Text

Proposed Upgraded Emergency Action Levels (Eals) Using NEI 99-01 Revision 4 Methodology-LDC 2003-093
	ML040050635
Person / Time
Site:	Grand Gulf
Issue date:	12/16/2003
From:	Bottemiller C; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GNRO-2003/00067, LDC 2003-093
	Download: ML040050635 (336)
	v • d • e

Waterloo Road

?.O. Box 756 Poi? Gibson, MS 391 50 Tel 601 437 6299 es Manager Plant Licensing December 16,2003 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Grand Gulf Nuclear Station - Proposed Upgraded Emergency Action Levels (EALs) Using NEI 99-01 Revision 4 Methodology- LDC 2003-093 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29

Reference:

NEI 99-01, Rev 4 Methodology for Development of Emergency Action Levels.

GNRO-2003/00067 Ladies and Gentlemen:

Upgraded Emergency Action Levels (EALs) are enclosed for NRC staff review and approval as required by 10CFR50 Appendix E, 1V.B. These new EALs were written using the methodology outlined in NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4, January 2003). NEI 99-01 has been endorsed by the NRC Staff in Regulatory Guide 1.101, Revision 4, July 2003, Emergency Planning and Preparedness for Nuclear Power Reactors and in NRC Regulatory Issue Summary 2003-18, October 8, 2003, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003. These changes have been reviewed and approved by the Onsite Safety Review Committee and the States of Mississippi and Louisiana and local governmental authorities.

The guidance contained in NEI 99-01 was found to be acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-I and NUMARCINESP-007 for developing EALs required in Section IV of Appendix E to 10CFR50 and IOCFR50.47(b)(4).

December 16,2003 GNRO-2003/00067 Page 2 of 3 Plant specific information is attached in the following order:

0 Current Emergency Plan Mark-Up Proposed Emergency Plan Pages - Changes incorporated Proposed EALs - To Be incorporated in Procedure Proposed EAL Bases - To Be incorporated in Procedure NEI 99-01, Rev. 4 to Plant Specific Correlations, Differences, Deviations, and Justifications The goal of this upgrade is to provide consistent emergency classifications internally and between the Entergy plants to the greatest extent possible limited only by plant specific design or location.

If you have any questions regarding this submittal, please contact Mr. Milton F. Guynn at 601-437-2166 Sincerely, CAB/MJL Attachment 1 GGNS Current Emergency Plan Mark-Up Attachment 2 GGNS Proposed Emergency Plan Pages - Changes Incorporated Attachment 3 GGNS Proposed EALs - To Be incorporated in Procedure Attachment 4 GGNS Proposed EAL Bases - To Be incorporated in Procedure Attachment 5 GGNS NEI 99-01, Rev. 4 to Plant Specific Correlations, Differences, Deviations, and Justifications cc: see next page

December 16,2003 GNRO-2003/00067 Page 3 of 3 Hoeg T. L. (GGNSSenior Resident) (w/a)

Levanway D. E. (Wise Carter) (w/a)

Reynolds N. S. (w/a)

Smith L. J. (WiseCarter ) (w/a)

Thomas H. L. (w/o)

U.S. Nuclear Regulatory Commission ALL LETTERS ATTN: Mr. Bruce Mallett (w/2) 61 1 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ALL LETTERS - U.S.

ATTN: Mr. Bhalchandra Vaidya, NRR/DLPM (w12) POSTAL SERVICE MAIL ATTN: FOR ADDRESSEE ONLY DELIVERY ADDRESS ONLY ATTN: U S . Postal Delivery Address Only Mail Stop OWFN17D-1 Washington, D.C. 20555-0001

Attachment I to GNRO-2003/00067 GGNS Current Emergency Plan Mark-Up

GG FSAR 4.0 EMERGENCY CONDITIONS 4.1 Emergency Classification Svstem There are four classes of emergency conditions used in emergency planning. These four classes cover the entire spectrum of possible emergency situations, from minor local incidents to hypothetical major radiological emergencies, and allow for classification of an accident, notification of the appropriate offsite agencies and support groups, and the activation of emergency organizations. The system also provides for the notification and implementation of actions immediately applicable to a specific condition, and for upgrading the response to the appropriate level of classification in the event of a change in the severity of the condition. These actions are further described in Section 6.0.

