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline limited to small fractions of the EPA Protective Action Guideline exposure levels, exposure levels.Difference
/ Deviation
/ Justification None 48 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HUI: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) A SECURITY CONDITION that does not involve a HOSTILE (1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).
ACTION as reported by the site security force.(2) Notification of a credible security threat directed at the site. (2) Notification of a credible security threat directed at FNP.(3) A validated notification from the NRC providing information of an (3) A validated notification from the NRC providing information of an aircraft threat, aircraft threat.Difference
/ Deviation
/ Justification Difference:
EAL Threshold (2); replaced 'the site' with FNP.Justification:
Editorial change -clearly identifies that threat is directed against the Farley site.Difference:
Site specific information provided.49 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU2: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Seismic event greater than Operating Basis Earthquake (OBE) as (1) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: indicated by seismic switch activation with the seismic system (site-specific indication that a seismic event met or exceeded OBE computer indicating EITHER of the following:
limits)
- Cumulative Absolute Velocity (CAV) greater than 0.160 g-sec AND Spectral Accelaration greater than 0.200g* Cumulative Absolute Velocity (CAV) greater than 0.160 g-sec AND Spectral Velocity greater than 15.240 cm/sec Difference I Deviation
/ Justification Difference:
Site specific information provided.
See VIS Seismic ARP -FNP-I(2)-ARP-I.12.
50 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU3: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None NET 99-01 Rev 6 Farley (1) A tornado strike within the PROTECTED AREA. (1) A tornado strike within the PROTECTED AREA.(2) Internal room or area flooding of a magnitude sufficient to require (2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode. component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA is impeded (3) Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release), chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to (4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles, prohibit the plant staff from accessing the site via personal vehicles.(5) (Site-specific list of natural or technological hazard events) (5) Sustained hurricane force winds greater than 74 mph forecast to be at the plant site in the next four hours.Difference
/ Deviation
/ Justification Difference:
Site specific information provided for EAL Threshold (5).51 HAZARDANDOHER:
CONDITIOTNS AFFECTINGPLNTSAEYCSAL HU4: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or S Receipt of multiple (more than 1) fire alarms or indications indications
- Field verification of a single fire alarm S Field verification of a single fire alarm AND AND b. The FIRE is located within ANY Table H2 rooms or areas.b. The FIRE is located within ANY of the following plant (2) a. Receipt of a single fire alarm (i.e., no other indications of a rooms or areas: FIRE).(site-specific list of plant rooms or areas) AND (2) a. Receipt of a single fire alarm (i.e., no other indications of a b. The FIRE is located within ANY of the Table H2 rooms or FIRE). areas.AND AND b. The FIRE is located within ANY of the following plant c. The existence of a FIRE is not verified within 30-minutes rooms or areas: of alarm receipt.(site-specific list of plant rooms or areas) (3) A FIRE within the plant PROTECTED AREA or ISFSI AND PROTECTED AREA not extinguished within 60-minutes of the c. The existence of a FIRE is not verified within 30-minutes initial report, alarm or indication.
of alarm receipt. (4) A FIRE within the plant PROTECTED AREA or ISFSI (3) A FIRE within the plant or lSFSI [for plants with an lSFSl outside PROTECTED AREA that requires firefighting support by an offsite the plant Protected Area] PROTECTED AREA not extinguished fire response agency to extinguish.
within 60-minutes of the initial report, alarm or indication.
52 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS (4) A FIRE within the plant or ISFSI [for plants with an ISFSl outside Table 112 the plant Protected Area] PROTECTED AREA that requires Auxiliary Buildin~g firefighting support by an offsite fire response agency to extinguish.
Diesel Generator IService Water Intake Structure (SWIS)Containment Difference
/ Deviation
/ Justification Differences:
EAL Thresholds (l)b and (2)b -added reference to Table 112 instead of listing areas separately for each threshold.
Justification:
Human factors consideration
-applicable rooms are the same for each threshold.
Placing these rooms into one table and referencing the table simplifies the process for identifying applicable rooms.Differences:
EAL Thresholds (3) and (4) -added PROTECTED AREA after plant.Justification:
Clarifies plant areas that are applicable to these EAL thresholds.
Differences:
Added Table 112 with applicable site specific room listing.53 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS HU7: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Other conditions exist which in the judgment of the Emergency (1) Other conditions exist which in the judgment of the emergency Director indicate that events are in progress or have occurred which director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems monitoring are expected unless further degradation of safety systems occurs. occurs.Difference I Deviation
/ Justification None 54 SYSTEM MALFUNCTIONS SGI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses). 4160V ESF busses 1I(2)F ANDj 1 (2)G.AND AND b. EITHER of the following:
- b. EITHER of the following:
- Restoration of at least one AC emergency bus in less
- Restoration of at least one AC emergency bus in less than (site-specific hours) is not likely. than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.* (Site-specific indication of an inability to adequately
- CORE COOLING CSF -RED conditions met remove heat from the core)Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See VI3 ESF Busses Drawing and VI6 CSFST Information.
