ML15191A161

Comanche Peak Nuclear Power Plant - License Amendment Request 15-003 for Revision to Units 1 & 2 Emergency Action Levels

ML15191A161
Person / Time
Site:	Comanche Peak
Issue date:	06/30/2015
From:	Flores R G Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15191A175	List: CP-201500668, Emergency Action Level Technical Bases (Redline and Strikeout Version) ML15191A161 ML15191A163
References
CP-201500668, LAR 15-003, TXX-15101
Download: ML15191A161 (125)

Text

Rafael Flores Luminant PowerSenior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56Rafael.Flores@Luminant.com Glen Rose, TX 76043Luminant 2548975590 C 817 559 0403F 254 897 6652CP-201500668 Ref. # 10CFR50.90 TXX-15101 10CFR50 Appendix EJune 30, 2015U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANTDOCKET NOS. 50-445 AND 50-446LICENSE AMENDMENT REQUEST 15-003 FOR REVISION TOUNIT 1 AND UNIT 2 EMERGENCY ACTION LEVELS

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planning andPreparedness for Production and Utilization Facilities,"

Section IV.B, Luminant Generation CompanyLLC (Luminant Power) is submitting a request for an amendment to the Emergency Plan for ComanchePeak Nuclear Power Plant (CPNPP) Units 1 and 2.The proposed amendment involves upgrading selected CPNPP Emergency Action Levels (EALs) basedon NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors,"

using theguidance of NRC Regulatory Issue Summary 2003-18, Supplement 2,"Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels."

CPNPP currently uses anemergency classification scheme based on Nuclear Energy Institute (NEI) 99-01, Revision 5,"Methodology for Development of Emergency Action Levels,"

February 2008, endorsed by the NRC inLetter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008." The plan, as changed, would continue to meet the standards in 10CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50, Appendix E,Section IV.B, Luminant Power requests NRC approval of this proposed change to the CPNPP Emergency Plan prior to implementation.

This License Amendment Request includes the following attachments:

• Attachment 1 -Evaluation of Proposed Change* Attachment 2 -CPNPP NEI 99-01, Revision 6 EAL Comparison Matrix* Attachment 3 -Emergency Action Level Technical Bases Document (Clean Version)* Attachment 4 -Emergency Action Level Technical Bases (Redline and Strikeout Version)* Attachment 5 -CPNPP Radiological Effluent EAL Values* Attachment 6 -Emergency Action Level Wallcharts for CPNPPLuminant Power requests approval of the proposed changes by June 30, 2016, with the amendment beingimplemented within 180 days of issuance.

U. S. Nuclear Regulatory Commission TXX-15101 Page 2 of 206/30/2015 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to thedesignated Texas State Official.

Luminant Power commits to review the new classification scheme with state and local emergency management officials following NRC approval and prior to implementation.

Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725 orjack.hicks@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.Sincerely, Luminant Generation Company LLCRafael FloresBy:__Tom P. lVcCoolVice President, Nuclear Engineering

& SupportAttachments

-1. Evaluation of Proposed Change2. CPNPP NEI 99-01, Revision 6 EAL Comparison Matrix3. Emergency Action Level Technical Bases Document (Clean Version)4. Emergency Action Level Technical Bases (Redline and Strikeout Version)5. CPNPP Radiological Effluent EAL Values6. Emergency Action Level Wallcharts for CPNPPc -William M. Dean, Office of Nuclear Reactor Regulation (cl & Attachment 1)Marc L. Dapas, Region IV (cl & Attachment 1)Balwant K. Singal, NRR (cl & Attachment 1)Resident Inspectors, Comanche Peak (cl & Attachment 1)Alice Hamilton Rogers, P.E., Texas Department of State Health Services (cl & Attachment

1)

Attachment 1 to TXX-1 5101Page 1 of 6EVALUATION OF PROPOSED CHANGE1. SUMMARY DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination

4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES Attachment to TXX-15101 Page 2 of 61.0 SUMMARY DESCRIPTION In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planningand Preparedness for Production and Utilization Facilities,"

Section IV.B, Luminant Generation Company LLC (Luminant Power) is submitting a request for an amendment to the Emergency Plan forComanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.The proposed amendment involves upgrading selected CPNPP Emergency Action Levels (EALs) basedon NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" (Reference

1) using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use ofNuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels"(Reference 2). CPNPP currently uses an emergency classification scheme based on Nuclear EnergyInstitute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"February 2008 (Reference

3) endorsed by the NRC in Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. NuclearRegulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008,"(Reference

4) and approved for CPNPP in Reference

5. The plan, as changed, would continue to meetthe standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50.2.0 DETAILED DESCRIPTION CPNPP currently uses an emergency classification scheme based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

February 2008 (Reference

3) endorsed by the NRC in Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson(Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review andEndorsement of NEI-99-01, Revision 5, dated February 2008," (Reference

4) and approved for CPNPP inReference

5. Luminant Power requests approval to change the CPNPP scheme basis to that described in NEI 99-01, Revision 6," Development of Emergency Action Levels for Non-Passive Reactors."

3.0 TECHNICAL EVALUATION The Initiating Conditions (ICs) and EALs that comprise the proposed scheme are presented inAttachment

2. This matrix provides a cross-reference between each generic IC and EAL contained inNEI 99-01, Revision 6 and the proposed CPNPP-specific IC and EAL. Differences and Deviations areidentified in accordance with the guidance discussed in RIS 2003-18 and Supplements.

The basis foreach Difference is included in Attachment

2. There are no Deviations from NEI 99-01, Revision

6. Thematrix follows the presentation order of NEI 99-01, Revision 6 -Abnormal Rad Levels/Radiological

Effluent, Cold Shutdown/Refueling System Malfunction, Events Related to Independent Spent FuelStorage Installation (ISFSI),

Fission Product Barrier Degradation, Hazards and Other Conditions Affecting Plant Safety, and System Malfunction.

The Defueled Station section is not used since CPNPPis an operating plant.Differences and Deviations As discussed in Regulatory Issue Summary (RIS) 2003-18, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows:* A difference is an EAL change where the basis scheme guidance differs in wording but agreesin meaning and intent, such that classification of an event would be the same, whether usingthe basis scheme guidance or the site-specific proposed EAL. Examples of differences includethe use of site-specific terminology or administrative re-formatting of site-specific EALs.

Attachment to TXX-15101 Page 3 of 6A deviation is an EAL change where the basis scheme guidance differs in wording and isaltered in meaning or intent, such that classification of the event could be different between thebasis scheme guidance and the site-specific proposed EAL. Examples of deviations include theuse of altered mode applicability, altering key words or time limits, or changing words ofphysical reference (protected area, safety- related equipment, etc.).Attachment 2 identifies each Difference between NEI 99-01 and the final products being evaluated inthis LAR. These differences do not alter the meaning or intent of the ICs or EALs. There are noDeviations between NEI 99-01 and the final products being evaluated in this LAR.Incorporation of Action Level Frequently Asked Questions Where appropriate, information from Emergency Action Level Frequently Asked Questions (EALFAQs) has been incorporated into Attachment 2 and Attachment 3.Related Documents Attachment 3 includes the site-specific Technical Basis Document for each recognition category for theproposed scheme. A Redline and Strikeout version is provided as Attachment

4. These documents include appropriate information from the basis information contained in NEI 99-01, Revision 6.Attachment 5 provides the Supporting Calculation for CPNPP EAL Table R-1, "Effluent MonitorClassification Thresholds."

Attachment 6 contains the proposed CPNPP EAL Wallcharts.

Operational Modes and Applicability Mode applicability of the proposed ICs and EALs is consistent with the NEI 99-01, Revision 6 basisscheme. The Operating Modes for CPNPP, as defined in the Technical Specifications, are listed below.MODE TITLE REACTIVITY

% RATED AVERAGE REACTORCONDITION (keff) THERMAL POWER COOLANT TEMPERATURE (F)1 Power Operation

>0.99 >5 NA2 Startup >0.99 <5 NA3 Hot Standby <0.99 NA >3504 Hot Shutdown

<0.99 NA 350>Tavg>200 5 Cold Shutdown

<0.99 NA <2006 Refueling NA NA NAIn addition to these operating modes, NEI 99-01, Revision 6 defines the "Defueled" mode as thecondition present when all reactor fuel is removed from Reactor Vessel (full core off load duringrefueling or an extended outage).

Station procedures recognize this condition as "No Mode."State/Local Government Review of Proposed ChangesLuminant Power interacts periodically with the Texas and local emergency management agencies.

TheState and Local emergency management officials are advised of any EAL changes actuallyimplemented.

In the case of this EAL scheme revision, Luminant Power has committed to review thenew classification scheme to State and Local emergency management officials following NRC approvaland prior to implementation.

Implementation Description Luminant Power plans to implement the proposed emergency classification scheme in the third quarterof 2016. When implemented, the changes to the EALs presented in Attachment 3 will become effective.

Attachment to TXX-15101 Page 4 of 6The EAL Technical Basis Document (Attachment

3) will be revised and maintained as a training andbackground reference resource.

Any changes to the approved ICs and EALs will be made in accordance with 10 CFR 50.54(q).

4.0 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The regulation in 10 CFR 50.47(b)(4) states, "A standard emergency classification and action levelscheme, the bases of which include facility system and effluent parameters, is in use by the nuclearfacility

licensee, and State and Local response plans call for reliance on information provided by facilitylicensees for determinations of minimunm initial offsite response measures."

10 CFR 50 Appendix E, Section IV, Content of Emergency Plans, item B, Assessment Actions states:1. "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need fornotification and participation of Local and State agencies, the Commission, and otherFederal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outsidethe site boundary to protect health and safety. The emergency action levels shall bebased on in-plant conditions and instrumentation in addition to onsite and offsitemonitoring.

By June 20, 2012, for nuclear power reactor licensees, these action levelsmust include hostile action that may adversely affect the nuclear power plant. Theinitial emergency action levels shall be discussed and agreed on by the applicant orlicensee and state and local governmental authorities, and approved by the NRC.Thereafter, emergency action levels shall be reviewed with the State and Localgovernmental authorities on an annual basis."2. A licensee desiring to change its entire emergency action level scheme shall submit anapplication for an amendment to its license and receive NRC approval beforeimplementing the change. Licensees shall follow the change process in § 50.54(q) for allother emergency action level changes.Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 4, Section C, Regulatory Position states:"The guidance in NUMARC/NESP-007 (Revision 2, January 1992), "Methodology forDevelopment of Emergency Action Levels,"

is acceptable to the NRC staff as analternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 fordeveloping EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10CFR50.47(b)(4).

In addition, the guidance contained in NEI 99-01 (Revision 4, January2003), "Methodology for Development of Emergency Action Levels,"

is acceptable tothe NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 and NUMARC/NESP-007 for developing EALs required in SectionIV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."

4.2 No Significant Hazards Consideration Determination Luminant Power has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criteria set forth in 10 CFR50.92(c) as discussed below:

Attachment to TXX-15101 Page 5 of 61. Does the proposed amendment involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications.

The proposed changes do notmodify any plant equipment and do not impact any failure modes that could lead to anaccident.

Additionally, the proposed changes do not impact the consequence of anyanalyzed accident since the changes do not affect any equipment related to accidentmitigation.

Based on this discussion, the proposed amendment does not increase theprobability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accidentfrom any accident previously evaluated?

Response:

No.These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications.

They do not modify any plantequipment and there is no impact on the capability of the existing equipment to performtheir intended functions.

No system setpoints are being modified and no changes are beingmade to the method in which plant operations are conducted.

No new failure modes areintroduced by the proposed changes.

The proposed amendment does not introduce accident initiators or malfunctions that would cause a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?Response:

No.These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications.

The proposed changes do notaffect any of the assumptions used in the accident

analysis, nor do they affect anyoperability requirements for equipment important to plant safety. Therefore, the proposedchanges will not result in a significant reduction in the margin of safety as defined in thebases for technical specifications covered in this license amendment request.4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that thehealth and safety of the public will not be endangered by the proposed change in the CPNPP EALScheme, (2) operation of CPNPP will continue to be conducted in compliance with the Commission regulations, and (3) the issuance of the amendment will not be inimical to the common defense andsecurity or to the health and safety of the public.5.0 ENVIRONMENTAL CONSIDERATION Luminant Power has determined that the proposed amendment would not change requirements withrespect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor Attachment to TXX-15101 Page 6 of 6would it change inspection or surveillance requirements.

Luminant Power has evaluated the proposedchange and has determined that the change does not involve:I. A Significant Hazards Consideration, II. A significant change in the types or significant increase in the amounts of any effluentthat may be released off site, orIII. A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii).

Therefore, pursuant to 10 CFR51.22(b),

no environmental impact statement or environmental assessment need beprepared in connection with the proposed amendment.

6.0 REFERENCES

1) NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive

Reactors, dated November 2012, (ADAMS Accession No. ML12326A805)

2) NRC Regulatory Issue Summary 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI)99-0 1, Methodology for Development of Emergency Action Levels, dated December 12, 2005(ADAMS Accession No. ML051450482)

3) Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development ofEmergency Action Levels,"

February 2008 (ADAMS Accession No. ML080450149).

4) Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear EnergyInstitute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review andEndorsement of NEI-99-01, Revision 5, dated February 2008," (ADAMS Accession ML080430535)

5) Letter from Eric J. Leeds (Nuclear Regulatory Commission) to Mr. Rafael Flores (Luminant Generation Company LLC) dated May 17, 2010, "Comanche Peak Nuclear Power Plant, Units 1and 2- Change to Emergency Action Level Scheme (TAC NOS. ME1304 and ME1305)"(ADAMS Accession No. ML100850115)

ATTACHMENT 2 TO TXX-15101 CPNPP NEI 99-01, REVISION 6EAL COMPARISON MATRIX(116 PAGES)

Attachment 2 to TXX-15101 EAL Comparison MatrixComanche Peak Nuclear Power PlantNEI 99-01 Revision 6EAL Comparison MatrixRevision 0

Attachment 2 to TXX-1 5101EAL Comparison MatrixTable of ContentsSection PageIntroduction

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IComparison Matrix Format ---------------------------------------------------------------------

1EAL Wording -------------------------------------------------------------------------------------------------------------------------------------------------------

I.EAL Emphasis Techniques

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1Global Differences

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2Differences and Deviations

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3Category A -Abnormal Rad Levels / Rad Effluents

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12Category C -Cold Shutdown

/ Refueling System Malfunction

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31Category D -Permanently Defueled Station Malfunction

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52Category E -Events Related to Independent Spent Fuel Storage Installations

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54Category F -Fission Product Barrier Degradation.................................................-----------------------------------------------------

56Category H -Hazards and Other Conditions Affecting Plant Safety -------------------------------------------------------------------------------

69Category S -System Malfunction

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88Table 1 -CPNPP EAL Categories/Subcategories

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

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6Table 3 -Summary of Deviations

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11 Attachment 2 to TXX-1 5101EAL Comparison MatrixIntroduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01Rev. 6 Final, Development of Emergency Action Levels for Non-Passive

Reactors, ADAMS Accession Number ML12326A805, and the ComanchePeak Nuclear Power Plant (CPNPP) ICs, Mode Applicability and EALs. Thisdocument provides a means of assessing CPNPP differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of CPNPPEAL bases and lists of source document references are given in the EALTechnical Bases Document.