Emergency Action Levels @ a s ) are used to provi exists. These levels are composed of a combination of plant parameters (such as instrument readings and system status) that can be used to give relatively quick indication to the Station operating staff of the severity of the accident situation. The purpose of the EALs is to provide the earliest possible indication of actual or potential accident situations. In most cases further assessment action is conducted both onsite and offsite before actual protective actions are initiated. EALs associated with radiological releases are related to the Environmental Protection Agencys Protective Action Guides (PAGs) summarized in EPA 400-R-92-001Manualof Protective Action Guides and Protective Actions for Nuclear Incidents. A determination by the station emergency organization, along with state and I

local support agencies, of the potential of reaching or e x d i n g the PAGs is performed in accordance with d environment. The developed from guidan GGNS Final S or equipment status due to planned maintenance or testing activities, an emergency condition may or may not exist and the situation must be evaluated on a case by case basis.

4-1 Revisio

GG FSAR The four emergency classes that comprise the emergency classification system are:

a. Unusual Event

b. Alert

c. Site Area Emergency

d. General Emergency.

4.1.1 Unusual Event The Unusual Event class is generally minor in nature, involves no releases of radioactive material that would require offsite response or monitoring, and is such that no immediate hazard to the public exists.

TIaining of the Emergency Organization members should emphasize the need to evaluate the potential for more serious plant conditions to occur at a future time.

4.1.2 Alert The Alert class involves relatively minor emergency situations that have a direct effect on the plant safety related systems. Because of the increased potential for more serious offsite consequences, the emergency organization is activated, as well as notifcation of key offsite authorities and the news media. The Alert class also addresses limited releases of radioactive material and therefore might require some radiological monitoring and assessment actions by the emergency organizations.

The Alert class assures that emergency personnel are readily available to respond to a 4-2 Revision

GG FSAR change in plant conditions and to provide assessment support as required.

4.1.3 Site Area Emere-Immediate protective actions are not required upon notification of a Site Area Emergency condition; however, preliminary steps are initiated in anticipation of possible protective actions. These preliminary steps include complete activation of the emergency organization, alerting and/or mobilizing of monitoring teams, and notification of ail offsite authorities and the news media. The Site Area Emergency class includes accidents which have a significant potential for the release of radioactive material.

Unlike the two previously described classes of emergencies, the Site Area Emergency is very likely to involve some radiation exposure to the near-site public. Also, many of the accidents included in this class have the potential for escalation to the General Emergency class.

4.1.4 General Emer-y The most severe emergency class used in emergency planning is the General Emergency.

Protective actions shall be recommended upon declaration of the General Emergency, as the accidents considered could result in the exceeding of the lower limits of the PAGs.

The General Emergency EALs that require dose projections offsite use jllctual meteorolpev rather than the adverse meteorology assumptions used in the Site Area Emergency action levels.

None of the accidents analyzed in the FSAR would normally be classified as a General Emergency. However, the Loss of Coolant Accident COCA) within the reactor coolant pressure boundary analyzed in the FSAR could lead to a General Emergency classification in a situation where there was a subsequent loss of plant safety systems 4-3 Revis

leading to a possible core melt and failure of containment. Criteria to be used for declaration of a General Emergency includes core and containment status as well as actual radiation release data.

4.2 Classification of Postulated Accidents A thorough analysis of each of the postulated accidents is included in the Grand Gulf Nuclear Station Final Safety Analysis Report (FSAR). All of the postulated accidents could be classified into one of the four emergency classes (SeeTable 4-2). In classifying each of the postulated accidents, the conservative assumptions used in the FSAR analysis were considered. It is possible that occurrence of some of the postulated accidents results in a classification lower in severity.