55 SYSTEM MALFUNCTIONS SG8: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. Loss of ALL offsite and ALL onsite AC power to (site- (1) a. Loss of ALL offsite and ALL onsite AC power to BOTH specific emergency buses) for 15 minutes or longer. 4160V ESF busses l(2)F AND l(2)G for 15 minutes or AND longer.b. Indicated voltage is less than (site-specific bus voltage AND value) on ALL (site-specific Vital DC busses) for 15 b. Indicated voltage is less than 105 VDC on ALL 125 VDC minutes or longer. vital busses for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See VI3 ESF Busses Drawing and V14 DC Voltage Reference.
56 SYSTEM MALFUNCTIONS SSI: INITIATING CONDITIONS None THRESHOLDS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.57 SYSINTEMIALFUNGCODTIONS SSS: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley Inability to shut down the reactor causing a challenge to (core cooling [PWR] Inability to shutdown the reactor causing a challenge to core cooling or RCS I RPV water level [BWR]) or RCS heat removal, heat removal.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley a. An automatic or manual (trip [PWR] / scram [BWR]) did +(I)not shutdown the reactor.AND b. All manual actions to shut down the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* (Site-specific indication of an inability to adequately remove heat from the core)* (Site-specific indication of an inability to adequately remove heat from the RCS)(1)a. An automatic or manual trip did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.
AND c. EITHER of the following conditions exist:* Core Cooling CSF -RED conditions met* Heat Sink CSF -RED conditions met Difference:/
Deitioe Jsteificifrainpoie.SeV6CFTIfration.
Difference:
Site specific information provided.
See V16 CSFST In formation.
58 SYSTEM MALFUNCTIONS SS8: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Indicated voltage is less than (site-specific bus voltage value) on (1) Indicated voltage is less than 105 VDC on ALL 125 VDC vital ALL (site-specific Vital DC busses) for 15 minutes or longer, busses for 15 minutes or longer.Difference I Deviation
/ Justification Difference:
Site specific information provided.
See V14 DC Voltage Reference.
59 SSAINTEMIALFUNGCODTIONS SAl: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Difference I Deviation
/ Justification THRESHOLDS NE1 99-01 Rev 6 Farley (1) a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 1 5 minutes or longer.AND b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.(1) a. AC power capability to BOTH 4160V ESF busses I(2)F AND I(2)G is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.Table SI Unit 1 Unit 2 Start-up Aux XFMR 1 A Start-up Aux XFMR 2A Start-up Aux XFMR lB Start-up Aux XFMR 2B Diesel Generator 1I-2A Diesel Generator 1 -2A Diesel Generator 1 B Diesel Generator 2B Diesel Generator 1 C Diesel Generator IC Diesel Generator 2C Diesel Generator 2C Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.60 SSA2NTEMIALFUNGCODTIONS 5A2: INITIATING CONDITIONS Difference I Deviation I Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An UNPLANNED event results in the inability to monitor (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the one or more of the following parameters from within the Control Room for 15 minutes or longer. Control Room for 15 minutes or longer.[ BWR parameter list] [PWR parameter list] Reactor Power Reactor Power Reactor Power RCS Level RCS Pressure RPV Water Level RCS Level In-Core/Core Exit Temperature RPV Pressure RCS Pressure Wide RangRe Level in at least one steam [generator Primary Containment In-Core/Core Exit Steam Generator Auxiliary or Emerg:ency Feed Water Flow Pressure Temperature Suppression Pool Level Levels in at least (site- AND specific number) steam generators
- b. ANY of the following transient events in progress.Suppression Pool Steam Generator Auxiliary 0 Automatic or manual runback greater than 25%Temperature or Emergency Feed Water thermal reactor power Flow 0 Electrical load rejection greater than 25% full electrical load AND S Reactor trip 0 ECCS actuation b. ANY of the following transient events in progress.61 SYSTEM MALFUNCTIONS
- Automatic or manual runback greater than 25%thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor scram [BWR] / trip [PWR]* EGGS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Farley specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
Difference:
NEI 99-01 Rev 6 includes (SI) after ECCS. Farley does not include (SI) after ECCS.Justification:
Site preference, does not detract or affect EAL determination.