It is, therefore, advisable to reference the EALTechnical Bases Document for background information while using thisdocument.

Comparison Matrix FormatThe ICs and EALs discussed in this document are grouped according to NEI99-01 Recognition Categories.

Within each Recognition

Category, the ICsand EALs are listed in tabular format according to the order in which they aregiven in NEI 99-01. Generally, each row of the comparison matrix providesthe following information:

" NEI EAL/IC identifier

" NEI EAL/IC wording" CPNPP EAL/IC identifier

" CPNPP EAL/IC wordingo Description of any differences or deviations EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in thisdocument, line breaks and indentation may differ slightly from theappearance of comparable wording in the source documents.

NEI 99-01 isthe source document for the NEI EALs; the CPNPP EAL Technical BasesDocument for the CPNPP EALs.The print and paragraph formatting conventions summarized below guidepresentation of the CPNPP EALs in accordance with the EAL writing criteria.

Space restrictions in the EAL table of this document sometimes override thiscriteria in cases when following the criteria would introduce undesirable complications in the EAL layout." Upper case-bold print is used for the logic terms AND, OR andEITHER." Bold font is used for certain logic terms, negative terms (not,cannot, etc.), any, all." Upper case print is reserved for defined terms, acronyms, systemabbreviations, logic terms (and, or, etc. when not used as aconjunction),

annunciator window engravings.

• Three or more items in a list are normally introduced with "Any of thefollowing..."

or "All of the following..."

Items of the list begin withbullets when a priority or sequence is not inferred.

" The use of AND/OR logic within the same EAL has been avoidedwhen possible.

When such logic cannot be avoided, indentation andseparation of subordinate contingent phrases is employed.

Global Differences The differences listed below generally apply throughout the set of EALs andare not repeated in the Justification sections of this document.

The globaldifferences do not decrease the effectiveness of the intent of NEI 99-01.1. The NEI phrase "Notification of Unusual Event" has been changed to"Unusual Event" or abbreviated "UE" to reduce EAL-user readingburden.2. In some instances NEI 99-01 IC Example EALs are implemented inseparate plant EALs to improve clarity and readability.

For example,NEI lists all IC HU3 Example EALs under one IC. The corresponding CPNPP EALs appear as unique EALs (e.g., HU3.1 through HU3.4).3. Mode applicability identifiers (numbers/letter) modify the NEI 99-01mode applicability names as follows:

1 -Power Operation, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown, 5 -Cold Shutdown, 6 -Refueling, D -Defueled.

NEI 99-01defines Defueled as follows:"Reactor Vessel contains no irradiated fuel (full core off-load duringrefueling or extended outage)."

4. "rain." is the standard abbreviation for "minutes" and is used toreduce EAL user reading burden.1 of 114 Attachment 2 to TXX-1 5101EAL Comparison Matrix5. The term "Emergency Director" has been replaced by "Emergency Coordinator" consistent with site-specific nomenclature.

6. Wherever the generic bracketed PWR term "reactor vessel/RCS" isprovided, CPNPP uses the term "RCS" as the site-specific nomenclature.

7. IC/EAL identification:

• NEI Recognition Category A "Abnormal Radiation Levels/Radiological Effluents" has been changed to Category R"Abnormal Rad Levels / Rad Effluents."

The designator "R" ismore intuitively associated with radiation (rad) or radiological events. NEI IC designators beginning with "A" have likewisebeen changed to "R."* NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, inturn, are grouped in "Recognition Categories."

CPNPPendeavors to optimize the NEI EAL organization andidentification scheme to enhance usability of the plant-specific EAL set. To this end, the CPNPP IC/EAL scheme includes thefollowing features:

a. Division of the NEI EAL set into three groups:o EALs applicable under all plant operating modes -This group would be reviewed by the EAL-user anytime emergency classification is considered.

o EALs applicable only under hot operating modes-This group would only be reviewed by the EAL-userwhen the plant is in Hot Shutdown, Hot Standby,Startup or Power Operation mode.o EALs applicable only under cold operating modes -This group would only be reviewed by the EAL-userwhen the plant is in Cold Shutdown, Refueling orDefueled mode.The purpose of the groups is to avoid review of hotcondition EALs when the plant is in a cold condition andavoid review of cold condition EALs when the plant is in ahot condition.

This approach significantly minimizes thetotal number of EALs that must be reviewed by the EAL-user for a given plant condition and, thereby, speedsidentification of the EAL that applies to the emergency.

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

-Category andsubcategory titles are selected to represent conditions that are operationally significant to the EAL-user.

Subcategories are used as necessary to further divide theEALs of a category into logical sets of possibleemergency classification thresholds.

The CPNPP EALcategories/subcategories and their relationship to NEIRecognition Categories are listed in Table 1.c. Unique identification of each EAL -Four characters comprise the EAL identifier as illustrated in Figure 1.Figure 1 -EAL Identifier EAL Identifier XXX.XCategory (R, H, E, S. F. C) iL Sequential number Within subcategory/classificatioo Emergency classification (G. S. A. U) 1ýSubcategory number (Ilif no subeetegory)

The first character is a letter associated with the categoryin which the EAL is located.

The second character is aletter associated with the emergency classification level(G for General Emergency, S for Site Area Emergency, Afor Alert, and U for Notification of Unusual Event). Thethird character is a number associated with one or moresubcategories within a given category.

Subcategories aresequentially numbered beginning with the number "1 ". If acategory does not have a subcategory, this character isassigned the number "1". The fourth character is anumber preceded by a period for each EAL within asubcategory.

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

2 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrixo Uniqueness

-The EAL identifier ensures that therecan be no confusion over which EAL is driving theneed for emergency classification.

o Speed in locating the EAL of concern -When theEALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user tothe location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assistsERO responders (who may not be in the samefacility as the ED) to find the EAL of concern in atimely manner without the need for a worddescription of the classification threshold.

o Possible classification upgrade -Thecategory/subcategory/identifier scheme helps theEAL-user find higher emergency classification EALsthat may become active if plant conditions worsen.Table 2 lists the CPNPP ICs and EALs that correspond tothe NEI ICs/Example EALs when the above EAL/ICorganization and identification scheme is implemented.

Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use ofNuclear Energy Institute (NEI) 99-01, Methodology for Development ofEmergency Action Levels" Supplements 1 and 2, a difference is an EALchange in which the basis scheme guidance differs in wording but agrees inmeaning and intent, such that classification of an event would be the same,whether using the basis scheme guidance or the CPNPP EAL. A deviation isan EAL change in which the basis scheme guidance differs in wording and isaltered in meaning or intent, such that classification of the event could bedifferent between the basis scheme guidance and the CPNPP proposedEAL.Administrative changes that do not actually change the textual content areneither differences nor deviations.

Likewise, any format change that does notalter the wording of the IC or EAL is considered neither a difference nor adeviation.

The following are examples of differences:

• Choosing the applicable EAL based upon plant type (i.e., BWR vs.PWR).* Using a numbering scheme other than that provided in NEI 99-01that does not change the intent of the overall scheme." Where the NEI 99-01 guidance specifically provides an option to notinclude an EAL if equipment for the EAL does not exist at CPNPP(e.g., automatic real-time dose assessment capability).

" Pulling information from the bases section up to the actual EAL thatdoes not change the intent of the EAL.* Choosing to state ALL Operating Modes are applicable instead ofstating N/A, or listing each mode individually under the AbnormalRad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.

• Using synonymous wording (e.g., greater than or equal to vs. at orabove, less than or equal vs. at or below, greater than or less thanvs. above or below, etc.)* Adding CPNPP equipment/instrument identification and/or nounnames to EALs.* Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained andthe overall progression of the EAL scheme is not affected.

" Any change to the IC and/or EAL, and/or basis wording, as stated inNEI 99-01, that does not alter the intent of the IC and/or EAL, i.e.,the IC and/or EAL continues to:o Classify at the correct classification level.o Logically integrate with other EALs in the EAL scheme.o Ensure that the resulting EAL scheme is complete (i.e.,classifies all potential emergency conditions).

The following are examples of deviations:

" Use of altered mode applicability.

• Altering key words or time limits." Changing words of physical reference (protected area, safety-related equipment, etc.).3 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrix* Eliminating an IC. This includes the removal of an IC from theFission Product Barrier Degradation category as this impacts thelogic of Fission Product Barrier ICs.* Changing a Fission Product Barrier from a Loss to a Potential Lossor vice-versa.

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

Use of thewording provided in NEI 99-01 is encouraged since the intent is forall users to have a standard set of defined terms as defined in NEI99-01.* Any change to the IC and/or EAL, and/or basis wording as stated inNEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the ICand/or EAL:o Does not classify at the classification level consistent withNEI 99-01.o Is not logically integrated with other EALs in the EALscheme.o Results in an incomplete EAL scheme (i.e., does not classifyall potential emergency conditions).

The "Difference/Deviation Justification" columns in the remaining sections ofthis document identify each difference between the NEI 99-01 IC/EALwording and the CPNPP IC/EAL wording.

An explanation that justifies thereason for each difference is then provided.

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

In all cases, however, the differences anddeviations do not decrease the effectiveness of the intent of NEI 99-01. Asummary list of CPNPP EAL deviations from NEI 99-01 is given in Table 3.4 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixTable I -CPNPP EAL Categories/Subcategories CPNPP EALs NEICategory Subcategory Recognition CategoryGroup: Any Operatingq Mode:1 -Radiological Effluent Abnormal Rad Levels/Radiological EffluentR- Abnormal Rad Levels/Rad Effluent 2 -Irradiated Fuel Event ICs/EALs3 -Area Radiation LevelsH -Hazards and Other Conditions Affecting 1 -Security Hazards and Other Conditions Affecting Plant Safety 2 -Seismic Event Plant Safety [Cs/EALs3 -Natural or Technological Hazard4 -Fire5 -Hazardous Gases6 -Control Room Evacuation 7 -Emergency Coordinator JudgmentE -ISFSl 1 -Confinement Boundary ISFSI ICs/EALsGroup: Hot Conditions:

1 -Loss of Emergency AC Power System Malfunction ICs/EALs2 -Loss of Vital DC Power3 -Loss of Control Room Indications 4 -RCS ActivityS -System Malfunction 5 -RCS Leakage6 -RPS Failure7 -Loss of Communications 8 -Containment Failure9 -Hazardous Event Affecting Safety SystemsF -Fission Product Barrier None Fission Product Barrier ICs/EALsGroup: Cold Conditions:

1 -RCS Level Cold Shutdown./

Refueling System2 -Loss of Emergency AC Power Malfunction ICs/EALsC -Cold Shutdown/Refueling System 3 -RCS Temperature Malfunction 4 -Loss of Vital DC Power5 -Loss of Communications 6 -Hazardous Event Affecting Safety Systems5 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable 2 -NEI / CPNPP EAL Identification Cross-Reference NEI CPNPPIC Example Category and Subcategory EALEALAU1 1 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RUI.1AU1 2 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RUI.1AU1 3 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RU1.2AU2 1 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RU2.1AA1 2 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RA1.1AA1 2 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RA1.2AA1 3 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RA1.3AA1 4 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RA1.4AA2 1 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RA2.1AA2 2 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RA2.2AA2 3 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RA2.3AA3 1 R -Abnormal Rad Levels / Rad Effluent, 3 -Area Radiation Levels RA3.1AA3 2 R -Abnormal Rad Levels / Rad Effluent, 3 -Area Radiation Levels RA3.2ASI 1 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RSI.1AS1 2 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RS1.2ASI 3 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RS1.36 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI CPNPP1C Example Category and Subcategory EALEALAS2 1 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RS2.1AG1 1 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RG1.1AG1 2 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RG1.2AG1 3 R -Abnormal Rad Levels / Rad Effluent, 1 -Radiological Effluent RG1.3AG2 1 R -Abnormal Rad Levels / Rad Effluent, 2 -Irradiated Fuel Event RG2.1CUl 1 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CU1.1CU1 2 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CUI.2CU2 1 C -Cold SD/ Refueling System Malfunction, 2 -Loss of ESF AC Power CU2.1CU3 1 C -Cold SD/ Refueling System Malfunction, 3 -RCS Temperature CU3.1CU3 2 C -Cold SD/ Refueling System Malfunction, 3 -RCS Temperature CU3.2CU4 I C -Cold SD/ Refueling System Malfunction, 4 -Loss of Vital DC Power CU4.1CU5 1, 2, 3 C -Cold SD/ Refueling System Malfunction, 5 -Loss of Communications CU5.1CA1 1 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CA1.1CAI 2 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CA1.2CA2 1 C -Cold SD/ Refueling System Malfunction, 1 -Loss of ESF AC Power CA2.1CA3 1, 2 C -Cold SD/ Refueling System Malfunction, 3 -RCS Temperature CA3.1CA6 1 C -Cold SD/ Refueling System Malfunction, 6 -Hazardous Event Affecting Safety Systems HA4.1CS1 I C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CS1.17 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI CPNPPIC Example Category and Subcategory EALEALCS1 2 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CS1.2CS1 3 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CSI.3CG1 1 C -Cold SD/ Refueling System Malfunction, 1 -RCS Level CGI.2CG1 2 C -Cold SD/ Refueling System Malfunction, Il -RCS Level CG1.2E-HUI 1 E -ISFSI -Confinement Boundary EUI.1FA1 1 F -Fission Product Barrier Degradation FA1.1FSI I F -Fission Product Barrier Degradation FSI.1FG1 1 F -Fission Product Barrier Degradation FG1.1HUI 1 H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HUI.1HU1 2 H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HU1.2HUI 3 H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HU1.3HU2 1 H -Hazards and Other Conditions Affecting Plant Safety, 2 -Seismic Event HU2.1HU3 1 H -Hazards and Other Conditions Affecting Plant Safety, 3 -Natural or Technological Hazard HU3.1HU3 2 H -Hazards and Other Conditions Affecting Plant Safety, 3 -Natural or Technological Hazard HU3.2HU3 3 H -Hazards and Other Conditions Affecting Plant Safety, 3 -Natural or Technological Hazard HU3.3HU3 4 H -Hazards and Other Conditions Affecting Plant Safety, 3 -Natural or Technological Hazard HU3.4HU3 5 N/A N/AHU4 1 H -Hazards and Other Conditions Affecting Plant Safety, 4 -Fire or Explosion HU4.18 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI CPNPPExample Category and Subcategory EALEALHU4 2 H -Hazards and Other Conditions Affecting Plant Safety, 4 -Fire or Explosion HU4.2HU4 3 H -Hazards and Other Conditions Affecting Plant Safety, 4 -Fire or Explosion HU4.3HU4 4 H -Hazards and Other Conditions Affecting Plant Safety, 4 -Fire or Explosion HU4.4HU7 I H -Hazards and Other Conditions Affecting Plant Safety, 7 -Judgment HU7.1HAI 1 H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HA1.1HA1 2 H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HAI.1HA5 1 H -Hazards and Other Conditions Affecting Plant Safety, 5 -Hazardous Gases HA5.1HA6 1 H -Hazards and Other Conditions Affecting Plant Safety, 6 -Control Room Evacuation HA6.1HA7 1 H -Hazards and Other Conditions Affecting Plant Safety, 7 -Judgment HA7.1HSI 1 H -Hazards and Other Conditions Affecting Plant Safety, I -Security HSI.1HS6 I H -Hazards and Other Conditions Affecting Plant Safety, 6 -Control Room Evacuation HS6.1HS7 1 H -Hazards and Other Conditions Affecting Plant Safety, 7 -Judgment HS7.1HG1 I H -Hazards and Other Conditions Affecting Plant Safety, 1 -Security HGI.1HG7 2 H -Hazards and Other Conditions Affecting Plant Safety, 7 -Judgment HG7.1SUl 1 S -System Malfunction, I -Loss of Emergency AC Power SUI.1SU2 I S -System Malfunction, 3 -Loss of Control Room Indications SU3.1SU3 1 S -System Malfunction, 4 -RCS Activity SU4.1SU3 2 S -System Malfunction, 4 -RCS Activity SU4.29 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI CPNPPIC Example Category and Subcategory EALEALSU4 1, 2, 3 S -System Malfunction, 5 -RCS Leakage SU5.1SU5 1 S -System Malfunction, 6 -RPS Failure SU6.1SU5 2 S -System Malfunction, 6 -RPS Failure SU6.2SU6 1, 2, 3 S -System Malfunction, 7 -Loss of Communications SU7.1SU7 1, 2 S -System Malfunction, 8 -Containment Failure SU8.1SA1 1 S -System Malfunction, 1 -Loss of Emergency AC Power SA1.1SA2 I S -System Malfunction, 3 -Loss of Control Room Indications SA3.1SA5 1 S -System Malfunction, 6 -RPS Failure SA6.1SA9 I S -Hazardous Event Affecting Safety Systems SA9.1SS1 1 S -System Malfunction, 1 -Loss of Emergency AC Power SS1.1SS5 1 S -System Malfunction, 6 -RPS Failure SS6.1SS8 1 S -System Malfunction, 2 -Loss of Vital DC Power SS2.1SG1 1 S -System Malfunction, 1 -Loss of Emergency AC Power SG1.1SG8 2 S -System Malfunction, 1 -Loss of Emergency AC Power SG1.210 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixTable 3 -Summary of Deviations NEI CPNPPIC Example EAL EAL Description N/A N/A N/A N/A11 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCategory AAbnormal Rad Levels / Radiological Effluent12 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording and Mode CPNPP CPNPP IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Release of gaseous or liquid RU1 Release of gaseous or liquid The CPNPP ODCM is the site-specific effluent releaseradioactivity greater than 2 times radioactivity greater than 2 times the controlling document.