4-4 Revisio

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS UNUSUAL EVENT ~~

NUREG-0654 JMTL4TING CONDITIONS EMERGENCY ACTION LEVEL

1. reach required shutdown within Failure to reach the requirwl plant operatiom mode p i f i a t i o n time limits within Technical Specificationaction statement time Frames for any of the following LCO's:

1. Safetytrelief Valves 3.4.4 or

2. ECCS Opentthg 3.5.1 p5

3. Primary Containment 3.6.1.1 PI

$. Primary Containment Airlocks 3.6.1.2 or

5. Primary Containment Isolation Valves 3.6.1.3 Of

5. Low Low Set Valves 32.1.6 M

7. Residual Heat Removal cWtaLunc?nt Spray 3.6.1.7 pf B. SuppresSiOn Pool Average Temperature 3.6.2.1 PI

9. SuppresSian Pool Level 3.6.2.2 or as Treatment System 3.6.4.3

2. Radiological effluent Technical Reqkments Manual 0limits exceeded of the TRM; 6.11 Radioactive Liquid Effluent section of TRM 4-5 Revision

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS UNUSUAL EVENT EMERGENCY ACTION LEVEL

1. Increase of 285mR/hr in 30 minutes on Offgas pretreatment monitor

-or

2. >1,400 mwhr on Offgas pretreatment monitor or

3. Laboratory analysis of coolant sample indicates >0.2 pCi/ml dose equivalent 1-131 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or

1. Laboratory analysis of coolant sample indicates >4.0 pCi/ml dose equivalent I-131

1. Exceeding primary system leak While inmodes 1,2 or 3:

specification 1. >5 gpm unidentified leakage or

2. >30 gpm total leakage averaged over previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period

5. Failure of a safety or relief valve in a safety rela 1. Shift Manager determines a SRV is stuck open in plant system to close following reduction of applicable mode 1,2, or 3 pressure i

6. Loss of offsite power or loss of onsite AC power oss of offsite power to:

capability and I__

enerators while in 7 . Fire within the plant lasting more than 10 minutes

8. Indications or alarms on process or effluent parameters not functional in control room to an extent requiring as:

plant shutdown or other significant loss of assessment or a. All vessel level ins communication capability

2. Degradation of the offsite co 4-6 Revision

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS UNUSUAL EVENT erienced or projected 1. A verified earthquake detected by in-plant seismic instrumentation or

2. A tornado observed on&

or

3. A hurricane warning issued that includes the site area

\ I

1. Other hazards being experien I 1. Notification of an aircraft crash onsite outside the protected area or

2. Notification of unusual aircraft activity over the facility example: spraying or dropping something on

3. Notification ofan onsite explosion (does not aff&

or Determination that a release oftoxic, oxygen lacing, or flammable gas will significantlyhamper ility of personnel to perform activities a M i g or r automatic &am initiated because of a e failure that has not penetrated the casing

12. Other plant conditionsexist that warrant increased ines that plant canditions exists awareness on the part of a plant operating staff or State imary notification to state and and/or local o&ite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown 4-7 Revision 50 05/03

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS ALERT EMERGENCY ACTION LEVEL

1. 14,000mR/hr on Offgas pretreatment monitor or 2: -~oian~sampleanalysisiftdicates>300 pCi/ml dose equivalent 1-131 or

3. Main steam line radiationexceedsradiation monitor trip setpoint

1. Isolation initiated and abnormal leakage downstream of MSIV's (>lo gpm or 5000 lbm/hr)

3. Primary coolant leak rate greater than 50 1. Total leakage calculated to be >50 gpm while in Plant Operating Condition 1,2 or 3 Verification of area radiation monitor reading >lo00 radioactive materials or

5. Loss of offsitepower loss of onsite AC power for less than 15 minutes.

and

c. 17AC

2. Loss of all three iesel generators

6. Loss of all onsite DC power for less than 15 minutes

7. Complete loss of any functionneeded for plant cold shutdown

2. The determination that there are no 1 systems functional to attain or mainta coolant c 2W°F 4-8 Revision 32 6/97

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS ALERT EMLERGENCY ACTION LEVEL ctor protection system to initiate and 1. Scram conditions confirmed which brings the reactor subcritical and

2. a. More than one rodcgeater than position 02 or

~ o position d is unknwn fix more than one rtxl

-and

b. SRM!s are either upscale or countrate is increasing (Assuming SRMs are lil in) and

3. a. ~ a c t power w < 4 0 0 n APRM (APRM own

1. Notification of a spent fuel damaging accident and

. ~ i g high h radiation a l G s on either 1 handliig vent exhaust ar tainment vent exhaust ation alarms on ONE OR MORE