62 SYSTEM MALFUNCTIONS SA5: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Automatic or manual (trip [PWRJ / scram [BWR]) fails to shut down the Automatic or manual trip fails to shutdown the reactor, and subsequent reactor, and subsequent manual actions taken at the reactor control consoles manual actions taken at the reactor control consoles are not successful in are not successful in shutting down the reactor, shutting down the reactor.Difference I Deviation
/ Justification None THRESHOLDS NE199-01 Rev 6 Farley (1) a. An automatic or manual (trip [PWR] / scram [BWR]) did (1) a. An automatic or manual trip did not shutdown the reactor.not shutdown the reactor.AND AND b. Manual actions taken at the reactor control consoles are not b. Manual actions taken at the reactor control consoles are not successful in shutting down the reactor.successful in shutting down the reactor.Difference I Deviation I Justification None 63 SYSTEM MALFUNCTIONS SA9: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. The occurrence of ANY of the following hazardous events: (1) a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake) 0 Seismic event (earthquake)
- Internal or external flooding event 0 Internal or external flooding event* High winds or tornado strike 0 High winds or tornado strike* FIRE S FIRE* EXPLOSION 0 EXPLOSION* (site-specific hazards) 0 Other events with similar hazard characteristics as* Other events with similar hazard characteristics as determined by the Shift Manager determined by the Shift Manager AND AND b. EITHER of the following:
- b. EITHER of the following:
- Event damage has caused indications of degraded I. Event damage has caused indications of degraded performance in at least one train of a SAFETY performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.SYSTEM needed for the current operating mode.
- The event has caused VISIBLE DAMAGE to a OR SAFETY SYSTEM component or structure needed for 2. The event has caused VISIBLE DAMAGE to a the current operating mode.SAFETY SYSTEM component or structure needed for the current operating mode.Difference
/ Deviation
/ Justification Difference:
No additional site specific hazards identified.
Justification:
Site personnel have determined that no additional site specific hazards are applicable to this EAL threshold.
64 SYSTEM MALFUNCTIONS SUI: INITIATING CONDITIONS NEI 99-01 Rev 6 Farley Loss of all offsite AC power capability to emergency buses for 15 minutes or Loss of all offsite AC power capability to emergency buses for 15 minutes or longer, longer.Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Farley (1) Loss of ALL offsite AC power capability to (site-specific (1) Loss of ALL offsite AC power capability to BOTHj 4160V ESF emergency buses) for 15 minutes or longer, busses l(2)F AN l(2)G for 15 minutes or longer.Table $2 IUniti 1 Unit 2 Start-up Aux XFMR 1 A Start-up Aux XFMR 2A Start-up Aux XFMR lB Start-up Aux XFMR 2B Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 ESF Busses Drawing.65 SYSTEM MALFUNCTIONS SU2: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley UNPLANNED loss of Control Room indications for 15 minutes or longer. UNPLANNED loss of Control Room indications for 15 minutes or longer.Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley 4 (1) a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.(1) a.[BWR parameter list] [P WR parameter list]Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment In-Core/Core Exit Pressure Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Steam Generator Temperature Auxiliary or Emergency__________________Feed Water Flow An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Contr'ol Room for 15 minutes or longer.Reactor Power RCS Level RCS Pressure In-Core/Core Exit Temperature Wide Range Level in at least one steam generator Steam Generator Auxiliary or Emergency Feed Water Flow Difference
/ Deviation
/ Justification Difference:
NE! 99-01 Rev 6 does not specify steam generator level transmitter (wide or narrow range). Farley specifies use of Wide Range Level indication.
Justification:
Site determination that Wide Range Level indication is applicable to this EAL threshold.
66 SSU3NTEMIALFUNGCODTIONS 5133: INITIATING CONDITIONS NE1 99-01 Rev 6 Farley Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits.Difference
/ Deviation I Justification None THRESHOLDS NE1 99-01 Rev 6 Farley 1-(1) (Site-specific radiation monitor) reading greater than (site-specific value).(2) Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
(1) RCS coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits as indicated by ANY of the following:
Dose Equivalent 1-131 greater than 0.5 [iCi/gm for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Dose Equivalent I-131 greater than Technical Specification figure 3.4.16-1.IF less than 20% power, THEN use the Dose Equivalent I-131 20% power limit on Technical Specification figure 3.4.16-1 RCS gross specific activity greater than ltCi/gm.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (1) is not included in the Farley EAL scheme.Justification:
Plant design difference.
Farley does not have radiation monitors that survey reator coolant system.Difference:
Renumbered NEI 99-01 Rev 6 EAL Threshold (2) to (1) for Farley and revised wording including table with conditions that meet the EAL threshold.
See VI9 RCS Activity Tech Spec.Justification:
Editorial change to clearly indicate Technical Specification limits to plant personnel.