the (site-specific effluent release ODCM limits for 60 minutes or longercontrolling document) limits for MODE: All60 minutes or longer.MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Reading on ANY effluent Reading on any Table R-1 effluent Example EALs #1 and #2 have been combined into a singleradiation monitor greater than 2 radiation monitor greater than column EAL to simplify presentation.

times the (site-specific effluent "UE" for greater than or equal to 60 The NEI phrase "...effluent radiation monitor greater than 2release controlling document) mi. (Notes 1, 2, 3) times the (site-specific effluent release controlling limits for 60 minutes or longer: document)"

and "effluent radiation monitor greater than 2(site-specific monitor list and times the alarm setpoint established by a current radioactivity threshold values corresponding discharge permit" have been replaced with "...any Table R-1to 2 times the controlling RU1.1 effluent radiation monitor greater than column "UE".document limits) UE thresholds for all CPNPP continuously monitored 2 Reading on ANY effluent gaseous release pathways are listed in Table R-1 toradiation monitor greater than 2 consolidate the information in a single location and, thereby,times the alarm setpoint simplify identification of the thresholds by the EAL user. Theestablished by a current values shown in Table R-1 column "UE", consistent with theradioactivity discharge permit for NEI bases, represent two times the ODCM release limits for60 minutes or longer, both liquid and gaseous release.3 Sample analysis for a gaseous or RU1.2 Sample analysis for a gaseous or The CPNPP ODCM is the site-specific effluent releaseliquid release indicates a liquid release indicates a concentration controlling document.

concentration or release rate or release rate > 2 x ODCM limits forgreater than 2 times the (site- greater than or equal to 60 min.specific effluent release (Notes 1, 2)controlling document) limits for13 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #60 minutes or longer.Notes 0 The Emergency Director N/A Note 1: The Emergency Coordinator The classification timeliness note has been standardized should declare the Unusual should declare the event across the CPNPP EAL scheme by referencing the "timeEvent promptly upon promptly upon determining limit" specified within the EAL wording.determining that 60 minutes that time limit has beenhas been exceeded, or will exceeded, or will likely belikely be exceeded.

exceeded.

" If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized detected and the release detected and the release across the CPNPP EAL scheme by referencing the "timestart time is unknown, start time is unknown, limit" specified within the EAL wording.assume that the release assume that the releaseduration has exceeded 60 duration has exceeded theminutes.

specified time limit." If the effluent flow past an Note 3: If the effluent flow past aneffluent monitor is known to effluent monitor is known to Nonehave stopped due to actions have stopped, indicating thatto isolate the release path, the release path is isolated, then the effluent monitor the effluent monitor readingreading is no longer valid for is no longer VALID forclassification purposes.

classification purposes.

14 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UEPlant Vent X-RE-5567 6.52E-4 pCi/miPVG384 + PVG385 A + BPlant Vent X-E570 (WRGM) Ven 4.OE+7 pLCi/sec 4.OE+6 lOCi/sec 4.OE+5 piCi/sec 4.OE+4 OCi/seco A+BGM0 PVF684 + PVF685U)' Main SteamMSLu78 u-RE-2325 MSLu79 u-RE-2326 90 jICi/ml*

9.0 liCj/ml*

0.9 pCi/ml* 2 x high alarmMSLu8O u-RE-2327 setpoint*

MSLu81 u-RE-2328 Liquid Waste X-RE-5253

...............-

2 x high alarmLWE-076 setpoint._ Service Water u-RE-4269 2 x high alarm* ' SSWu65....

....SSWu66 u-RE-4270 setpoint* with reactor shutdown15 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording and Mode CPNPP CPNPP IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU2 UNPLANNED loss of water level RU2 Unplanned loss of water level above Noneabove irradiated fuel. irradiated fuelMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNA CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the Site-specific area radiation monitors are listed in Table R-2.drop in the REFUELING REFUELING PATHWAY as indicated PATHWAY as indicated by by low water level alarm or indication ANY of the following:

(site-specific level ANDindications).

UNPLANNED rise in corresponding ANND area radiation levels as indicated byradiation levels as indicated any Table R-2 area radiation monitorsby ANY of the following radiation monitors.

(site-specific list of arearadiation monitors)

Table R-2 SFP & Refueling Cavity Area Radiation MonitorsSFP:* SFP001, LRAM SFP 2 E WALL (X-RE-6272)

• SFP002, LRAM SFP 2 N WALL (X-RE-6273)

" SFP003, LRAM SFP 1 E WALL (X-RE-6274)

" SFP004, LRAM SFP 1 S WALL (X-RE-6275)

Refueling Cavity:* RFCuI0, LRAM W REFUEL CAV860 (u-RE-6251)

" RFCu12, LRAM E REFUEL CAV 860 (u-RE-6253) 16 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)Release of gaseous or liquid RA1 Release of gaseous or liquid Noneradioactivity resulting in offsite radioactivity resulting in offsite dosedose greater than 10 mrem TEDE greater than 10 mrem TEDE or 50or 50 mrem thyroid CDE. mrem thyroid CDEMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Reading on ANY of the following RAl.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity radiation monitors greater than radiation monitor greater than column effluent release to the environment are listed in Table R-1.the reading shown for 15 "ALERT" for greater than or equal to UE, Alert, SAE and GE thresholds for all CPNPPminutes or longer: 15 min. (Notes 1, 2, 3, 4) continuously monitored gaseous and liquid release pathwaysare listed in Table R-1 to consolidate the information in a(site-specific monitor list and single location and, thereby, simplify identification of thethreshold values) thresholds by the EAL-user.

2 Dose assessment using actual RA1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptormeteorology indicates doses meteorology indicates doses greater point.greater than 10 mrem TEDE or than 10 mrem TEDE or 50 mrem50 mrem thyroid CDE at or thyroid CDE at or beyond the thebeyond (site-specific dose EXCLUSION AREA BOUNDARYreceptor point). (Notes 3, 4)3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The exclusion area boundary is the site-specific receptorsample indicates a concentration indicates a concentration or release point.or release rate that would result rate that would result in doses greaterin doses greater than 10 mrem than 10 mrem TEDE or 50 mremTEDE or 50 mrem thyroid CDE thyroid CDE at or beyond the theat or beyond (site-specific dose EXCLUSION AREA BOUNDARY forreceptor point) for one hour of 60 min. of exposure (Notes 1, 2)exposure.

17 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixT r4Field survey results indicateEITHER of the following at orbeyond (site-specific dosereceptor point):" Closed window dose ratesgreater than 10 mR/hrexpected to continue for 60minutes or longer." Analyses of field surveysamples indicate thyroidCDE greater than 50 mremfor one hour of inhalation.

RA1.4Field survey results indicate EITHERof the following at or beyond theEXCLUSION AREA BOUNDARY:

" Closed window dose ratesgreater than 10 mR/hrexpected to continue forgreater than or equal to 60min.* Analyses of field surveysamples indicate thyroid CDEgreater than 50 mrem for 60min. of inhalation.

(Notes 1, 2)The exclusion area boundary is the site-specific receptorpoint.Notes" The Emergency Directorshould declare the Alertpromptly upon determining that the applicable time hasbeen exceeded, or will likelybe exceeded.

" If an ongoing release isdetected and the releasestart time is unknown,assume that the releaseduration has exceeded 15minutes." If the effluent flow past aneffluent monitor is known tohave stopped due to actionsto isolate the release path,then the effluent monitorreading is no longer valid forclassification purposes.

" The pre-calculated effluentmonitor values oresented inN/ANote 1: The Emergency Coordinator should declare the eventpromptly upon determining that time limit has beenexceeded, or will likely beexceeded.

Note 2: If an ongoing release isdetected and the releasestart time is unknown,assume that the releaseduration has exceeded thespecified time limit.Note 3: If the effluent flow past aneffluent monitor is known tohave stopped, indicating that the release path isisolated, the effluent monitorreading is no longer VALIDfor classification purposes.

Note 4 The pre-calculated effluentmonitor values presented inEALs RAI.1. RSI.1 andThe classification timeliness note has been standardized across the CPNPP EAL scheme by referencing the "timelimit" specified within the EAL wording.The classification timeliness note has been standardized across the CPNPP EAL scheme by referencing the "timelimit" specified within the EAL wording.NoneIncorporated site-specific EAL numbers associated withgeneric EAL#1.18 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixEAL #1 should be used for RG1.1 should be used foremergency classification emergency classification assessments until the results assessments until thefrom a dose assessment results from a doseusing actual meteorology are assessment using actualavailable.

meteorology are available.

19 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)AA2 Significant lowering of water RA2 Significant lowering of water level Nonelevel above, or damage to, above, or damage to, irradiated fuelirradiated fuel. MODE: AllMODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Uncovery of irradiated fuel in the RA2.1 Uncovery of irradiated fuel in the NoneREFUELING PATHWAY.

REFUELING PATHWAY2 Damage to irradiated fuel RA2.2 Damage to irradiated fuel resulting in a Site-specific list of radiation monitors bulletized.

resulting in a release of release of radioactivity radioactivity from the fuel as ANDindicated by ANY of the High alarm on any of the following:

following radiation monitors:

0 Any Table R-2 area radiation monitors(site-specific listing of radiation

• CAGu97, CNTMT AIR PIG GASmonitors, and the associated (u-RE-5503)

readings, setpoints and/oralarms)

• CAPu98, CNTMT AIR PIGPART (u-RE-5502) 0 CAIu99, CNTMT AIR PIGIODINE (u-RE-5566) a FBV088, FB VENT EXH (X-RE-5700)3 Lowering of spent fuel pool level RA2.3 Lowering of spent fuel pool level to El. Post-Fukushima order EA-12-051 required the installation ofto (site-specific Level 2 value). 844.3' (Level 2) reliable SFP level indication capable of identifying normal level[See Developer Notes] (Level 1), SFP level 10 ft. above the top of the fuel racks(Level 2) and SFP level at the top of the fuel racks (Level 3).Comanche Peak designated as Level 2 the water level 10 feet(+/- 1.0 foot) above the top of the fuel racks (El 844'- 2.75"rounded to 844.3' indicated) 20 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable R-2 SFP & Refueling Cavity Area Radiation MonitorsSFP:* SFP001, LRAM SFP 2 E WALL (X-RE-6272)

" SFP002, LRAM SFP 2 N WALL (X-RE-6273)

• SFP003, LRAM SFP 1 E WALL (X-RE-6274)

• SFP004, LRAM SFP I S WALL (X-RE-6275)

Refueling Cavity:" RFCulO, LRAM W REFUEL CAV860 (u-RE-6251)

" RFCu12, LRAM E REFUEL CAV 860 (u-RE-6253) 21 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)AA3 Radiation levels that impede RA3 Radiation levels that IMPEDE access Noneaccess to equipment necessary to equipment necessary for normalfor normal plant operations, plant operations, cooldown orcooldown or shutdown shutdownMODE: All MODE: AllNEI Ex. CPNPPEAL # NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification 1 Dose rate greater than 15 mR/hr RA3.1 Dose rates greater than 15 mR/hr in No other site-specific areas requiring continuous occupancy in ANY of the following areas: EITHER of the following areas: exist at CPNPP.* Contrl RoomControl RoomCControl48 (X-RE-6281) or CRM49 CRM048 (X-RE-6281) and CRM049 (X-RE-6282) are theCRM08 (XRE-681) r CR049 installed CR ARMs.* Central Alarm Station (X-RE-6282)

• (other site-specific OR The CAS does not have installed area radiation monitoring areas/rooms)

Central Alarm Station (by survey) and thus must be determined by survey.2 An UNPLANNED event results RA3.2 An UNPLANNED event results in The list of plant rooms or areas with entry-related modein radiation levels that prohibit or radiation levels that prohibit or applicability identified specify those rooms or areas thatimpede access to any of the IMPEDE access to any Table R-3 contain equipment which require a manual/local action asfollowing plant rooms or areas: rooms or areas (Note 5) specified in operating procedures used for normal plant(site-specific list of plant rooms operation, cooldown and shutdown.

or areas with entry-related modeapplicability identified)

Note If the equipment in the listed N/A Note 5: If the equipment in the Noneroom or area was already listed room or area wasinoperable or out-of-service already inoperable or out-before the event occurred, then of-service before the eventno emergency classification is occurred, then nowarranted.

emergency classification iswarranted.