2. Summation

13. Ongoing security compromise 4-9 Revision 50 05/03

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS instrumentation2 OBE levels or

2. A tornado causing damage to Safety Related or

3. Sustained winds 1.73 mph onsite

15. Other hazards being ced or projected 1. Notification of an aircraft crash onsite inside the protected area,no damage to plant vital structures (SSW Complex, Diesel Generator, Auxiliary, Containment or Control Buildings) or

2. Notification of missile impacts on plant non-vital or

. Notification of an onsite~xplasionaffixting plant or ination that the of toxic or flammable facility structures has threatened to render ated equipment Inoperable or a turbine%ilure that has r d t e d in ion

16. 0 t h plant

~ conditions exist that warrant erminesthat plant conditions precautionaryactivation of technical support center utionary activation of the TSC

2. Control of shutdown ed at the remott 4 -10 Revision 50 05/03

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS MERGENCY G-0654 INITIATING CONDITIONS EMERGENCY ACTION LEVEL

1. RPV water level <-167 in.

Bad

2. Makeup capacity unable to maintain or increase reactor vessel level

1. RPV water Ievel <-167 in. or cannot be determined a&

2. a. High coolant activity indicated by analysis of sample > 300 pCilml dose equivalent 1-131 a

b. Containment or Drywell hydrogen concentration greater than 0.5 96

1. RCIC or main steam line isolation required due to confirmed steam line break and The associated line fail= isolate

4. Loss of offsite power loss of onsite AC power ss of offsite power to:

for more than 15 minutes and and and

2. Loss of all ivisional diesel generators and

3. > 15 minutes N 5. Loss of all vital onsite DC power for more than 15 minutes

6. Complete loss of any function needed for plant hot

1. Loss of Division 1, 2

> 15minutes)

1. HPCS and RCIC not functio shutdown

2. Not able to depressurizewith SRV 4 - 11 Revision 27 19/94

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS SITE AREA EMERGENCY EMERGENCY ACTION LEVEL

1. Scram conditions confirmed and

2. All control rods NOT inserted to between 00 and 02

3. Reactor power 4% on APRM (APRM Down scale light off)

I 1, a. Notification of a spent fuel damaging accident 0'

b. Low water level in spent fuel pool below top of spent he1 and unable to restore level to above fuel.

and

2. a. Any post accident a u e n t radiation monitor c o n f m Noble Gas, Iodine release rates corresponding to:

b. 0.5 Ci/sec Noble Gas (30 minutes) or 6.0 E-4 Cikec Iodine(30 minutes) or Cikec Noble Gas(2 minutes) port Radiation and/or at the site boundary

b. 500 mWHr (for 2

9. Fire compromising the functions of safety systems I

\

4-12 Revision 38 12/98

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS SITE AREA EMERGENCY EMERGENCY ACTION LEVEL

10. a. ors detect levels correspondingto I. Any post accident effluent radiation monitor confirm release rates correspondingto:

or five times these

a. 0.5 CYsec Noble Gas for 30 minutes or

b. b. 6.0 E-4 Ci/sec Iodine fa 30 minutes or

c. 5.0 Cilsec Noble Gasfor 2 minutes or the environs d. 6.0 E-3 Cilsec I d i ~ f 2aminutes C. EPA protective Action Gu or be exceeded outside the sit 2. Radiation monitoring t&s report radiation andla Iodine concentrationreadings at the site boundary 0 mWHt for 30 minutes

11. Imminent loss of physical control of the plant 1

12. Severe natural phenomena being experienced or projected with plant not in cold shutdown instrumentation 2 SSE

2. Sustained winds 2 90 mph onsite 4 - 13 Revision 50 05/03

GG FSAR TABLE 4-1 EMERGENCY ACTtON LEVELS SITE AREA EMERGENCY EMERGENCY ACTION LEVEL

13. Otherhazardsbe enced or projected with 1. Notification of an aircraft crash into plant vital plant not in cold structures (SSW Complex, Diesel Generator, Auxiliary, Containment or Control Buildings) or

2. Notification of severe damage to safe shutdown equipment fkom missiles or explosion or

3. Determination that the of toxic or flammable gases into vital areas (Control Room, ESF SWGR, Remote Shutdown Rooms, etc.) constitutesa plant