67 SYSTEM MALFUNCTIONS SU4: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) RCS unidentified or pressure boundary leakage greater than (site- (1) RCS unidentified or pressure boundary leakage greater than 10 gpm specific value) for 15 minutes or longer. for 15 minutes or longer.(2) RCS identified leakage greater than (site-specific value) for 15 (2) RCS identified leakage greater than 25 gpm for 15 minutes or minutes or longer. longer.(3) Leakage from the RCS to a location outside containment greater (3) Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer. than 25 gpm for 15 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific value is not used for EAL Threshlds (1) and (2). See V20 RCS Leakage Tech Spec.Justification:
FNP Tech Spec leak rate is less than identified EAL threshold values. Per Developer Notes the identified values are used.68 SYSTEM MALFUNCTIONS SU5: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. An automatic (trip [PWR] / scram [BWR]) did not (1) a. An automatic trip did not shutdown the reactor.shutdown the reactor. AND AND b. A subsequent manual action taken at the reactor control b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.consoles is successful in shutting down the reactor. (2) a. A manual trip did not shutdown the reactor.(2) a. A manual trip ([PWR] / scram [BWR]) did not shutdown AND the reactor. b. EITHER of the following:
AND
- A subsequent manual action taken at the reactor control b. EITHER of the following:
consoles is successful in shutting down the reactor.A subsequent automatic trip is successful in shutting 1. A subsequent manual action taken at the reactor control down the reactor.consoles is successful in shutting down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.Difference
/ Deviation
/ Justification None 69 SSTEM MALFUATNGCODTIONS SU6: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) Loss of ALL of the following onsite communication methods: (I) Loss of ALL of the following onsite communication methods: (site-specific list of communications methods) [In plant telephonesI (2) Loss of ALL of the following ORO communications methods:I{
Public address systemI (site-specific list of communications methods) Plant radio systems (3) Loss of ALL of the following NRC communications methods: (site-specific list of communications methods) (2) Loss of ALL of the following ORO communications methods: SENN (Emergency Notification Network)Commercial phones (3) Loss of ALL of the following NRC communications methods: ENS on Federal Telecommunications System (FTS)Commercial phones Difference
/ Deviation
/ Justification Difference:
Site specific information provided.70 SUJ7: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Farley (1) a. Failure of containment to isolate when required by an (1) a. Failure of containment to isolate when required by an actuation signal. actuation signal.AND AND b. ALL required penetrations are not closed within 15 b. ALL required penetrations are not closed within 15 minutes of the actuation signal. minutes of the actuation signal.(2) a. Containment pressure greater than (site-specific pressure).
(2) a. Containment pressure greater than 27 psig.AND AND b. Less than one full train of (site-specific system or b. Less than one CTMT fan cooler and one full train of equipment) is operating per design for 15 minutes or CTMT spray is operating per design for 15 minutes or longer, longer.Difference
/Deviation
/ Justification Difference:
Site specific information provided for EAL threshold (2)a. See V21 Containment Spray Initiation Setpoint.Difference:
NEI 99-01 Rev 6 EAL threshold (2)b. refers to only one train of a site specific system. Farley EAL threshold includes additional components (one CTMT fan cooler) that support CTMT spray to meet this threshold entry condition.
Justification:
Plant design difference.
71 Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Units 1 and 2 License Amendment Request for Changes to Emergency Action Level Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant Enclosure 2 Hatch Deviations and Differences Matrix NEI 99-01 Rev 6 Deviations and Differences Edwin I. Hatch Nuclear Plant -Units I and 2 Table of Contents Generic Differences..............................................................
RGI: Initiating Conditions
.....................................................
2 RG2: Initiating Conditions
.....................................................
3 RS 1: Initiating Conditions
......................................................
4 RS2: Initiating Conditions
......................................................
5 RA1: Initiating Conditions
.....................................................
6 RA2: Initiating Conditions
.....................................................
8 RA3: Initiating Conditions
....................................................
10 RUI: Initiating Conditions
....................................................
11 RU2: Initiating Conditions
....................................................
12 CGl: Initiating Conditions
....................................................
13 CS 1: Initiating Conditions.....................................................
16 CAl: Initiating Conditions
....................................................
18 CA2: Initiating Conditions
....................................................
19 CA3: Initiating Conditions....................................................
20 CA6: Initiating Conditions....................................................
22 CUl: Initiating Conditions....................................................
24 CU2: Initiating Conditions....................................................
25 CU3: Initiating Conditions....................................................
26 CU4: Initiating Conditions....................................................
27 CU5: Initiating Conditions....................................................
28 E-HU1 : Initiating Conditions
...............
.................................
29 BWR Fission Product Barrier Matrix -Initiating Conditions/Thresholds..
31 1. RCS Activity ....................................................
31 2. RPV Water Level................................................
32 3. Not Applicable
..................................................
33 4. Primary Containment Radiation
...............................
35 5. Other Indications................................................
35 6. Emergency Director Judgment.................................
36 HGl: Initiating Conditions....................................................
37 HG7: Initiating Conditions....................................................
38 HS1l: Initiating Conditions
....................................................
39 HS6: Initiating Conditions
....................................................
40 HS7: Initiating Conditions
....................................................
41 HAl: Initiating Conditions....................................................
42 HAS: Initiating Conditions....................................................
43 HA6: Initiating Conditions....................................................
44 HA7: Initiating Conditions....................................................
45 HUl: Initiating Conditions....................................................
46 HU2: Initiating Conditions....................................................
47 HU3: Initiating Conditions....................................................
48 HU4: Initiating Conditions....................................................
49 HU7: Initiating Conditions....................................................
51 SG1: Initiating Conditions.....................................................
52 SG8: Initiating Conditions
....................................................
53 SS1: Initiating Conditions
.....................................................