22 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable R-3 Safe Operation

& Shutdown Rooms/Areas Room/Area Mode Applicability Charging Pump Rooms 1, 2, 3, 4, 5, 6CVCS Valve Rooms 1, 2, 3, 4, 5, 61 E Switchgear Rooms AllRHR Pump Rooms 4, 5, 623 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPN#PP CPNPP IC Wording Difference/Deviation Justification IC#(s)ASI Release of gaseous radioactivity RS1 Release of gaseous radioactivity Noneresulting in offsite dose greater resulting in offsite dose greater thanthan 100 mrem TEDE or 500 100 mrem TEDE or 500 mrem thyroidmrem thyroid CDE CDEMODE: All MODE: All MODE: AllNEI Ex. NEI Example EAL Wording CAPN CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #Reading on ANY of the following RS1.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity radiation monitors greater than radiation monitor greater than column effluent release to the environment are listed in Table R-1.the reading shown for 15 "SAE" for greater than or equal to 15 UE, Alert, SAE and GE thresholds for all CPNPP continuously minutes or longer: min. monitored gaseous and liquid release pathways are listed in(site-specific monitor list and (Notes 1, 2, 3, 4) Table R-1 to consolidate the information in a single locationthreshold values) and, thereby, simplify identification of the thresholds by theEAL-user.

2 Dose assessment using actual RS1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptormeteorology indicates doses meteorology indicates doses greater point.greater than 100 mrem TEDE or than 100 mrem TEDE or 500 mrem500 mrem thyroid CDE at or thyroid CDE at or beyond thebeyond (site-specific dose EXCLUSION AREA BOUNDARYreceptor point) (Notes 3, 4)3 Field survey results indicate RS1.3 Field survey results indicate EITHER The exclusion area boundary is the site-specific receptorEITHER of the following at or of the following at or beyond the point.beyond (site-specific dose EXCLUSION AREA BOUNDARY:

receptor point): 0 Closed window dose rates* Closed window dose rates greater than 100 mR/hrgreater than 100 mR/hr expected to continue for greaterexpected to continue for 60 than or equal to 60 min.minutes or longer.* Analyses of field survey 0 Analyses of field surveysamples indicate thyroid samples indicate thyroid CDE24 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCDE greater than 500 greater than 500 mrem for 60mrem for one hour of min. of inhalation.

inhalation.

(Notes 1, 2)Notes S The Emergency Directorsotes ho dmecrgeny trecitere Note 1: The Emergency Coordinator The classification timeliness note has been standardized should declare the Site Area should declare the event across the CPNPP EAL scheme by referencing the "time limit"Emergency promptly upon promptly upon determining specified within the EAL wording.determining that the that time limit has beenapplicable time has been exceeded, or will likely beexceeded, or will likely be exceeded,

exceeded, exceeded.

exceeded.

" If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized detected and the release start detected and the release across the CPNPP EAL scheme by referencing the "time limit"time is unknown, assume that start time is unknown, specified within the EAL wording.the release duration has assume that the releaseexceeded 15 minutes.

duration has exceeded the" If the effluent flow past an specified time limit.effluent monitor is known tohave stopped due to actions Note 3: If the effluent flow past antohsoave stopped rae tactis effluent monitor is known to Noneto isolate the release path, have stopped, indicating thatthen the effluent monitor the release path is isolated, reading is no longer valid for the effluent monitor readingclassification purposes.

is no longer VALID for* The pre-calculated effluent classification purposes.

monitor values presented in Note 5 The pre-calculated effluent Incorporated site-specific EAL numbers associated withEAL #1 should be used for monitor values presented in generic EAL#1.emergency classification EALs RAI.1, RS1.1 andassessments until the results RG1.1 should be used forfrom a dose assessment emergency classification using actual meteorology are assessments until the resultsavailable.

from a dose assessment using actual meteorology areavailable.

25 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)AS2 Spent fuel pool level at (site- RS2 Spent fuel pool level at the top of the Top of the fuel racks is the site-specific Level 3 description.

specific Level 3 description) fuel racksMODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1Lowering of spent fuel pool levelto (site-specific Level 3 value)RS2.1Lowering of spent fuel pool level to El.835.3' (Level 3)Post-Fukushima order EA-12-051 required the installation ofreliable SFP level indication capable of identifying normal level(Level 1), SFP level 10 ft. above the top of the fuel racks(Level 2) and SFP level at the top of the fuel racks (Level 3).Comanche Peak designated as Level 3 the water level greaterthan 1 foot above the top of the fuel storage racks plus theaccuracy of the SFP level instrument channel (El. 835' -2.75"rounded to 835.3' indicated).

26 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)AG1 Release of gaseous radioactivity RG1 Release of gaseous radioactivity Noneresulting in offsite dose greater resulting in offsite dose greaterthan 1,000 mrem TEDE or than 1,000 mrem TEDE or 5,0005,000 mrem thyroid CDE. mrem thyroid CDEMODE: All MODE: AllNEI Ex. CPNPPEAL Ex NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification I Reading on ANY of the following RG1.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity effluentradiation monitors greater than radiation monitor greater than release to the environment are listed in Table R-1. UE, Alert, SAEthe reading shown for 15 column "GE" for greater than or and GE thresholds for all CPNPP continuously monitored gaseousminutes or longer: equal to 15 min. or liquid release pathways are listed in Table R-1 to consolidate the(site-specific monitor list and (Notes 1, 2, 3, 4) information in a single location and, thereby, simplify identification ofthreshold values) the thresholds by the EAL-user.

2 Dose assessment using actual RG1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptor point.meteorology indicates doses meteorology indicates dosesgreater than 1,000 mrem TEDE greater than 1000 mrem TEDE oror 5,000 mrem thyroid CDE at 5000 mrem thyroid CDE at oror beyond (site-specific dose beyond the EXCLUSION AREAreceptor point). BOUNDARY (Notes 3, 4)3 Field survey results indicate RGI .3 Field survey results indicate The exclusion area boundary is the site-specific receptor point.EITHER of the following at or EITHER of the following at orbeyond (site-specific dose beyond the EXCLUSION AREAreceptor point): BOUNDARY:

e Closed window dose rates Closed window dose ratesgreater than 1,000 mR/hr greater than 1000 mR/hrexpected to continue for 60 expected to continue forminutes or longer, greater than or equal to 60* Analyses of field survey min.samples indicate thyroid CDEgreater than 5,000 mrem for

• Analyses of field survey27 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrixone hour of inhalation.

samples indicate thyroid CDEgreater than 5000 mrem for 60min. of inhalation.

(Notes 1, 2)Notes" The Emergency Directorshould declare the Site AreaEmergency promptly upondetermining that theapplicable time has beenexceeded, or will likely beexceeded.

" If an ongoing release isdetected and the releasestart time is unknown,assume that the releaseduration has exceeded 15minutes.* If the effluent flow past aneffluent monitor is known tohave stopped due to actionsto isolate the release path,then the effluent monitorreading is no longer valid forclassification purposes.

• The pre-calculated effluentmonitor values presented inEAL #1 should be used foremergency classification assessments until the resultsfrom a dose assessment using actual meteorology areavailable.

Note 1: The Emergency Coordinator shoulddeclare the eventpromptly upondetermining that timelimit has beenexceeded, or will likelybe exceeded.

Note 2: If an ongoing release isdetected and therelease start time isunknown, assume thatthe release duration hasexceeded the specified time limit.Note 3: If the effluent flow pastan effluent monitor isknown to have stopped,indicating that therelease path is isolated, the effluent monitorreading is no longerVALID for classification purposes.

Note 5 The pre-calculated effluent monitor valuespresented in EALsRA1.1, RSI.1 andRG1.1 should be usedfor emergency classification assessments until theresults from a doseThe classification timeliness note has been standardized across theCPNPP EAL scheme by referencing the "time limit" specified withinthe EAL wording.The classification timeliness note has been standardized across theCPNPP EAL scheme by referencing the "time limit" specified withinthe EAL wording.NoneIncorporated site-specific EAL numbers associated with genericEAL#1.28 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrixassessment using actualmeteorology areavailable.

29 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)AG2 Spent fuel pool level cannot be RG2 Spent fuel pool level cannot be Top of the fuel racks is the site-specific Level 3 description.

restored to at least (site-specific restored to at least the top of the fuelLevel 3 description) for 60 racks for 60 minutes or longerminutes or longer MODE: AllMODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be Post-Fukushima order EA-1 2-051 required the installation ofrestored to at least (site-specific restored to at least El. 835.3' (Level 3) reliable SFP level indication capable of identifying normal levelLevel 3 value) for 60 minutes or for greater than or equal to 60 min. (Level 1), SFP level 10 ft. above the top of the fuel rackslonger (Note 1) (Level 2) and SFP level at the top of the fuel racks (Level 1).Comanche Peak designated as Level 3 the water level greaterthan 1 foot above the top of the fuel storage racks plus theaccuracy of the SFP level instrument channel (El. 835'- 2.75"rounded to 835.3' indicated).

Note The Emergency Director should N/A Note 1: The Emergency Coordinator The classification timeliness note has been standardized declare the General Emergency should declare the event across the CPNPP EAL scheme by referencing the "time limit"promptly upon determining that promptly upon determining specified within the EAL wording.60 minutes has been exceeded, that time limit has beenor will likely be exceeded.

exceeded, or will likely beexceeded.

30 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCategory CCold Shutdown

/ Refueling System Malfunction 31 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification CU1 UNPLANNED loss of (reactor CUl UNPLANNED loss of RCS Nonevessel/RCS

[PWR] or RCP inventory for 15 minutes or[BWR]) inventory for 15 minutes longeror longer. MODE: 5 -Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. CPNPPEAL # NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification 1 UNPLANNED loss of reactor CUI.1 UNPLANNED loss of reactor Nonecoolant results in (reactor coolant results in RCS watervessel/RCS

[PWR] or RCP level less than a required lower[BWR]) level less than a limit for greater than or equal torequired lower limit for 15 15 min. (Note 1)minutes or longer.2 a. (Reactor vessel/RCS

[PWR] CU1.2 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable monitored smsadtnsor RCP [BWR]) level cannot AND EITHER sumps and tanks.be monitored.

Added bulleted criteria "Visual observation of UNISOLABLE RCSAND ° UNPLANNED increase in leakage" to include direct observation of RCS leakage.any Table C-1 sump/tank

b. UNPLANNED increase in level due to loss of RCS(site-specific sump and/or inventory tank) levels.

• Visual observation ofUNISOLABLE RCS leakageNote The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across theshould declare the Unusual Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinEvent promptly upon declare the event the EAL wording.determining that 15 minutes promptly uponhas been exceeded, or will determining that timelikely be exceeded.

limit has beenexceeded, or will likely32 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixI I I be exceeded.II Table C-1 Sumps/Tanks

• Containment Sump 1* Containment Sump 2* Reactor Cavity Sump* CCW Surge Tank A* CCWSurgeTankB

• PRT* RCDT33 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification CU2 Loss of all but one AC power CU2 Loss of all but one AC power "Safeguard" is the site-specific term for emergency buses.source to emergency buses for source to safeguard buses for 1515 minutes or longer. minutes or longer.MODE: Cold Shutdown, MODE: 6 -Cold Shutdown, Refueling, Defueled Refueling, DefueledNE! Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 a. AC power capability to (site- CU2.1 AC power capability, Table C-3, 6.9KV safeguard buses uEA1 and uEA2 are the emergency buses.specific emergency buses) is to 6.9 KV safeguard buses uEA1 Site-specific AC power sources are tabularized in Table C-3.reduced to a single power and uEA2 reduced to a singlesource for 15 minutes or power source for greater than orlonger, equal to 15 min.AND (Note 1)ANDb. Any additional single powersource failure will result in Any additional single Table C-3loss of all AC power toAnadioalsgeTbeC-SAFETY SYSTE MS. power source failure will result inloss of all AC power to SAFETYSYSTEMSNote The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

34 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixTable C-3 AC Power SourcesOffsite:0 138 KV switchyard circuita 345 KV switchyard circuitOnsite:" uEGI" uEG235 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in RCS Nonetemperature temperature MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I UNPLANNED increase in RCS CU3.1 UNPLANNED increase in RCS 200'F is the site-specific Tech. Spec. cold shutdown temperature temperature to greater than (site- temperature to greater than limit.specific Technical Specification 200°F due to loss of decay heat Added "due to loss of decay heat removal capability" to reinforce thecold shutdown temperature limit) removal capability (Note 9) generic bases that states "EAL #1 involves a loss of decay heatremoval capability" 2 Loss of ALL RCS temperature CU3.2 Loss of all RCS temperature and Noneand (reactor vessel/RCS

[PWR] RCS level indication for greateror RCP [BWR]) level indication than or equal to 15 min. (Note 1)for 15 minutes or longer.Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded determining that timelimit has been exceeded, or will likely beexceeded.

N/A N/A N/A Note 9: Begin monitoring hot Added note to remind end-user that the hot condition EALs becomecondition EALs applicable once operating mode changes to hot conditions.

concurrently.

36 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)CU4 Loss of Vital DC power for 15 CU4 Loss of vital DC power for 15 Noneminutes or longer. minutes or longer.MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. NEICPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # NIEapeALWrig EAL #1 Indicated voltage is less than CU4.1 Less than 105 VDC bus voltage 105 VDC is the site-specific minimum vital DC bus voltage.(site-specific bus voltage value) indications on Technical DC operability requirements are specified in Technical on required Vital DC buses for 15 Specification required 125 VDC Specifications.

minutes or longer, buses (uED1, uED2, uED3,uED4) for greater than or equal to15 min. (Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event promptly the EAL wording.15 minutes has been exceeded, upon determining thator will likely be exceeded.

time limit has beenexceeded, or will likely beexceeded.

37 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)CU5 Loss of all onsite or offsite CU5 Loss of all onsite or offsite Nonecommunications capabilities, communications capabilities.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling, Defueled Refueling, DefueledNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I Loss of ALL of the following CU5.1 Loss of all Table C-5 onsite Example EALs #1, 2 and 3 have been combined into a singleonsite communication methods:

communication methods EAL for simplification of presentation.