14. Other plant conditions exist that warrant activation of emergency centers and monitoring teams or a release is in progress or imminent precautionary notifiation to the public near the site 1.5. Evacuation of Control room and control of shutdown systems not established from local stations in 15 minutes 2. Unable to establi f shutdown systems at the remote shutdown pane 4 - 14 Revision 50 05/03

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS GENERAL EMERGENCY EMERGENCY ACTION LEVEL Effluent monitor(s) (UNDER ACTUAL METEOROLOGICAL CONDJTIONS) confirms release rates corresponding to site boundary exposure of: (2 hr dose commitment)

a. 1OOOmRemTEDE or

b. 5000mRemCDE or Radiation monitoring teams report radiation andlor Note: iodine concentrations readings (at the site boundary)

Consider evacuation only wit corresponding to:

boundary unless these site bo a. 1OOOmRemTEDE or

b. 1.2 E-5 pCiIcc Iodine of any two of the following fission product potential loss of 3rd barrier, (e.g., loss of primary daries with a potential for loss of the third:

coolant boundary, clad failure, and high potential for loss of containment) Fuel Cladding ant sample analysis indicates 300 pCilml equivalent 1-131

a. RPV water

b. RPV pressure maintained >

(Continued on next page)

c. > 100 R/Hr in Drywell 4 - 15 Revision 27 10194

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS GENERAL EMERGENCY EMERGENCY ACTION LEVEL

1. (Continued) ion product barriers with a potential Loss of any two of the following fission product

, (e.g., loss of primary coolant boundaries with a potential for loss of the third:

Reactor Pressure Boundary Loss

a. Drywe11pressure >1.23 psig &indication of a steam leak in the drywell or

b. Main steam line not isolated or C. RCIC steam line break outside containment with inability to isolate Potential loss

a. Total reactor coolant leakage calculated to be r.50 gPm or

b. >10 ~ l hinr ContaGent Primarv Containment Loss Primary containment pressure >56 psig or of ability to isolate drywell or primary inment leakage into areas outside the primary inment afe region of HCTL 3PSP curve of HDOL curve

3. Loss of physical control of the facility 1 . Physical attack on the plant has unauthorized personnel occupyi Note: or the Remote Shutdown Panel or contr Consider 2 mile precautionary evacuation Heat Removal, Reactor Water Level or Control capabilities.

4-16 Revision 41 3/00

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS GENERAL 1 ERGENCY REG4654 I M T I A m G CONDITIONS EMERGENCY ACTION LEVEL from whatever source, 1. The Emergency Director/OffsiteEmergency of large amounts of radioactivity Coordinator determines that plant conditions exist ible, e.g., any core melt that make the relam of large amounts of radioactivity in a short period of time likely. (not limited to the following examples)

Notea:

a. For core melt a. a r e damage is predicted to occur (within two releases from hours )

place and large amoun not yet in the containment a Containment pressure is > 22 psig or 2 mile precautionary evacuatio containment is breached mile downwind evacuation (45 if large amounts of fission prod than gap activity) are in the con atmosphere. Recommend sheltering in o parts of the plume exposure Emergency Planning Zone under this circumstance.

b. For core melt sequences where significant releases from containment are not yet taking place and containment failure leading to a direct atmospheric release is likely in the sequence but not imminent and large amounts of fission products in addition to noble gases are in the containment atmosphere, consider precautionary evacuation to 5 miles and 10 miles downwind evacuation (45" to 90" sector)

C. For core melt sequences where large amounts of fission products other then noble gases are in the Containment atmosphere and containment failure is judged imminent, recommend shelter for those areas where evacuation cannot be accomplished before transport of activity to that location.

d. As release information becomes available adjust these actions in accordance with dose projections, time available to evacuate and estimated times given current conditions.

4 - 17 Revision 27 10194

GG FSAR TABLE 4-1 EMERGENCY ACTION LEVELS GENERAL EMERGENCY EMERGENCY ACTION LEVEL a.

b. Small or large LOCAs with fai perform leading to core melt de melt in minutes to hours. Loss of containment integrity may be imminent.