54 SS5: Initiating Conditions
.....................................................
55 SS8: Initiating Conditions.....................................................
56 SAl: Initiating Conditions
....................................................
57 SA2: Initiating Conditions
....................................................
58 SA5: Initiating Conditions
....................................................
60 SA9: Initiating Conditions
....................................................
61 SUI : Initiating Conditions
....................................................
63 SU2: Initiating Conditions
....................................................
64 SU3: Initiating Conditions
....................................................
65 SU4: Initiating Conditions
....................................................
66 SU5: Initiating Conditions
....................................................
67 SU6: Initiating Conditions
....................................................
68 Uspendi A fo the oradoogiale Sieffluent/radeiaitionslve asaporae Uses R for the radiological effluent/radiation level ICs Emergency Classification ICs are presented in ascending order (NOUE -GE) Emergency Classification ICs are presented in descending order (GE -NOUE)BWROG EPG/SAG Revision 3 guidance not included Incorporated EP FAQ 2015-003 and 20 15-004 guidance in EALs and Basis'Direct' release to the environment is not defined in FPB Matrix Basis lnco orated EP FAQ 2015-006 uidance in FPB Matrix Basis Instrument setpoint readings used as threshold values to determine emergency classifications have been verified by Hatch personnel as being within the range of the instrument and clearly and consistently read within the scale of the instrument.
Site specific information is highlighted in yellow.Grey text items to be provided once instrumentation installed.
Site specific information will be added using 50.54(g) process.ODCM is the controlling Radiation Effluent Document.Appendix A -Deleted PWR Acronyms and Abbreviations.
Added additional acronyms as needed.Appendix B -Incorporated Site Specific definitions as appropriate.
ABNORML RADLEVEL INITADIOLGICALNEFFLUNTS CEL RG1: INITIATING CONDITIONS Difference
/ Deviation l Justification None THRESHOLDS NET199-01 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater 1Di1I-P601 (feeding 1DI I-R631, Rx Bldg 2.6 ~iCi/cc than 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond Vent Wide Range)(site-specific dose receptor point). 2DI l-P601 (feeding 2D1 1-R631, Rx Bldg 2.6 jiCi/cc (3) Field survey results indicate EITHER of the following at or beyond Vent Wide Range)(site-specific dose receptor point): Main Stack Accident Range Monitor:* Closed window dose rates greater than 1,000 mR/hr expected to 1Di1l-P007 (feeding 1D1 1-R631, Main Stack 8.1 X 103 iiCi/cc continue for 60 minutes or longer. Wide Range) _______* Analyses of field survey samples indicate thyroid CDE greater (2) Dose assessment using actual meteorology indicates doses greater than 5,000 mrem for one hour of inhalation, than 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the site boundary.(3) Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 1,000 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 5,000 mrem for one hour of inhalation.
Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
2 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RG2: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS Difference
/ Deviation I Justification None 3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RSI: INITIATING CONDITIONS Difference
/ Deviation I Justification None NEI 99-01 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater IDl 1-P601 (feeding 1D1 1-R63 l, Rx Bldg 2.6 x 10-' piCi/cc than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond (site- Vent Wide Range)specific dose receptor point). 2D1 l-P601 (feeding 2D1 1-R63 !, Rx Bldg 2.6 x 10" jiCi/cc (3) Field survey results indicate EITHER of the following at or beyond Vent Wide Range)(site-specific dose receptor point): Main Stack Accident Range Monitor:* Closed window dose rates greater than 100 mR/hr expected to 1D D1l-P007 (feeding 1D D1-R631, Main Stack 8.1 X 102 latCi/cc continue for 60 minutes or longer. Wide Range)________
- Analyses of field survey samples indicate thyroid CDE greater (2) Dose assessment using actual meteorology indicates doses greater than 500 mrem for one hour of inhalation.
than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the site boundary.(3) Field survey results indicate EITHtER of the following at or beyond the site boundary:* Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.
Difference I Deviation I Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
4 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RS2: INITIATING CONDITIONS Difference
/ Deviation I Justification None THRSHOLDS Difference I Deviation
/ Justification None 5 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RAI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-0 1 Rev 6 Hatch (1) Reading on ANY of the following radiation monitors greater than (1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values) Reactor Building Vent Accident Range Monitor: (2) Dose assessment using actual meteorology indicates doses greater 1D1Il-P601 (feeding 1Di11-R631, Rx Bldg 2.6 X 10"2 than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site- Vent Wide Range)specific dose receptor point). 2DI l-P601 (feeding 2DI 1 -R63 1, Rx Bldg 2.6 x 10"2 (3) Analysis of a liquid effluent sample indicates a concentration or Vent Wide Range)release rate that would result in doses greater than 10 mrem TEDE Main Stack Accident Range Monitor: or 50 mrem thyroid CDE at or beyond (site-specific dose receptor 1DI1l-P007 (feeding ID11-R631, Main 8.1 X 10' ptCi/cc point) for one hour of exposure.