OR(site specific list of Loss of all Table C-5 offsite Table C-5 provides a site-specific list of onsite, offsite (ORO) andcommunications methods) communication methods NRC communications methods.OR2 Loss of ALL of the following ORO Loss of all Table C-5 NRCcommunications methods:

communication methods(site specific list ofcommunications methods)3 Loss of ALL of the following NRCcommunications methods:(site specific list ofcommunications methods)38 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable C-5 Communication MethodsSystem Onsite Offsite NRCGai-tronics Page/Party (PA) XPlant Radios XPABX X X XPublic Telephone X X XFederal Telephone System (FTS) X X39 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification CA1 Loss of (reactor vessel/RCS CA1 Loss of RCS inventory None[PWR] or RCP [BWR]) inventory MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I Loss of (reactor vessel/RCS CAl. 1 Loss of RCS inventory as RCS level less than 48 in. above upper core plate (top) is the site-[PWR] or RCP [BWR]) inventory indicated by RCS level less than specific reactor vessel level corresponding to potential RHR pumpas indicated by level less than 48 in. above upper core plate cavitation in the shutdown cooling mode..(site-specific level). (top)2 a. (Reactor vessel/RCS

[PWR] CA1.2 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable sumpsor RCP [BWR]) level cannot monitored for greater than or and tanks.be monitored for 15 minutes equal to 15 min. (Note 1) Added bulleted criteria "Visual observation of UNISOLABLE RCSor longer AND EITHER leakage" to include direct observation of RCS leakage.AND 9 UNPLANNED increase inb. UNPLANNED increase in any Table C-1 sump/tank (site-specific sump and/or level due to a loss of RCStank) levels due to a loss of inventory (reactor vessel/RCS

[PWR]

• Visual observation ofor RCP [BWR]) inventory.

UNISOLABLE RCS leakageNote The Emergency Director should N/A Note 1:The Emergency The classification timeliness note has been standardized across thedeclare the Alert promptly upon Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withindetermining that 15 minutes has declare the event the EAL wording.been exceeded, or will likely be promptly uponexceeded determining that timelimit has been exceeded, or will likely beexceeded.

40 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite "Safeguard" is the site-specific term for emergency buses.AC power to emergency buses AC power to safeguard busesfor 15 minutes or longer for 15 minutes or longer.MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling, Defueled Refueling, DefueledNEI Ex. CPNPPEAL # NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification I Loss of ALL offsite and ALL CA2.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC Power to (site-specific AC power capability, Table C-3, emergency buses.emergency buses) for 15 to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table C-3.minutes or longer. uEA1 and uEA2 for greater thanor equal to 15 min. (Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

41 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)CA3 Inability to maintain the plant in CA3 Inability to maintain the plant in Nonecold shutdown.

cold shutdown.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording bifference/Deviation Justification EAL # EAL #1 UNPLANNED increase in RCS UNPLANNED increase in RCS Example EALs #1 and #2 have been combined into a single EALtemperature to greater than temperature to greater than as EAL # is the alternative threshold based on a loss of RCS(site-specific Technical 200OF for greater than Table C- temperature indication.

Specification cold shutdown 4 duration 200'F is the site-specific Tech. Spec. cold shutdown temperature temperature limit) for greater (Note 1, 9) limit.than the duration specified inthan the follo iong tle. Cn OR Table C-4 is the site-specific implementation of the generic RCSthe following table. CA3.1 Heat-up Duration Threshold table.2 UNPLANNED RCS pressure increase greater than 10 psig 10 psig is the site-specific pressure increase readable by Controlincrease greater than (site- due to a loss of RCS cooling Room indications.

specific pressure reading).

(This EAL does not apply(This EAL does not apply during during water-solid plantwater-solid plant conditions, conditions)

[PWR])Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

42 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixN/A N/ANote 9: Begin monitoring hotcondition EALsconcurrently.

Added note to remind end-user that the hot condition EALs becomeapplicable once operating mode changes to hot conditions.

Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up DurationIntact (but not at reduced Not applicable 60 minutes*inventory

[PWR])Not intact (or at reduced Established 20 minutes*inventory

[PWR]) Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature isbeing reduced, the EAL is not applicable.

Table C-4: RCS Heat-up Duration Thresholds RCS Status CONTAINMENT CLOSURE Heat-up DurationStatusIntact (but not REDUCED N/A 60 mi.*INVENTORY)

Not intact Established 20 min.*ORREDUCED INVENTORY Not established 0 min.* If an RCS heat removal system is in operation within this time frame and RCS temperature isbeing reduced, the EAL is not applicable.

43 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)CA6 Hazardous event affecting a CA6 Hazardous event affecting a NoneSAFETY SYSTEM needed for SAFETY SYSTEM needed forthe current operating mode. the current operating mode.MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling 44 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. The occurrence of ANY of CA6.1 The occurrence of any Table The hazardous events have been tabularized in Table C-6.the following hazardous C-6 hazardous event Replaced "Shift Manager" with "Emergency Coordinator" as the EC* Seismic event AND EITHER: can be either the SM or augmented ERO EC.(earthquake) e Event damage has caused* Internal or external intdcation of d adedflooding event indications of degraded*High winds or tornado performance in at least onestrike train of a SAFETY SYSTEMstFIRE needed for the current* EXPLOSION operating mode* (site-specific hazards) e The event has caused* Other events with similar VISIBLE DAMAGE to ahazard characteristics as SAFETY SYSTEMdetermined by the Shift component or structure Manager needed for the currentAND operating modeb. EITHER of the following:

1. Event damage. has causedindications of degradedperformance in at leastone train of a SAFETYSYSTEM needed for thecurrent operating mode.OR2. The event has causedVISIBLE DAMAGE to aSAFETY SYSTEMcomponent or structure needed for the currentoperating mode.45 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable C-6 Hazardous Events* Seismic event (earthquake)

• Internal or external FLOODING event* High winds or tornado strike* FIRE* EXPLOSION

• Other events with similar hazard characteristics as determined by the Emergency Coordinator 46 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)CS1 Loss of (reactor vessel/RCS CS1 Loss of RCS inventory affecting None[PWR] or RCP [BWR]) inventory core decay heat removalaffecting core decay heat capability removal capability.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 a. CONTAINMENT CLOSURE CS1.1 With CONTAINMENT When RCS level less than 27.25 in. (rounded to 27.3 for instrument not established.

CLOSURE not established, readability) above upper core plate (top), water level is six inchesAND RCS level less than 27.3 in. below the elevation of the bottom of the RCS hot leg penetration.

above upper core plate (top)b. (Reactor vessel/RCS

[PWR]or RCP [BWR]) level less than(site-specific level).2 a. CONTAINMENT CLOSURE CS1.2 With CONTAINMENT When Reactor Vessel water level drops to or below 0 in. above upperestablished.

CLOSURE established, RCS core plate (top) 823'-0" elevation, core uncovery is about to occur.AND level less than or equal to 0 in.above upper core plate (top)b. (Reactor vessel/RCS

[PWR]or RCP [BWR]) level less than(site-specific level).3 a. (Reactor vessel/RCS

[PWR] CS1.3 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable sumpsor RCP [BWR]) level cannot monitored for greater than or and tanks.be monitored for 30 minutes equal to 30 mn. (Note 1) Containment HRRM greater than 20,000 mR/hr would be indicative AND Core. uNce iof possible core uncovery in the Refueling mode.AND Core uncovery is indicated byany of the following:

b. Core uncovery is indicated by

• UNPLANNED increase inANY of the following:

any Table C-1 sump/tank 47 of 114 Attachment 2 to TXX-1 5101EAL Comparison Matrix" (Site-specific radiation monitor) reading greaterthan (site-specific value)" Erratic source rangemonitor indication

[PWR]" UNPLANNED increase in(site-specific sump and/ortank) levels of sufficient magnitude to indicatecore uncovery" (Other site-specific indications) level of sufficient magnitude to indicate core uncovery* Erratic Source RangeMonitor indication

• greater than 20,000 R/hr onany of the following:

-CTEu16, Containment HRRM (u-RE-6290A)

-CTWu17, Containment HRRM (u-RE-6290B)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Site Area Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinEmergency promptly upon declare the event the EAL wording.determining that 30 minutes has promptly uponbeen exceeded, or will likely be determining that timeexceeded limit has beenexceeded, or will likelybe exceeded.

48 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification Loss of (reactor vessel/RCS

[PWR] or RCP [BWR]) inventory affecting fuel clad integrity withcontainment challenged MODE: Cold Shutdown, Refueling CG1Loss of RCS inventory affecting fuel clad integrity withcontainment challenged MODE: Cold Shutdown, Refueling NoneNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL IIEAL #a. (Reactor vessel/RCS

[PWR] or CGI.1 RCS level less than or equal to 0 When Reactor Vessel water level drops to or below 0 in. aboveRCP [BWR]) level less than in. above upper core plate (top) upper core plate (top) 823'-0" elevation, core uncovery is about to(site-specific level) for 30 for greater than or equal to 30 occur.minutes or longer. min. (Note 1)AND AND Table C-2 provides a tabularized list of containment challenge

b. ANY indication from the indications.

Containment Challenge Table Any Containment Challenge (see below), indication, Table C-22 a. (Reactor vessel/RCS

[PWR] or CG1.2 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable RCP [BWR]) level cannot be monitored for greater than or sumps and tanks.monitored for 30 minutes or equal to 30 min. (Note 1) Containment HRRM greater than 20,000 mR/hr would be indicative longer. AND of possible core uncovery in the Refueling mode.AND Core uncovery is indicated byany of the following:

Table C-2 provides a tabularized list of containment challenge

b. Core uncovery is indicated by UNPLANNED increase indications.

ANY of the following:

in any Table C-1 4% hydrogen concentration in the presence of oxygen represents 0 (Site-specific radiation sump/tank level of an explosive mixture in containment.

monitor) reading greater sufficient magnitude to Specified a 1 psig pressure rise as minimum observable than (site-specific value) indicate core uncovery containment pressure increase.

• Erratic source range Erratic Source Rangemonitor indication

[PWR] Monitor indication

• UNPLANNED increase in Greater than 20,000 R/hr49 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrix(site-specific sump and/ortank) levels of sufficient magnitude to indicate coreuncoverye (Other site-specific indications)

ANDc. ANY indication from theContainment Challenge Table(see below).on any of the following:

-CTEu16, Containment HRRM (u-RE-6290A)

-CTWu17, Containment HRRM (u-RE-6290B)

ANDAny Containment Challenge indication, Table C-2NoteThe Emergency Director shoulddeclare the General Emergency promptly upon determining that30 minutes has been exceeded, or will likely be exceeded.

N/AN/ANote 1: The Emergency Coordinator shoulddeclare the eventpromptly upondetermining that time limithas been exceeded, orwill likely be exceeded.

Note 6: If CONTAINMENT CLOSURE is re-established prior toexceeding the 30-minute time limit, declaration of aGeneral Emergency isnot required.

The classification timeliness note has been standardized acrossthe CPNPP EAL scheme by referencing the "time limit" specified within the EAL wording.Note 6 implements the asterisked note associated with the genericContainment Challenge table.Containment Challenge Table" CONTAINMENT CLOSURE not established*

• (Explosive mixture) exists inside containment

• UNPLANNED increase in containment pressureE Secondary containment radiation monitor reading above (site-specific value) [BWR]* If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

50 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable C-2 Containment Challenge Indications

• CONTAINMENT CLOSURE not established (Note 6)" Containment hydrogen concentration greater than 4%* Unplanned rise greater than 1 psig in Containment pressure51 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCategory DPermanently Defueled Station Malfunction 52 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)PD-AU1 Recognition Category D N/A N/A NEI Recognition Category PD ICs and EALs are applicable only toPD-AU2 Permanently Defueled Station permanently defueled stations.

CPNPP is not a defueled station.PD-SU1PD-HU1PD-HU2PD-HU3PD-AA1PD-AA2PD-HA1PD-HA353 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCategory EIndependent Spent Fuel Storage Installation 54 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask NoneCONFINEMENT BOUNDARY CONFINEMENT BOUNDARYMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I Damage to a loaded cask EU1.1 Damage to a loaded cask The specified dose rate represents 2 times the cask technical CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY specification allowable levels per the ISFSI Technical Specifications indicated by an on-contact as indicated by an on-contact (CoC).radiation reading greater than (2 radiation reading greater thantimes the site-specific cask EITHER:specific technical specification allowable radiation level) on the t 60 mrem/hr (v + rp) on thesurface of the spent fuel cask. top of the overpacko 600 mrem/hr (-r + rj on theside of the overpack(excluding inlet and outletducts)55 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCategory FFission Product Barrier Degradation 56 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)FAl Any Loss or any Potential Loss of FA1 Any loss or any potential loss of Noneeither the Fuel Clad or RCS either Fuel Clad or RCSbarrier.

MODE: 1 -Power Operation, 2 -MODE: Power Operation, Hot Startup, 3 -Hot Standby, 4 -HotStandby,

Startup, Hot Shutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Any Loss or any Potential Loss FAI.1 Any loss or any potential loss of Table F-1 provides the fission product barrier loss and potential lossof either the Fuel Clad or RCS either Fuel Clad or RCS (Table thresholds.

barrier.

F-i)57 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)FS1 Loss or Potential Loss of any two FS1 Loss or potential loss of any two Nonebarriers barriersMODE: Power Operation, Hot MODE: 1 -Power Operation, 2 -Standby,

Startup, Hot Shutdown

Startup, 3 -Hot Standby, 4 -HotShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss or Potential Loss of any two FS1.1 Loss or potential loss of any two Table F-1 provides the fission product barrier loss and potential lossbarriers barriers thresholds.

58 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)FG1 Loss of any two barriers and FG1 Loss of any two barriers and loss NoneLoss or Potential Loss of third or potential loss of the thirdbarrier barrierMODE: Power Operation, Hot MODE: 1 -Power Operation, 2 -Standby,

Startup, Hot Shutdown

Startup, 3 -Hot Standby, 4 -HotShutdownNEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL #Loss of any two barriers and FG1.1 Loss of any two barriers Table F-1 provides the fission product barrier loss and potential lossLoss or Potential Loss of third thresholds.

barrier ANDLoss or potential loss of the thirdbarrier (Table F-i)59 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixPWR Fuel Clad Fission Product Barrier Degradation Thresholds NEI CPNPPNEI NEI Threshold Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss RCS or SG Tube Leakage N/A N/A N/A1 Not Applicable FC Loss Inadequate Heat Removal FC Loss CSFST Core Cooling-RED Consistent with the generic developers note options CSFST Core2 A. Core exit thermocouple 1.1 Path conditions met Cooling Red Path is used in lieu of CET temperatures.

readings greater than (site-specific temperature value).FC Loss RCS Activity/CMNT Rad FC Loss Containment radiation greater CTEu16 Containment HRRM (u-RE-6290A) or CTWu17than 85 R/hr Containment HRRM (u4-RE-6290B) are the site-specific containment 3 A. Containment radiation C.1 CTEu16 Containment HRRM high range radiation monitors.

The specified monitors and valuesmonitor reading greater than (u-RE-6290A),

or are containment radiation monitor readings corresponding to 2%(site-specific value) CTWuI 7 Containment HRRM clad failures.