C. Small or large LOCA occurs and containment performance is unsuccessful affecting longer term success of the ECCS. Could lead to core degradation or melt in several hours without containment boundary.

d. Shutdown occurs but requisite decay heat removal systems (e.g., RHR) or non-safety systems heat removal means are rendered unavailable. Core degradation or melt occur in about ten hours with subsequent containment failure.

5 . Any major internal events (e.g., fires, earthquakes, 1. Fires, earthquakes, etc., substanti substantially beyond design basis) which could cause basis which could or have caused massive common damage to plant systems resulting damage to plant systems in any of the above.

4 - 18 Revision 27 10194

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY Abnormal Rad AU 1 AA1 AS1 AG1 Levels I Unplanned release of Unplanned release of gaseous Offsite dose resulting from an Offsite dose resulting from an Radiological gaseous or liquid or liquid radioactivity to the actual or imminent release of actual or imminent release of Effluent radioactivity to the environment that exceeds 20 x gaseous radioactivity exceeds gaseous radioactivity exceeds environment that exceeds 2 ODCM limit for 215 minutes 100 mR TEDE or 500 mR 1000 mR TEDE or 5000 mR x ODCM limit for 260 Plant Mode: 1,2,3,4,5,D CDE Thyroid for the actual or CDE Thyroid for the actual or minutes projected duration of the projected duration of the Plant Mode: 1,2,3,4,5,D release using actual release using actual meteorology meteorology Plant Mode: 1,2,3,4,5, D Plant Mode: 1,2,3,4,5,D AU2 AA2 Unexpected increase in Release of radioactive material plant radiation or increase in radiation levels Plant Mode: 1,2,3,4,5,D within the facility that impedes operation of systems required to maintain or establish safe operations or cold shutdown Plant Mode: 1,2,3,4,5,D AA3 Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the RPV Plant Mode: 1,2,3,4,5,D

-ission Product FU1 FA1 FS1 FG1 3arrier Loss or Potential Loss of Loss or Potential Loss of either Loss or Potential Loss of any Loss of any two Fission legradation Primary Containment Fuel Clad or Reactor Pressure two Fission Product Barriers Product Barriers with Loss or Plant Mode: 1,2,3 Boundary Plant Mode: 1,2,3 Potential Loss of third barrier.

Plant Mode: 1, 2,3 Plant Mode: 1,2,3 Plant Mode Power Operation Startup 131 Hot Shutdown )4) Cold Shutdown Refueling a Defueled 4-5 Revision xx xx/03

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION CATEGORY Hazards and Other UNUSUAL EVENT HU1 ALERT HA1 1 SITE AREA EMERGENCY HS1 1 GENERAL EMERGENCY HGl Conditions Confirmed security event Confirmed security event in a Confirmed security event in a Security event resulting in loss Affecting Plant which indicates a potential plant Protected Area plant Vital Area of physical control of the facility Safety degradation in the level of Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D safety of the plant.

Plant Mode: 1,2,3,4,5,D HU2 HA2 HS2 HG2 Conditions exist which in the Conditions exist which in the Conditions exist which in the Conditions exist which in the judgment of the Emergency judgment of the Emergency judgment of the Emergency judgment of the Emergency Director warrant declaration Director warrant declaration of Director warrant declaration of Director warrant declaration of of an Unusual Event. an Alert. a Site Area Emergency. a General Emergency.

Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D HA3 HS3 Control Room evacuation has Control Room evacuation has been initiated. been initiated and plant Plant Mode: 1,2,3,4,5,~ control Cannot be established.

Plant Mode: 1,2,3,4,5,D

~

HU3 HA4 Natural or destructive Natural or destructive phenomena affecting the phenomena affecting a Vital Protected Area. Area Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode 111 Power Operation 121 Startup 131 Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-6 Revision xx xA03

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY Hazards and Other HU4 HA5 Conditions Fire within the power block Fire within the power block Affecting Plant not extinguished within 15 affecting the operability of plant Safety (cont) minutes of detection. safety systems required to Plant Mode: 1,2,3,4,5,D establish or maintain safe shutdown.

Plant Mode: 1,2,3,4,5,D HU5 HA6 Release of toxic or Release of toxic or flammable flammable gases deemed gases within or contiguous to a detrimental to safe operation Vital Area which jeopardizes of the plant. operation of safety systems Plant Mode: 1,2,3,4,5,D required to establish or maintain safe shutdown.