Stack Wide Range) _______(4) Field survey results indicate EITHER of the following at or beyond (2) Dose assessment using actual meteorology indicates doses greater (site-specific dose receptor point): than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the site* Closed window dose rates greater than 10 mR/hr expected to boundary.continue for 60 minutes or longer. (3) Analysis of a liquid effluent sample indicates a concentration or* Analyses of field survey samples indicate thyroid CDE greater release rate that would result in doses greater than 10 mrem TEDE than 50 mrem for one hour of inhalation, or 50 mrem thyroid CDE at or beyond the site boundary for one hour of exposure.(4) Field survey results indicate EITHER of the following at or beyond the site boundary:* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.* Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.
6 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation and V30ODCM Site Boundary Reference.
7 ABNORML ADLEVEL /NIRADIOLGICALNEFFLUNTS C/EL RA2: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (1) Uncovery of irradiated fuel in the REFUELING PATHWAY. (1) Uncovery of irradiated fuel in the REFUELING PATHWAY.(2) Damage to irradiated fuel resulting in a release of radioactivity from (2) Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors:
the fuel as indicated by alarms on ANY Table R1 monitors: (site-specific listing of radiation monitors, and the associated Table RI readings, setpoints and/or alarms) Refuel Floor Area Radiation Monitors (3) Lowering of spent fuel pooi level to (site-specific Level 2 value). Unit I Unit 2 1D21-K601 A -Rx Head Laydown Area 2021-K(601 A -Rx Head Laydown Area 1021-K(601 B -Refueling Floor Stairway 2D21-K(601 M -Spent Fuel/Fuel Pool Areas 1D21-K601 D -Refuel Floor 2D21-K(601 E -Dryer/'Separator Pool 1 D21-K601 E -Drywell Shield Plug 2D21-K(611 K -RPV Refuel Floor 228'1 D21-K601 M -Spent Fuel Pool and New Fuel 2D21-K61 1 L1- RPV Refuel Floor 228'Storage area Refuel Floor Ventilation Monitors Exhas2011 1-K635 A-D -Refuel Floor 0xWSep. Vent.~~~~~~~~~~~Exhaust21-K3A--ReulForW/p Vn 8 ABNORMAL RAD) LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS Difference
/ Deviation
/ Justification Difference:
Hatch EAL Threshold (2) incorporates Table RI to identify applicable site specific monitors.Justification:
Editorial change -Human Factors consideration.
Difference:
Site specific information provided.
See V4 Alarm Response Procedure Reference.
9 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RA3: INITIATING CONDITIONS NEI 99-01 Rev 6 Hatch Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Hatch (1) Dose rate greater than 15 mR/hr in ANY of the following areas: (1) Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room I Control Room area radiation monitor 1D21-K600 B or C* Central Alarm Station Central Alarm Station (by survey)* (other site-specific areas/rooms)(2 AnUPANDeetrslsiraaiolvlshtpoibtr (2) An UNPLANNED event results in radiation levels that prohibit or impede UPAccEss to eny TabesHitplant roomstior areaes:tarhbto impede access to any of the following plant rooms or areas:imeeacstonyTbe1pltrosorre: (site-specific list of plant rooms or areas with entry-related mode TbeH apiaiiyietfe)Building Rooms Applicable Modes apiaiiyietfe)Diesel building All All Unit 1/2 130' All Reactor building Unit 1/2 SE Diagonals (RHR) All Unit 1/2 NE Diagonals (RHR) All Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (1) includes applicable areas as bullets and identifies other site-specific areas/rooms.
Hatch Threshold (1) includes applicable areas in table format. in addition, no additional site-specific areas/rooms, other than those identified in first two bullets of NEI 99-01 Rev 6 EAL Threshold (1) are included.
Site specific information provided.
See V5 Alarm Response Procedure Reference
-Control Room Rad Monitor.Justification:
Editorial change -table format used instead of bullets. Hatch personnel have determined that no additional site-specific areas/rooms are applicable to EAL Threshold (1).Difference:
Site specific information provided.
Hatch EAL Threshold (2) incorporates Table H1 to identify applicable site specific rooms/areas.
10 ABNORMAL HAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RUI: INITIATING CONDITIONS NE1 99-01 Rev 6 Hatch Release of gaseous or liquid radioactivity greater than 2 times the (site- Release of gaseous or liquid radioactivity greater than 2 times the ODCM specific effluent release controlling document) limits for 60 minutes or limits for 60 minutes or longer.longer.Difference
/ Deviation
/ Justification None THRESHOLDS NE1 99-01 Rev 6 Hatch (1) Reading on ANY effluent radiation monitor greater than 2 times the (1) Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 ODCM limits for 60 minutes or longer: minutes or longer: Reactor Building Vent Normal Range Monitor: (site-specific monitor list and threshold values corresponding to 2 1D11I-K619 A(B)times the controlling document limits) 2D1 1-K636 A(B)(2) Reading on ANY effluent radiation monitor greater than 2 times the Main Stack Normal Range Monitor: alarm setpoint established by a current radioactivity discharge IDi1l-K600 A(B)permit for 60 minutes or longer. Liquid Radwaste Effluent Line Monitor: 1D 11-K604 (3) Sample analysis for a gaseous or liquid release indicates a2D1K0 concentration or release rate greater than 2 times the (site-specific 2eric WaeI SsemEflet6ie0oitr effluent release controlling document) limits for 60 minutes or 1D11I-K605 longer. 2D 11-K605 (2) Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.(3) Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times ODCM limits for 60 minutes or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V2 Rad Monitor Calculation.