OR (u-RE-6290B)

B. (Site-specific indications that reactor coolant activity isgreater than 300 l.LCi/gm dose FC Loss Dose equivalent 1-131 coolant Site-specific units for DEl is pCi/cc.equivalent 1-131) C.2 activity greater than 300 pCi/ccFC Loss CNMT Integrity or Bypass N/A N/A N/A4 Not Applicable FC Loss Other Indications FC Loss Gross Failed Fuel Monitor, The Gross Failed Fuel Monitor threshold of 1.0E04 pCi/mlA. (site-specific as applicable)

C.3 FFLju60 (u_-RE-0406),

radiation represents approximately 2% fuel clad failure.greater than I.0E04 pCi/ml60 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNE! CPNPPNPI NEI Threshold Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss ED Judgment FC Loss Any condition in the opinion of Nonethe Emergency Coordinator A. ANY condition in the E.1 that indicates loss of the fuelopinion of the Emergency ca areDirector that indicates Loss of clad barrierthe Fuel Clad Barrier.FC RCS or SG Tube Leakage N/A N/A See FC P-Loss B.1. The RCS level threshold is implemented asP-Loss A. RCS/reactor vessel level CSFST Core Cooling Orange Path conditions met.1 less than (site-specific level)FC Inadequate Heat Removal FC CSFST Core Cooling-Consistent with the generic developers note options CSFST CoreP-Loss P-Loss ORANGE Path conditions met Cooling Orange Path is used in lieu of CET temperatures.

P-os A. Core exit thermocouple B.12 readings greater than (site-specific temperature value)OR FC CSFST Heat Sink-RED Path Consistent with the generic developers note options CSFST HeatB. Inadequate RCS heat P-Loss conditions met Sink Red Path is used.removal capability via steam B.2 ANDThe phrase "and heat sink required" was added to preclude thegenerators as indicated by Heat sink is required need for classification for conditions in which RCS pressure is less(site-specific indications).

than SG pressure or Heat Sink-RED path entry was createdthrough operator action directed by an EOP.FC RCS Activity/CMNT Rad N/A N/A N/AP-LossNot Applicable 3FC CNMT Integrity or Bypass N/A N/A N/AP-Loss Not Applicable 4FC Other Indications N/A N/A No other site-specific Fuel Clad Potential Loss indication has beenP-Loss identified for CPNPP.A. (site-specific as applicable) 561 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI CPNPPFPB NEI Threshold Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Emergency Director FC Any condition in the opinion of NoneP-Loss Judgment P-Loss the Emergency Coordinator thatE.1 indicates potential loss of the6 A. Any condition in the opinion fuel clad barrierof the Emergency Director thatindicates Potential Loss of theFuel Clad Barrier.62 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixPWR RCS Fission Product Barrier Degradation Thresholds NEI CPNPPNEI NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FP13 #(s)RCS RCS or SG Tube Leakage RCS Loss An automatic or manual NoneLoss A. An automatic or manual A.1 ECCS (SI) actuation requiredI ECCS (SI) actuation is by EITHER:required by EITHER of the

• UNISOLABLE RCSfollowing:

leakage1. UNISOLABLE RCS

• SG tube RUPTUREleakageOR2. SG tube RUPTURE.RCS Inadequate Heat Removal N/A N/A N/ALoss Not Applicable 2RCS RCS Activity/CMNT Rad RCS Loss Containment radiation greater CTEu16 Containment HRRM (u-RE-6290A) or CTWu17Loss A. Containment radiation C.1 than 5 R/hr Containment HRRM (u-RE-6290B) are the site-specific 3 monitor reading greater than CTEu16 Containment HRRM containment high range radiation monitors.

The specified monitors(site-specific value). (nu-RE-6290A),

or and values are containment radiation monitor readingsCTWu17 Containment HRRM corresponding to TS limit coolant activity.

(u-RE-6290B)

RCS CNMT Integrity or Bypass N/A N/A N/ALoss Not Applicable 4RCS Other Indications N/A N/A No other site-specific RCS Loss indication has been identified forLoss CPNPP.A. (site-specific as applicable) 563 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI CPNPPNEI NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS Emergency Director Judgment RCS Loss Any condition in the opinion NoneLoss Aof the Emergency Coordinator Los A. ANY condition in the opinion E.1 that indicates loss of the RCS6 of the Emergency Director that barrierindicates Loss of the RCSBarrier.RCS RCS or SG Tube Leakage RCS Operation of a standby NoneP-Loss 1 A. Operation of a standby P-Loss A.1 charging pump is required bycharging (makeup) pump is EITHER:required by EITHER of the 9 UNISOLABLE RCSfollowing:

leakage1. UNISOLABLE RCS

• SG tube leakageleakageOR RCS CSFST Integrity-RED Path Consistent with the generic developers note options CSFST2. SG tube leakage.

P-Loss A.2 conditions met Integrity Red Path is used.ORB. RCS cooldown rate greaterthan (site-specific pressurized thermal shockcriteria/limits defined by site-specific indications).

RCS Inadequate Heat Removal RCS CSFST Heat Sink-RED Path Consistent with the generic developers note options CSFST HeatP-Loss B.1 conditions met Sink Red Path is used.P-Loss 2 A. Inadequate RCS heat ANDremoval capability via steam The phrase "and heat sink required" was added to preclude thegenerators as indicated by Heat sink is required need for classification for conditions in which RCS pressure is less(site-specific indications),

than SG pressure or Heat Sink-RED path entry was createdthrough operator action directed by an EOP.RCS CS Activity/IMNT Rad N/A N/A N/AP-Loss 3 Not Applicable 64 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEIFPB# NEI IC WordingRCS CNMT Integrity or BypassP-Loss 4 Not Applicable RCS Other Indications P-Loss 5 A. (site-specific as applicable)

CPNPP FPB Wording Difference/Deviation Justification N/A N/AN/A No other site-specific RCS Potential Loss indication has beenidentified for CPNPP.RCSP-Loss 6Emergency Director JudgmentA. ANY condition in the opinionof the Emergency Director thatindicates Potential Loss of theRCS Barrier.RCSP-Loss E.1Any condition in the opinion ofthe Emergency Coordinator thatindicates potential loss of theRCS barrierNone65 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixPWR Containment Fission Product Barrier Degradation Thresholds NEI CPNPPNEI NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)CNMT RCS or SG Tube Leakage CNTMT A leaking or RUPTURED SG is NoneLoss A Loss FAULTED outside of containment A. A leaking or RUPTURED SG is1 FAULTED outside of containment.

A.1CNMT Inadequate Heat Removal N/A N/A N/ALoss Not Applicable 2CNMT RCS Activity/CMNT Rad N/A N/A N/ALoss Not applicable 3CNMTLoss4CNMT Integrity or BypassA. Containment isolation is requiredANDEITHER of the following:

1. Containment integrity has beenlost based on Emergency Director judgment.

OR2. UNISOLABLE pathway fromthe containment to theenvironment exists.ORB. Indications of RCS leakage outsideof containment.

CNTMTLossD.1Containment isolation is requiredAND EITHER:" Containment integrity has beenlost based on Emergency Coordinator judgment* UNISOLABLE pathway fromContainment to the environment existsNoneCNTMTLossD.2Indications of RCS leakage outside ofcontainment None66 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNE! CPNPPFPB NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)CNMT Other Indications N/A N/A No other site-specific Containment Loss indication hasLoss been identified for CPNPP.A. (site-specific as applicable) 5CNMT Emergency Director Judgment CNTMT Any condition in the opinion of the NoneLoss ANY condition in the opinion of the Loss Emergency Coordinator that indicates 6 NYcntinnthopnoofteloss of the containment barrierEmergency Director that indicates Loss E.1of the Containment Barrier.CNMT RCS or SG Tube Leakage N/A N/A N/AP-Loss Not Applicable CNMT Inadequate Heat Removal CNTMT CSFST Core Cooling-RED Path Consistent with the generic developers note optionsP-Loss P-Loss conditions met CSFST Core Cooling Red Path is used in lieu of CETA. 1. (Site-specific criteria for entry AND temperatures and RCS levels.2 into core cooling restoration B.1procedure)

Restoration procedures not effective Added Note 1 consistent with other thresholds with awithin 15 min. (Note 1) timing component.

AND2. Restoration procedure noteffective within 15 minutes.CNMT RCS Activity/CMNT Rad CNTMT Containment radiation greater than CTEu16 Containment HRRM (u-RE-6290A) orP-Loss A. Containment radiation monitor P-Loss 1,110 R/hr CTWu17 Containment HRRM (u-RE-6290B) are the3 reading greater than (site-specific C. CTEu16 Containment HRRM (u-RE- site-specific containment high range radiation value). 6290A), or monitors.

The specified monitors and values areCTWu17 Containment HRRM (u-RE- containment radiation monitor readings corresponding 6290B) to 20% clad damage.CNMT CNTMT Integrity or Bypass CNTMT CSFST Containment-RED Path Consistent with the generic developers note optionsP-Loss A. Containment pressure greater than P-Loss conditions met CSFST Containment Red Path is used in lieu of4 (site-specific value) D.1 containment pressure.

67 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI CPNPPNEB NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)OR CNTMT Containment hydrogen concentration 4% hydrogen concentration in the presence of oxygenB. Explosive mixture exists inside P-Loss greater than 4% represents an explosive mixture in containment.

containment D.2ORC. 1. Containment pressure greaterthan (site-specific pressuresetpoint)

CNTMT Containment pressure greater than 18 The Containment pressure setpoint (18 psig) is theAND P-Loss psig with neither Containment Spray pressure at which the Containment Spray System2. Less than one full train of (site- D.3 system train operating per design for should actuate and begin performing its function.

specific system or equipment) greater than or equal to 15 min. (Note Added Note 1 consistent with other thresholds with ais operating per design for 15 1 timing component.

minutes or longer.CNMT Other Indications N/A N/A No other site-specific Containment Potential LossP-Loss indication has been identified for CPNPP.A. (site-specific as applicable) 5CNMT Emergency Director Judgment CNTMT Any condition in the opinion of the NoneP-Loss A. ANY condition in the opinion of the P-Loss Emergency Coordinator that indicates 6 Emergency Director that indicates E.1 potential loss of the containment Potential Loss of the Containment barrierBarrier.68 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCategory HHazards and Other Conditions Affecting Plant Safety69 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI CPNPPNEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification IC# IC#(s)HU1 Confirmed SECURITY HU1 Confirmed SECURITY NoneCONDITION or threat CONDITION or threat.MODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 A SECURITY CONDITION that HU1.1 A SECURITY CONDITION that The security shift supervision is defined as the Security Shiftdoes not involve a HOSTILE does not involve a HOSTILE Supervisor ACTION as reported by the (site- ACTION as reported by thespecific security shift supervision).

Security Shift Supervisor 2 Notification of a credible security HU1.2 Notification of a credible security Nonethreat directed at the site. threat directed at the site3 A validated notification from the HU1.3 A validated notification from the NoneNRC providing information of an NRC providing information of anaircraft threat. aircraft threat70 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE Nonelevel levelMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Seismic event greater than HU2.1 Seismic event greater than OBE The CPNPP OBE indicators are either annunciator 2A-3.1, OBEOperating Basis Earthquake as indicated by annunciator 2A- EXCEEDED, or yellow OBE light on Seismic Monitoring system(OBE) as indicated by: ' 3.1, OBE EXCEEDED, or yellow panel(site-specific indication that a OBE light on Seismic Monitoring seismic event met or exceeded system panelOBE limits)71 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)HU3 Hazardous event. HU3 Hazardous event NoneMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 A tornado strike within the HU3.1 A tornado strike within the NonePROTECTED AREA. PROTECTED AREA2 Internal room or area flooding of a HU3.2 Internal room or area FLOODING Nonemagnitude sufficient to require of a magnitude sufficient tomanual or automatic electrical require manual or automatic isolation of a SAFETY SYSTEM electrical isolation of a SAFETYcomponent needed for the current SYSTEM component needed foroperating mode. the current operating mode3 Movement of personnel within the HU3.3 Movement of personnel within the NonePROTECTED AREA is impeded PROTECTED AREA isdue to an offsite event involving IMPEDED due to an offsite eventhazardous materials (e.g., an involving hazardous materials offsite chemical spill or toxic gas (e.g., an offsite chemical spill orrelease).

toxic gas release)4 A hazardous event that results in HU3.4 A hazardous event that results in Added reference to Note 7.on-site conditions sufficient to on-site conditions sufficient toprohibit the plant staff from prohibit the plant staff fromaccessing the site via personal accessing the site via personalvehicles.

vehicles (Note 7)5 (Site-specific list of natural or N/A N/A No other site-specific hazard has been identified for CPNPP.technological hazard events)Note EAL #3 does not apply to routine N/A Note 7: This EAL does not This note, designated Note #7, is intended to apply to generictraffic impediments such as fog, apply to routine traffic example EAL #4, not #3 as specified in the generic guidance.

72 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrixsnow, ice, or vehicle breakdowns impediments such asor accidents.

fog, snow, ice, orvehicle breakdowns oraccidents.

73 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HU4 FIRE potentially degrading the HU4 FIRE potentially degrading the Nonelevel of safety of the plant. level of safety of the plantMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. A FIRE is NOT extinguished HU4.1 A FIRE is not extinguished Table H-1 provides a tabularized list of site-specific fire areas.within 15-minutes of ANY of the within 15 min. of any of thefollowing FIRE detection following FIRE detection indications:

indications (Note 1):" Report from the field (i.e.,

• Report from the field (i.e.,visual observation) visual observation)

" Receipt of multiple (more e Receipt of multiple (morethan 1) fire alarms or than 1) fire alarms orindications indications

" Field verification of a single

• Field verification of a singlefire alarm fire alarmAND ANDb. The FIRE is located within The FIRE is located within anyANY of the following plant rooms Table H-1 areaor areas:(site-specific list of plant rooms orareas)2 a. Receipt of a single fire alarm HU4.2 Receipt of a single fire alarm Table H-1 provides a tabularized list of site-specific fire areas.(i.e., no other indications of a (i.e., no other indications of aFIRE). FIRE)AND ANDI b. The FIRE is located within The fire alarm is indicating a74 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixANY of the following plant rooms FIRE within any Table H-1 areaor areas: AND(site-specific list of plant rooms or The existence of a FIRE is notareas) verified within 30 min. of alarmAND receipt (Note 1)c. The existence of a FIRE isnot verified within 30-minutes ofalarm receipt.3 A FIRE within the plant or ISFSI HU4.3 A FIRE within the ISFSI or plant CPNPP has an ISFSI located outside the plant Protected Area.[for plants with an ISFSI outside PROTECTED AREA notthe plant Protected Area] extinguished within 60 min. ofPROTECTED AREA not the initial report, alarm orextinguished within 60-minutes of indication (Note 1)the initial report, alarm orindication.

4 A FIRE within the plant or ISFSI HU4.4 A FIRE within the ISFSI or plant CPNPP has an ISFSI located outside the plant Protected Area.[for plants with an ISFSI outside PROTECTED AREA thatthe plant Protected Area] requires firefighting support byPROTECTED AREA that requires an offsite fire response agencyfirefighting support by an offsite to extinguish fire response agency toextinguish.

Note Note: The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across theshould declare the Unusual Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinEvent promptly upon determining declare the event the EAL wording.that the applicable time has been promptly uponexceeded, or will likely be determining that timeexceeded.

limit has been exceeded, or will likely beexceeded.