Plant Mode: 1,2,3,4,5,D System su1 SA1 ss1 SG1 Malfunction Loss of all offsite power to AC Power to Div 1&11 ESF -oss of all offsite and onsite Prolonged loss (>4hours) of all ESF Busses for >15 Minutes busses reduced to a single 3ower to Div 1&11 ESF busses. 3ffsite and onsite power to Div Plant Mode: 1,2,3,4,5 power source for >15 minutes Plant Mode: 1,2,3 l&ll ESF busses.

such that any additional single Plant Mode: 1,2,3 failure would result in loss of AC power to Div I & I 1 ESF busses.

Plant Mode: 1,2,3 SA2 Loss of all offsite and onsite power to Div I & II ESF busses.

Plant Mode: 4,5,D Plant Mode )IIPower Operation 121 Startup 131 Hot Shutdown 14( Cold Shutdown 151 Refueling a Defueled 4-7 Revision xx xx/03

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY System su2 ss2 Malfunction (cont) Unplanned loss of required Loss of all vital DC power DC power for >15 minutes Plant Mode: 1,2,3 Plant Mode: 4,5 SA3 ss3 SG2 Failure of reactor protection Failure of reactor protection Failure of reactor protection system to complete or initiate system to complete or initiate system instrumentationto an automatic reactor scram an automatic reactor scram complete an automatic reactor once a reactor protection once a reactor protection scram and manual scram was system setpoint has been system setpoint has been not successful and there is exceeded and manual scram exceeded and manual scram indication of an extreme was successful. was not successful. challenge to the ability to cool Plant Mode: 1,2 Plant Mode: 1,2 the core.

Plant Mode: 1,2 su3 SA4 ss4 SG3 Loss of RPV inventory Loss of RPV inventory with Loss of RPV inventory Loss of RPV inventory Plant Mode: 1,2,3 irradiated fuel in the RPV affecting core decay heat affecting fuel clad integrity with Plant Mode: 4,5 removal capability with containment challenged with su4 irradiated fuel in the RPV irradiated fuel in the RPV a,

Y CI) m Unplanned loss of RPV Plant Mode: 4,5 Plant Mode: 4,5 m

a, inventory

-I u) Plant Mode: 4 0

U su5 Unplanned loss of RPV nventory with irradiated fuel n the RPV Plant Mode: 5 Plant Mode 111 Power Operation 121 Startup 131 Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-8 Revision xx xxJ03

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNlTlON UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY System SU6 SA5 ss5 Malfunction (cont) Unplanned loss of decay Inability to maintain plant in Complete loss of heat heat removal capability with cold shutdown with irradiated removal capability.

irradiated fuel in the RPV fuel in the RPV Plant Mode: 1,2,3 Plant Mode: 4,5 Plant Mode: 4,5 su7 Inadvertent criticality Plant Mode: 3,4,5

.e Unplanned SU8 loss of most or Unplanned SA6 loss of most or all SS6 Inability to monitor a 0

.I-m all safety system safety system annunciation or significant transient in

'- c E .E! annunciation or indication in indication in the control room progress.

zt;; the control room for >15 with either a significant Plant Mode: 1,2,3 c .o 20 -z minutes transient in progress, or vt Plant Mode: 1,2,3 compensatory non-alarming vt 0 indicators are unavailable.

2 Plant Mode: 1,2,3 su9 Unplanned loss of all onsite or offsite communications capabilities.

Plant Mode: 1,2,3,4,5 SUlO Fuel clad degradation Plant Mode: 1,2, 3,4,5 Plant Mode 111 Power Operation 12( Startup 131 Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-9 Revision xx xdO3

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION System CATEGORY Ex UNUSUAL EVENT ALERT 1 SITE AREA EMERGENCY 1 GENERAL EMERGENCY Malfunction (cont) 5g:::

f Inability to reach required shutdown within technical m u specification limits.