11 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS RU2: INITIATING CONDITIONS Difference I Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (1) a. UNPLANNED water level drop in the REFUELING (1) a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
PATHWAY as indicated by ANY of the following: (site-specific level indications).
[Personnel report of low water level AND ISFP low level alarm annunciator
-Spent Fuel Storage Pool r b. UNPLANNED rise in area radiation levels as indicated by Low 654-022-1/2 ANY of the following radiation monitors.
AND (site-specific list of area radiation monitors)
- b. UNPLANNED rise in area radiation levels as indicated by ANY of the followin~g radiation monitors.ID21-K601 A -Rx Head Laydown Area 1D21-K601 D -Refuel Floor 1ID2I-1-K601 E -Drywell Shield Plug ID21-K601 M -Spent Fuel Pool and New Fuel Storage area 2D21-K601 A -Rx Head Laydown Area 2D21-K601 M -Spent Fuel/Fuel Pool Areas 2D21-K601 E -Dryer/Separator Pool 2D21-K611 K -RPV Refuel Floor 228'2D21-K611I L -RPV Refuel Floor 228'Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V6 SFP Level Low Annunciator and V2 Rad Monitor Calculation.
12 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CGI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None~THRESHOiLDS NE1 99-01 Rev 6 IHatch 13 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS (I) a. (Reactor vesseliRCS
[PWR] or RPV [BWR]) level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table (see below).(2) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:
- (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication
[PWR]* UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
AND c. ANY indication from the Containment Challenge Table (see below).(1) a. RPV level less than -155" (TAF) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table C1.(2) a. RPV level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:
- UNPLANNED level increase in any of the following of sufficient magnitude to indicate core uncovery Dr weel Floor Drain Sumps Reactor Building Floor Drain Sumps IDrywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps Torus Rad Waste Tanks Torus Room Sumps AND c. ANY indication from the Containment Challenge Table C1.* fSecondary CONTAINMENT INTEGRITY is reestablished*pirt exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Containment Challenge Table* CONTAINMENT CLOSURE not established*
- (Explosive mixture) exists inside containment
- UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [B WR]*If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Difference
/ Deviation
/ Justification Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b, first bullet refers to Site Specific radiation monitor readings greater than a site specific value.Hatch EAL Threshold (2)b does not include site specific radiation monitor readings.Justification:
Plant design -Calculation SMNHI-13-021I determined that the Drywell Wide Range Radiation Monitor would be off scale low and Area Radiation Montiors would be off scale high. Therefore, there are no site specific radiation monitors available for use.14 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threshold (2)b places level before increase and includes the applicable components in table format.Justification:
Human factors consideration
-an increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Difference:
NEI 99-01 Rev 6 EAL Threshold (2)b, last bullet refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Hatch.Justification:
Hatch does not use any other site-specific indications of core uncovery that those already identified in EAL Threshold (2)b.Difference:
Table designator (CI) assigned to Containment Challenge Table.Justification:
Editorial change to clearly identify tables within the document.Difference:
NEI 99-01 Rev 6 Containment Challenge Table lists items in bullet format. Hatch Containment Challenge Table lists items in table format.Justification:
Editorial change -table format does not affect use of the Containment Challenge Table.Difference:
NEI 99-01 Rev 6 Containment Challenge Table identifies CONTAINMENT CLOSURE not established as a containment challenge.
Hatch identifies Secondary CONTAINMENT INTEGRITY NOT established as a containment challenge.
Justification:
Hatch considers Secondary Containment Integrity not established to be equivalent to Containment Closure not established.
Use of this terminology does not affect the EAL threshold where this condition would be used.Difference:
Site specific information provided.
See V7 RPV Level Indications/Display, V9 Component/System References, Vi10 H2 and 02 Concentration, VI 1 Primary Containment Pressure Refernce (> 56 psig), and V1 2 Secondary Containment Rad Monitors.15 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS CSI: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NEI 99-01 Rev 6 Hatch (I) a. CONTAINMENT CLOSURE not established.
(1) a. Secondary CONTAINMENT INTEGRITY not established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than -41" (6" below the Level 2 actuation (site-specific level). setpoint).
(2) a. CONTAINMENT CLOSURE established.
(2) a. Secondary CONTAINMENT INTEGRITY established.