75 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixTable H-1 Fire Areasu-Containment Su--Safeguards Building* X-Auxiliary Building* X-Electrical

& Control Building* X-Fuel Building* X-Service Water Intake Structure

• u-Diesel Generator Building* u-Normal Switchgear Rooms* u-CST* u-RWST76 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HU7 Other conditions exist which in HU7 Other conditions existing that in Nonethe judgment of the Emergency the judgment of the Emergency Director warrant declaration of a Coordinator warrant declaration (NO)UE of a UEMODE: All MODE: AllNEI Ex. CPNPPEA E NEI Example EAL Wording EAL CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in HU7.1 Other conditions exist which in Nonethe judgment of the Emergency the judgment of the Emergency Director indicate that events are Coordinator indicate that eventsin progress or have occurred are in progress or have occurredwhich indicate a potential which indicate a potential degradation of the level of safety degradation of the level of safetyof the plant or indicate a security of the plant or indicate a securitythreat to facility protection has threat to facility protection hasbeen initiated.

No releases of been initiated.

No releases ofradioactive material requiring radioactive material requiring offsite response or monitoring are offsite response or monitoring expected unless further are expected unless furtherdegradation of safety systems degradation of SAFETYoccurs. SYSTEMS occurs.77 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HA1 HOSTILE ACTION within the HA1 HOSTILE ACTION within the NoneOWNER CONTROLLED AREA or OWNER CONTROLLED AREAairborne attack threat within 30 or airborne attack threat within 30minutes.

minutesMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is The security shift supervision is defined as the Security Shifthas occurred within the OWNER occurring or has occurred within Supervisor CONTROLLED AREA as reported the OWNER CONTROLLED by the (site-specific security shift AREA as reported by thesupervision).

Security Shift Supervisor 2 A validated notification from NRC of HA1.2 A validated notification from NoneNRC of an aircraft attackan aircraft attack threat within 30 trean 30rcraf theminutesthreat within 30 min. of theminuts ofthe ite.site78 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HA5 Gaseous release impeding HA5 Gaseous release IMPEDING Noneaccess to equipment necessary access to equipment necessary for normal plant operations, for normal plant operations, cooldown or shutdown.

cooldown or shutdownMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. Release of a toxic, corrosive, HA5.1 Release of a toxic, corrosive, The list of plant rooms or areas with entry-related modeasphyxiant or flammable gas asphyxiant or flammable gas into applicability identified specify those rooms or areas that containinto any of the following plant any Table H-2 rooms or areas equipment which require a manual/local action as specified inrooms or areas: AND operating procedures used for normal plant operation, cooldownAND and shutdown.

(site-specific list of plantrooms or areas with entry- Entry into the room or area is The control room has adequate protection from hazardous gases.related mode applicability prohibited or IMPEDED (Note 5)identified)

ANDb.Entry into the room or area isprohibited or impeded.NoteNote: If the equipment in thelisted room or area was alreadyinoperable or out-of-service before the event occurred, thenno emergency classification iswarranted.

N/ANote 5: If the equipment in thelisted room or area wasalready inoperable or out-of-service before theevent occurred, then noemergency classification is warranted.

None79 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable H-2 Safe Operation

& Shutdown Rooms/Areas Room/Area Mode Applicability Charging Pump Rooms 1,2, 3, 4, 5, 6CVCS Valve Rooms 1,2,3,4,5,6 1E Switchgear Rooms AllRHR Pump Rooms 4,5,680 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HA6 Control Room evacuation HA6 Control Room evacuation Noneresulting in transfer of plant resulting in transfer of plantcontrol to alternate locations, control to alternate locations MODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I An event has resulted in plant HA6.1 An event has resulted in plant Remote Shutdown Panel (RSP) is the site-specific remote shutdowncontrol being transferred from the control being transferred from the panels/local control stations.

Control Room to (site-specific Control Room to the Remoteremote shutdown panels and Shutdown Panel (RSP)local control stations).

81 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HA7 Other conditions exist which in the HA7 Other conditions exist that in the Nonejudgment of the Emergency Director judgment of the Emergency Coordinator warrant declaration of an Alert. warrant declaration of an AlertMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Other conditions exist which, in the HA7.1 Other conditions exist which, in the Nonejudgment of the Emergency

Director, judgment of the Emergency Coordinator, indicate that events are in progress or indicate that events are in progress orhave occurred which involve an actual or have occurred which involve an actual orpotential substantial degradation of the potential substantial degradation of thelevel of safety of the plant or a security level of safety of the plant or a securityevent that involves probable life event that involves probable lifethreatening risk to site personnel or threatening risk to site personnel ordamage to site equipment because of damage to site equipment because ofHOSTILE ACTION. Any releases are HOSTILE ACTION. Any releases areexpected to be limited to small fractions expected to be limited to small fractions of the EPA Protective Action Guideline of the EPA Protective Action Guideline exposure levels, exposure levels.82 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HS1 HOSTILE ACTION within the HS1 HOSTILE ACTION within the NonePROTECTED AREA PROTECTED AREAMODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The security shift supervision is defined as the Security Shiftor has occurred within the occurred within the PROTECTED AREA Supervisor PROTECTED AREA as reported as reported by the Security Shiftby the (site-specific security shift Supervisor supervision).

83 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HS6 Inability to control a key safety HS6 Inability to control a key safety function Nonefunction from outside the Control from outside the Control RoomRoom.MODE: All MODE: AllNEI Ex. CPNPPEAL # NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification 1 a. An event has resulted in plant HS6.1 An event has resulted in plant control Remote Shutdown Panel (RSP) is the site-specific remotecontrol being transferred from the being transferred from the Control Room shutdown panels/local control stations.

Control Room to (site-specific to the Auxiliary Shutdown Panel (RSP)remote shutdown panels and local ANDcontrol stations).

AND Control of any of the following key safetyfunctions is not reestablished within 15b. Control of ANY of the min. (Note 1):following key safety functions isnot reestablished within (site-specific number of minutes).

• Core cooling" Reactivity control e RCS heat removal" Core cooling [PWR] / RCPwater level [BWR]* RCS heat removal84 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HS7 Other conditions exist which in HS7 Other conditions existing that in the Nonethe judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of a warrant declaration of a Site AreaSite Area Emergency.

Emergency MODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I Other conditions exist which in HS7.1 Other conditions exist which in the Replaced "site boundary" with "EXCLUSION AREAthe judgment of the Emergency judgment of the Emergency Coordinator BOUNDARY".

Director indicate that events are indicate that events are in progress or EXCLUSION AREA BOUNDARY is a synonymous term forin progress or have occurred have occurred which involve actual or site boundary.

CPNPP FSAR Section 2.1.1.3 and Figure 2.1-which involve actual or likely likely major failures of plant functions 2 define the Exclusion Area Boundary.

This boundary ismajor failures of plant functions needed for protection of the public or used for establishing effluent release limits with respect toneeded for protection of the HOSTILE ACTION that results in the requirements of 1OCFR20.

See also CPNPP Emergency public or HOSTILE ACTION that intentional damage or malicious acts, (1) Plan Appendix E, Complex and Owner Controlled Area andresults in intentional damage or toward site personnel or equipment that CCNPP ODCM Section 5.0 Design Features.

malicious acts, (1) toward site could lead to the likely failure of or, (2)personnel or equipment that that prevent effective access tocould lead to the likely failure of equipment needed for the protection ofor, (2) that prevent effective the public. Any releases are notaccess to equipment needed for expected to result in exposure levelsthe protection of the public. Any which exceed EPA Protective Actionreleases are not expected to Guideline exposure levels beyond theresult in exposure levels which EXCLUSION AREA BOUNDARY.

exceed EPA Protective ActionGuideline exposure levelsbeyond the site boundary.

85 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification HG1 HOSTILE ACTION resulting in HG1 HOSTILE ACTION resulting in loss of Noneloss of physical control of the physical control of the facilityfacility.

MODE: AllMODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 a. A HOSTILE ACTION is HG1.1 A HOSTILE ACTION is occurring or has The security shift supervision is defined as the Security Shiftoccurring or has occurred within occurred within the PROTECTED AREA Supervisor the PROTECTED AREA as as reported by the Security Shiftreported by the (site-specific Supervisor security shift supervision).

AND EITHER of the following hasAND occurred:

b. EITHER of the following has One or more of the following safetyoccurred:

functions cannot be controlled or1. ANY of the following safety maintained functions cannot be

• Reactivity controlcontrolled or maintained.

• Core cooling" Reactivity control

• RCS heat removal" Core cooling OR[PWR]/RCP waterlevel [BWR] Damage to spent fuel has occurred* RCS heat removal or is IMMINENTOR2. Damage to spent fuel hasoccurred or is IMMINENT.

86 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)HG7 Other conditions exist which in HG7 Other conditions exist which in the Nonethe judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of a warrant declaration of a GeneralGeneral Emergency Emergency MODE: All MODE: AllNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in HG7.1 Other conditions exist which in the Nonethe judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are indicate that events are in progress orin progress or have occurred have occurred which involve actual orwhich involve actual or IMMINENT substantial core degradation IMMINENT substantial core or melting with potential for loss ofdegradation or melting with containment integrity or HOSTILEpotential for loss of containment ACTION that results in an actual loss ofintegrity or HOSTILE ACTION physical control of the facility.

Releasesthat results in an actual loss of can be reasonably expected to exceedphysical control of the facility.

EPA Protective Action Guideline Releases can be reasonably exposure levels offsite for more than theexpected to exceed EPA immediate site area.Protective Action Guideline exposure levels offsite for morethan the immediate site area.87 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCategory SSystem Malfunction 88 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording lC#(s) CPNPP IC Wording Difference/Deviation Justification SU1 Loss of all offsite AC power SU1 Loss of all offsite AC power "Safeguard" is the site-specific term for emergency buses.capability to emergency buses for capability to safeguard buses for15 minutes or longer. 15 minutes or longerMODE: Power Operation,

Startup, MODE: 1 -Power Operation, 2 -Hot Standby, Hot Shutdown

Startup, 3 -Hot Standby, 4 -HotShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of ALL offsite AC power SUI.1 Loss of all offsite AC power 6.9KV safeguard buses uEA1 and uEA2 are the site-specific capability to (site-specific capability, Table S-1, to 6.9 KV emergency buses.emergency buses) for 15 minutes safeguard buses uEA1 and uEA2 Site-specific AC power sources are tabularized in Table S-1.or longer, for greater than or equal to 15min. (Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

Table S-1 AC Power SourcesOffsite:* 138 KV switchyard circuit* 345 KV switchyard circuitOnsite:* uEG1* uEG289 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SU2 UNPLANNED loss of Control SU3 UNPLANNED loss of Control NoneRoom indications for 15 minutes Room indications for 15 minutesor longer, or longer.MODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPN PP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 An UNPLANNED event results in SU3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Tablethe inability to monitor one or the inability to monitor one or S-2.more of the following parameters more Table S-2 parameters from Added the words "to at least one S/G" to Auxiliary or emergency from within the Control Room for within the Control Room for feedwater flow. This is consistent with Level in at least one S/G.15 minutes or longer, greater than or equal to 15 m fin.(Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL-scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has been exceeded, or will likely beexceeded.

90 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrix[BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRCP Water Level RCS LevelRCP Pressure RCS PressurePrimary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number)steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water FlowTable S-2 Safety System Parameters

• Reactor power* RCS level* RCS pressure* Core Exit TIC temperature

• Level in at least one SG* Auxiliary or emergency feed flow in at leastone SG91 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)SU3 Reactor coolant activity greater SU4 Reactor coolant activity greater Nonethan Technical Specification than Technical Specification allowable limits, allowable limitsMODE: Power Operation,

Startup, MODE: 1 -Power Operation, 2 -Hot Standby, Hot Shutdown

Startup, 3 -Hot Standby, 4 -HotShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 (Site-specific radiation monitor)

SU4.2 Gross Failed Fuel Monitor, The High Alarm (RED) setpoint is based on the Technical reading greater than (site-specific FFLu60 (u-RE-0406),

High Alarm Specifications maximum allowable concentration of radioactivity invalue). (RED) the reactor coolant, 87 pCi/gm.2 Sample analysis indicates that a SU4.1 Reactor coolant Dose Equivalent CPNPP T.S. Section 3.4.16 provides the TS allowable coolantreactor coolant activity value is 1-131 specific activity greater than activity limits.greater than an allowable limit 60 pCi/gmspecified in Technical ORSpecifications.

Reactor coolant Dose Equivalent XE-133 specific activity greaterthan 500 pCi/gm92.of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SU4 RCS leakage for 15 minutes or SU5 RCS leakage for 15 minutes or Nonelonger. longerMODE: Power Operation, MODE: I -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #I RCS unidentified or pressure SU5.1 RCS unidentified or pressure Example EALs #1, 2 and 3 have been combined into a single EALboundary leakage greater than boundary leakage greater than for usability.

(site-specific value) for 15 10 gpm for greater than or equal Added the defined term "UNISOLABLE" to the third condition tominutes or longer, to 15 min. emphasize the generic bases "In this case, RCS leakage has been2 RCS identified leakage greater OR detected and operators, following applicable procedures, have beenthan (site-specific value) for 15 RCS identified leakage greater unable to promptly isolate the leak."minutes or longer, than 25 gpm for greater than orequal to 15 min.3 Leakage from the RCS to a ORlocation outside containment greater than 25 gpm for 15 UNISOLABLE leakage from theminutes or longer. RCS to a location outsidecontainment greater than 25 gpmfor greater than or equal to 15min.(Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likely93 of 114 Attachment 2 to TXX-1e5101 EAL Comparison MatrixI I I I be exceeded.II 94 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)Automatic or manual (trip SU6 Automatic or manual trip fails to None[PWR] / scram [BWR]) fails to shut down the reactorshutdown the reactor.

MODE: 1 -Power Operation MODE: Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL # Dfeec/eito utfcto1a. An automatic (trip [PWR] /scram [BWR]) did not shutdownthe reactor.ANDb. A subsequent manual actiontaken at the reactor controlconsoles is successful inshutting down the reactor.SU6.1An automatic trip did not shutdown the reactor as indicated byreactor power greater than 5%after any RPS setpoint isexceededANDA subsequent automatic trip ormanual trip action taken at thereactor control consoles(MCB reactor trip switches ordeenergizing uB3 and uB4) issuccessful in shutting down thereactor as indicated by reactorpower less than or equal to 5%(Note 8)As specified in the generic developers guidance "Developers mayinclude site-specific EOP criteria indicative of a successful reactorshutdown in an EAL statement, the Basis or both (e.g., a reactorpower level)."

Reactor power less than or equal to 5% is the site-specific indication of a successful reactor trip.Added the words "... as indicated by reactor power greater than 5%after any RPS setpoint is exceeded" to clarify that it is a failure of theautomatic trip when a valid trip signal has been exceed.MCB reactor trip switches or deenergizing uB3 and uB4 are the site-specific reactor control console trip switches credited for asuccessful manual trip.a. A manual trip ([PWR] / SU6.2 A manual trip did not shut down As specified in the generic developers guidance "Developers mayscram [BWR]) did not shutdown the reactor as indicated by include site-specific EOP criteria indicative of a successful reactorthe reactor.

reactor power greater than 5% shutdown in an EAL statement, the Basis or both (e.g., a reactorAND after any manual trip action was power level)."