AND AND b. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level less than b. RPV level less than -155" (TAF).(site-specific level). (3) a. RPV level cannot be monitored for 30 minutes or longer.(3) a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) level cannot AND be monitored for 30 minutes or longer. b. Core uncovery is indicated by ANY of the following:
AND 0 UNPLANNED level increase in any of the following b. Core uncovery is indicated by ANY of the following:
of sufficient magnitude to indicate core uncovery:* (Site-specific radiation monitor) reading greater than D Drweel Floor Drain Sumps Reactor Building Floor Drain Sumps (site-specific value) I Drywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps* Erratic source range monitor indication
[PWR] Torus Rad Waste Tanks tank) levels of sufficient magnitude to indicate core uncovery* (Other site-specific indications)
Difference
/ Deviation
/ Justification 16 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Justification:
Difference:
Diferece:
NEI 99-01 Rev 6 EAL Thresholds (1)a and (2)a use the term CONTAINMENT CLOSURE. Hatch EAL Thresholds (l)a and (2)a use the term Secondary CONTAINMENT INTEGRITY.
Jusifiatin:Hatch considers Secondary CONTAINMENT INTEGRITY to be equivalent to CONTAINMENT CLOSURE. Use of this terminology does not affect the threshold for these EALs.Diffeence:
NEI 99-01 Rev 6 EAL Threshold (3)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threhsold (3)b places level before increase and includes the applicable components in table format.Jusifiatin:Human factors consideration
-a level increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Diffeence:
NEI 99-01 Rev 6 EAL Threshold (3)b, first bullet refers to Site Specific radiation monitor readings greater than a site specific value.Hatch EAL Threshold (3)b does not include site specific radiation monitor readings.Jusifiatin:Plant design -Calculation SMNH-05-009 determined that the Drywell Wide Range Radiation Monitor would be off scale low and Area Radiation Montiors would be off scale high. Therefore, there are no site specific radiation monitors available for use.Diffeence:
NEI 99-0 1 Rev 6 EAL Threshold (3)b, last bullet refers to Other site-specific indications of core uncovery.
No Other site-specific indications are used at Hatch.Jusifiatin:Hatch does not use any other site-specific indications of core uncovery that those already identified in EAL Threshold (3)b.Diffeence:
Site specific information provided.
See V8 Level 2 Actuation Setpoint Information, V7 RPV Level Indications/Display, and V9 Component/System Reference.
17 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CA1: INITIATING CONDITIONS Difference
/ Deviation
/ Justification None THRESHOLDS NET199-01 Rev 6 Hatch (1) Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory as (1) Loss of RPV inventory as indicated by level less than -35" (Level 2 indicated by level less than (site-specific level), actuation setpoint).
(2) a. (Reactor vesseliRCS
[PWR] or RPV [BWR]) level cannot (2) a. RPV level cannot be monitored for 15 minutes or longer be monitored for 15 minutes or longer AND AND b. UNPLANNED level increase in any of the following due to b. UNPLANNED increase in (site-specific sump and/or tank) a loss of RPV inventory:
levels due to a loss of (reactor vesseliRCS
[PWR] or RPV D Drweel Floor Drain Sumps Reactor Building Floor Drain Sumps[BWR]) inventory.
I Drywell Equipment Drain Sumps ITurbine Building Floor Drain Sumps Torus Rad Waste Tanks Difference
/ Deviation
/ Justification Difference:
NE1 99-01 Rev 6 EAL Threshold (2)b uses levels as a clarifier after the listed site specific components.
Hatch EAL Threshold (2)b places level before increase and includes the applicable components in table format.Justification:
Human factors consideration
-a level increase in any of the identified components continues to satisfy the EAL threshold.
Listing the applicable components in table format facilitates identification (rather than being included in a list).Difference:
Site specific information provided.
See V8 Level 2 Actuation Setpoint Information and V9 Component/System Reference.
18 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS~CA2: INITIATING CONDITIONS NEI 99-01 Rev 6 Hatch Loss of all offsite and all onsite AC power to emergency buses for 15 minutes Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer. or longer.Difference
/ Deviation
/ Justification Difference:
Site specific information provided for IC.Justification:
Terminology difference
-Hatch refers to emergency buses as essential buses..... :THRESHOLD S S NEI 99-01 Rev 6 Hatch (1) Loss of ALL offsite and ALL onsite AC Power to (site-specific (1) Loss of ALL offsite and ALL onsite AC Power to 4160 VAC emergency buses) for 15 minutes or longer. Essential Buses 1/2E, 1/2F, and 112G for 15 minutes or longer.Table S1 Unit I Unit 2 Start-up Aux XFMR IC Start-up Aux XFMR 2C Start-up Aux XFMR 1D Start-up Aux XFMR 2D Diesel Generator 1 A Diesel Generator 2A Diesel Generator lB Diesel Generator 1B Diesel Generator 1C Diesel Generator 2C Difference
/ Deviation
/ Justification Difference:
Site specific information provided.
See V13 4160 VAC Essential Buses Information.
19