Reactor power less than or equal to 5% is the site-initiated specific indication of a successful reactor trip.b. EITHER of the following:

AND Added the words "... as indicated by reactor power greater than 5%1. A subsequent manual A subsequent automatic trip or after any manual trip action was initiated" to clarify that it is a failureaction taken at the reactor manual trip action taken at the of any manual trip when an actual manual trip signal has beencontrol consoles is95 of 114 Attachment 2 to TXX-1 5101EAL Comparison Matrixsuccessful in shutting reactor control console inserted.

down the reactor.

(MOB reactor trip switches ordeentheeactr.eactrrgzing sw s o Combined conditions b.1 and b.2 into a single statement to simplifyOR ~~~~~deenergizing 2133 and uB4) is thprsnai.

OR successful in shutting down the the presentation.

2 A subsequent automatic reactor as indicated by reactor MCB reactor trip switches or deenergizing uB3 and uB4 are the site-(trip [PWR] / scram power less than or equal to 5% specific reactor control console trip switches credited for a[BWR]) is successful in (Note 8) successful manual trip.shutting down the reactor.Notes Note: A manual action is any N/A Note 8: A manual action is any Noneoperator action, or set of actions, operator action, or set ofwhich causes the control rods to actions, which causesbe rapidly inserted into the core, the control rods to beand does not include manually rapidly inserted into thedriving in control rods orimplementation of boron include manually drivinginjection strategies.

in control rods orimplementation of boroninjection strategies.

96 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SU6 Loss of all onsite or offsite SU7 Loss of all onsite or offsite Nonecommunications capabilities, communications capabilities.

MODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of ALL of the following SU7.1 Loss of all Table S-4 onsite Example EALs #1, 2 and 3 have been combined into a single EALonsite communication methods:

communication methods for simplification of presentation.

(site-specific list of OR Table S-4 provides a site-specific list of onsite, offsite (ORO) andcommunications methods)

Loss of all Table S-4 offsite NRC communications methods.2 Loss of ALL of the following communication methodsORO communications methods:

OR(site-specific list of Loss of all Table S-4 NRCcommunications methods) communication methods3 Loss of ALL of the following NRC communications methods:(site-specific list ofcommunications methods)97 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable S-4 Communication MethodsSystem Onsite Offsite NRCGai-tronics Page/Party (PA) XPlant Radios XPABX X X XPublic Telephone X X XFederal Telephone System (FTS) X X98 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SU7 Failure to isolate containment or SU8 Failure to isolate containment or Noneloss of containment pressure loss of containment pressurecontrol.

[PWR] controlMODE: Power Operation, MODE: I -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 a. Failure of containment to Any penetration is not isolated Reworded EAL to better describe the intent. Penetrations cannotisolate when required by an within 15 min. of a VALID close, but they can be isolated by closure of one or more isolation actuation signal. containment isolation signal valves associated with that penetration.

The revised wordingOR maintains the generic example EAL intent while more clearlyAND Containment pressure greater describing failure to isolate threshold.

b. ALL required penetrations than 18 psig with neitherb. not requied witinetionuts Containment Spray system The containment pressure setpoint (18 psig) is the pressure atr nt cluationsewiignal.

1operating per design for greater which the containment depressurization equipment should actuateof the actuation signal. than or equal to 15 min. and begin performing its function.

One train of containment SU8.1 (Note 1) depressurization equipment is defined as a Containment Spray2 a. Containment pressure system.greater than (site-specific pressure).

ANDb. Less than one full train of(site-specific system orequipment) is operating perdesign for 15 minutes or longer.N/A N/A N/A Note 1: The Emergency Added Note 1 to be consistent in its use for EAL thresholds with aCoordinator should timing component.

declare the event99 of 114 Attachment 2 to TXX)-15101 EAL Comparison Matrixpromptly upondetermining that timelimit has been exceeded, or will likely be exceeded.

100 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SA1 Loss of all but one AC power SA1 Loss of all but one AC power "Safeguard" is the site-specific term for emergency buses.source to emergency buses for source to safeguard buses for 1515 minutes or longer. minutes or longer.MODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNE! Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. AC power capability to (site- SAl.1 AC power capability, Table S-1, 6.9KV safeguard buses uEA1 and uEA2 are the site-specific specific emergency buses) is to 6.9 KV safeguard buses uEA1 emergency buses.reduced to a single power source and uEA2 reduced to a single Site-specific AC power sources are tabularized in Table S-1.for 15 minutes or longer, power source for greater than orAND equal to 15 min. (Note 1)ANDb. Any additional single powersource failure will result in a loss Any additional single powerof all AC power to SAFETY source failure will result in loss ofSYSTEMS.

all AC power to SAFETYSYSTEMSNote The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Alert promptly upon Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withindetermining that 15 minutes has declare the event the EAL wording.been exceeded, or will likely be promptly uponexceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

101 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable S-1 AC Power SourcesOffsite:* 138 KV switchyard circuit* 345 KV switchyard circuitOnsite:* uEGI* uEG2102 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SA2 UNPLANNED loss of Control SA3 UNPLANNED loss of Control NoneRoom indications for 15 minutes Room indications for 15 minutesor longer with a significant or longer with a significant transient in progress.

transient in progress.

MODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 An UNPLANNED event results in SA3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Tablethe inability to monitor one or the inability to monitor one or S-2.more of the following parameters more Table S-2 parameters from The site-specific significant transients list to tabulated in Table S-3.from within the Control Room for within the Control Room for15 minutes or longer, greater than or equal to 15 min. CPNPP is a PWR and thus does not include thermal powerAND (Note 1) oscillations greater than 10%.ANY of the following transient ANDevents in progress.

Any significant transient is in" Automatic or manual progress, Table S-3runback greater than 25%thermal reactor power" Electrical load rejection greater than 25% fullelectrical load" Reactor scram [BWR] / trip[PWR]* ECCS (SI) actuation

• Thermal power oscillations greater than 10% [BWR]103 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNote The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that declare the event the EAL wording.15 minutes has been exceeded, promptly uponor will likely be exceeded.

determining that timelimit has beenexceeded, or will likelybe exceeded.

[BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRCP Water Level RCS LevelRCP Pressure RCS PressurePrimary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number)steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water FlowTable S-2 Safety System Parameters

• Reactor power* RCS level* RCS pressure* Core Exit T/C temperature

• Level in at least one SG* Auxiliary or emergency feed flow in at leastone SGTable S-3 Significant Transients

• Reactor trip* Runback greater than or equal to 25%thermal power* Electrical load rejection greater than 25%electrical load104 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrix.ECCS actuation NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)SA5 Automatic or manual (trip [PWR] SA6 Automatic or manual trip fails to None/ scram [BWR]) fails to shutdown shut down the reactor andthe reactor, and subsequent subsequent manual actionsmanual actions taken at the taken at the reactor controlreactor control consoles are not consoles are not successful insuccessful in shutting down the shutting down the reactorreactor.

MODE: 1 -Power Operation MODE: Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. An automatic or manual (trip SA6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactorshutdown the reactor.

indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactorAND greater than 5% power level)."

Reactor power less than or equal to 5% is the site-AND specific indication of a successful reactor trip.b. Manual actions taken at the MCB reactor trip switches or deenergizing qB3 and uB4 are the site-reactor control consoles are not Manual trip actions taken at the sCi reactor trip switches credited for asuccessful in shutting down the reactor control console (MCB specific reactor control console trip switches credited for areactor.

reactor trip switches or successful manual trip.deenergizing uB3 and uB4) arenot successful in shutting downthe reactor as indicated byreactor power greater than 5%(Note 8)Notes Note: A manual action is any N/A Note 8: A manual action is any Noneoperator action, or set of actions, operator action, or set ofwhich causes the control rods to actions, which causesbe rapidly inserted into the core, the control rods to beand does not include manually105 of 114 Attachment 2 to TXX-15101 EAL Comparison Matrixdriving in control rods or rapidly inserted into theimplementation of boron injection core, and does notstrategies.

include manually drivingin control rods orimplementation of boroninjection strategies.

106 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SA9 Hazardous event affecting a SA9 Hazardous event affecting a NoneSAFETY SYSTEM needed for SAFETY SYSTEM needed forthe current operating mode. the current operating modeMODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown Shutdown107 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1a. The occurrence of ANY ofthe following hazardous events:" Seismic event (earthquake)

" Internal or external floodingevent" High winds or tornado strike" FIRE" EXPLOSION

" (site-specific hazards)" Other events with similarhazard characteristics asdetermined by the ShiftManagerANDb. EITHER of the following:

1. Event damage hascaused indications ofdegraded performance inat least one train of aSAFETY SYSTEMneeded for the currentoperating mode.OR2. The event has causedVISIBLE DAMAGE to aSAFETY SYSTEMcomponent or structure needed for the currentoperating mode.SA9.1The occurrence of any Table S-5 hazardous eventAND EITHER:" Event damage has causedindications of degradedperformance in at least onetrain of a SAFETY SYSTEMneeded for the currentoperating mode" The event has causedVISIBLE DAMAGE to aSAFETY SYSTEMcomponent or structure needed for the currentoperating modeThe hazardous events have been tabularized in Table S-5.Replaced "Shift Manager" with "Emergency Coordinator" as the ECcan be either the SM or augmented ERO EC.108 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixTable S-5 Hazardous Events* Seismic event (earthquake)

• Internal or external FLOODING event* High winds or tornado strike* FIRE* EXPLOSION

• Other events with similar hazard characteristics as determined by the Emergency Coordinator 109 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SS1 Loss of all offsite and all onsite SS1 Loss of all offsite and all onsite "Safeguard" is the site-specific term for emergency buses.AC power to emergency buses AC power to safeguard busesfor 15 minutes or longer, for 15 minutes or longerMODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of ALL offsite and ALL SS1.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.emergency buses) for 15 minutes to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table S-1.or longer. uEA1 and uEA2 for greater thanor equal to 15 min. (Note 1)NoteThe Emergency Director shoulddeclare the Unusual Eventpromptly upon determining that15 minutes has been exceeded, or will likely be exceeded.

N/ANote 1: The Emergency Coordinator shoulddeclare the eventpromptly upondetermining that timelimit has beenexceeded, or will likelybe exceeded.

The classification timeliness note has been standardized across theCPNPP EAL scheme by referencing the "time limit" specified withinthe EAL wording.110 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification SS5 Inability to shutdown the reactor SS6 Inability to shut down the Nonecausing a challenge to (core reactor causing a challenge tocooling [PWR] / RCP water level core cooling or RCS heat[BWR]) or RCS heat removal, removalMODE: Power Operation MODE: 1 -Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. An automatic or manual (trip SS6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactorshutdown the reactor.

indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactorAND greater than 5% power level)."

Reactor power less than or equal to 5% is the site-b. All manual actions to AND specific indication of a successful reactor trip.shuw te m acnl actions to sIndication that core cooling is extremely challenged is manifested byshutdown the reactor have been All actions to shut down the CSTCoeoligRDPtcndinsm.

unsuccessful.

reactor are not successful asAND indicated by reactor power Indication that heat removal is extremely challenged is manifested greater than 5% by CSFST Heat Sink RED Path conditions met.c. EITHER of the following AND EITHER:conditions exist:(Site-specific indication of e CSFST Core Coolingan inability to adequately RED Path conditions metremove heat from the e CSFST Heat Sink REDcore) Path conditions met(Site-specific indication ofan inability to adequately remove heat from theRCS)111 of 114 Attachment 2 to TXX-1 5101EAL Comparison MatrixNEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)SS8 Loss of all Vital DC power for 15 SS2 Loss of all vital DC power for 15 Noneminutes or longer. minutes or longer.MODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #1 Indicated voltage is less than SS2.1 Less than 105 VDC on all 125 105 VDC is the site-specific minimum vital DC bus voltage.(site-specific bus voltage value) VDC safeguard buses uED1, DC buses uED1, uED2, uED3 and uED4 are the site-specific vitalon ALL (site-specific Vital DC uED2, uED3 and uED4 for DC buses.ubusses) for 15 minutes or longer, greater than or equal to 15 min.(Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should declare the CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that event promptly upon the EAL wording.15 minutes has been exceeded, determining that time limit hasor will likely be exceeded.

been exceeded, or will likely beexceeded.

112 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SG1 Prolonged loss of all offsite and SGla Prolonged loss of all offsite and "Safeguard" is the site-specific term for emergency buses.all onsite AC power to all onsite AC power toemergency buses. safeguard busesMODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. Loss of ALL offsite and ALL SGI.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.emergency buses). to 6.9 KV safeguard buses uEA1 Credit is given to APDGs as alternate AC power sources capable ofAND and uEA2 powering a train of decay heat removal.b. EITHER of the following:

AND EITHER: 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time.Restoration of at least Restoration of at least one CSFST Core Cooling RED Path conditions met indicates significant one AC emergency bus in emergency bus from a core exit superheating and core uncovery.

less than (site-pencysic Table S-1 source or APDGless than (site-specific in less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is nothours) is not likely, likely (Note 1)(Site-specific indication of CSFST Core Cooling REDan inability to adequately Path conditions metremove heat from thecore)NoteThe Emergency Director shoulddeclare the General Emergency promptly upon determining that(site-specific hours) has beenexceeded, or will likely beexceeded.

N/ANote 1: The Emergency Coordinator shoulddeclare the eventpromptly upondetermining that timelimit has beenexceeded, or will likelybe exceeded.

The classification timeliness note has been standardized across theCPNPP EAL scheme by referencing the "time limit" specified withinthe EAL wording.113 of 114 Attachment 2 to TXX-15101 EAL Comparison MatrixCPNPPNEI IC# NEI IC Wording lC#(s) CPNPP IC Wording Difference/Deviation Justification SG8 Loss of all AC and Vital DC SG1 b Loss of all AC and vital DC Nonepower sources for 15 minutes or power sources for 15 minutes orlonger, longerMODE: Power Operation, MODE: 1 -Power Operation, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -HotShutdown ShutdownNEI Ex. CPNPPEA E NEI Example EAL Wording EAL CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #a. Loss of ALL offsite and ALL SG1.2 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.emergency buses) for 15 minutes to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table S-1.or longer. uEA1 and uEA2 for greater thanAND or equal to 15 min. 105 VDC is the site-specific minimum vital DC bus voltage.AND buses uED1, uED2, uED3 and uED4 are the site-specific vital DCb. Indicated voltage is less than buses.(site-specific bus voltage value) Less than 105 VDC on all 125on ALL (site-specific Vital DC VDC safeguard buses uED1,busses) for 15 minutes or longer. uED2, uED3 and uED4 forgreater than or equal to 15 min.(Note 1)Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across thedeclare the Unusual Event Coordinator should declare the CPNPP EAL scheme by referencing the "time limit" specified withinpromptly upon determining that 15 event promptly upon the EAL wording.minutes has been exceeded, or determining that time limit haswill likely be exceeded.

been exceeded, or will likely beexceeded.

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