Plant Mode: 1,2,3 Plant Mode 111 Power Operation 121 Startup 131 Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-10 Revision xx xx/03

TABLE 4-2 Classification of FSAR Design Bases Accidents Design Bases Accident Classification Seizure of one recirculation pump Unusual Event Recirculation pum.p shaft break Unusual Event Rod drop accident Alert 1 Instrument line break

~

Unusual Event Steam system pipe break outside containment Site Area Emergency LOCA within reactor coolant pressure boundary Site Area Emergency Feedwater line break outside containment Site Area Emergency Main condenser Off Gas treatment system failure Site Area Emergency Liquid radwaste tank failure Alert Fuel handling accident outside primary containment Site Area Emergency Fuel handling accident inside primary containment Alert Note:

This table is provided for example purposes only. Classificationwas determined by applyin to each FSAR Design Bases Accident. This table is not procedurally implemented.

4 Revisio

Attachment 2 to GNRO-2003/00067 GGNS Proposed Emergency Plan Pages -

Changes Incorporated

GG FSAR 4.0 EMERGENCY CONDITIONS 4.1 Emergency Classification System There are four classes of emergency conditions used in emergency planning. These four classes cover the entire spectrum of possible emergency situations, from minor local incidents to hypothetical major radiological emergencies, and allow for classification of an accident, notification of the appropriate offsite agencies and support groups, and the activation of emergency organizations. The system also provides for the notification and implementation of actions immediately applicable to a specific condition, and for upgrading the response to the appropriate level of classification in the event of a change in the severity of the condition. These actions are further described in Section 6.0.

Emergency Action Levels (EALs) are used to provide Plant Specific indication that an Initiating Condition exists. These levels are composed of a combination of plant parameters (such as instrument readings and system status) that can be used to give relatively quick indication to the Station operating staff of the severity of the accident situation. The purpose of the EALs is to provide the earliest possible indication of actual or potential accident situations. In most cases further assessment action is conducted both onsite and offsite before actual protective actions are initiated. EALs associated with radiological releases are related to the Environmental Protection Agency's Protective Action Guides (PAGs) summarized in EPA 400-R-92-001 "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." A determination by the station emergency organization, along with state and local support agencies, of the potential of reaching or exceeding the PAGs is performed in accordance with dose assessment procedures in the event of a radiological release to the environment. The EALs are found in implementing Procedure 10-S-01-1 and correlate to the Initiating Conditions in Table 4-1. The EALs were developed from guidance contained in NEI 99-01 (Revision 4, January 2003) and from accidents analyzed in the GGNS Final Safety Analysis Report. When EALs are observed in conjunction with plant or equipment status due to planned maintenance or testing activities, an emergency condition may or may not exist and the situation must be evaluated on a case by case basis.

4-1 Revision xx xx/xx

GG FSAR change in plant conditions and to provide assessment support as required.

4.1.3 Site Area Emergency Immediate protective actions are not required upon notification of a Site Area Emergency condition; however, preliminary steps are initiated in anticipation of possible protective actions. These preliminary steps include complete activation of the emergency organization, alerting and/or mobilizing of monitoring teams, and notification of all offsite authorities and the news media. The Site Area Emergency class includes accidents which have a significant potential for the release of radioactive material.

Unlike the two previously described classes of emergencies, the Site Area Emergency is very likely to involve some radiation exposure to the near-site public. Also, many of the accidents included in this class have the potential for escalation to the General Emergency class.

4.1.4 General Emergency The most severe emergency class used in emergency planning is the General Emergency.

Protective actions shall be recommended upon declaration of the General Emergency, as the accidents considered could result in the exceeding of the lower limits of the PAGs.

The General Emergency EALs that require dose projections offsite use actual meteorology rather than the adverse meteorology assumptions used in the Site Area Emergency action levels.

None of the accidents analyzed in the FSAR would normally be classified as a General Emergency. However, the Loss of Coolant Accident (LOCA) within the reactor coolant pressure boundary analyzed in the FSAR could lead to a General Emergency classification in a situation where there was a subsequent loss of plant safety systems 4-3 Revision xx xx/xx

GG FSAR leading to a possible core melt and failure of containment. Criteria to be used for declaration of a General Emergency includes core and containment status as well as actual radiation release data.

4.2 Classification of Postulated Accidents A thorough analysis of each of the postulated accidents is included in the Grand Gulf Nuclear Station Final Safety Analysis Report (FSAR). All of the postulated accidents could be classified into one of the four emergency classes (See Table 4-2). In classifying each of the postulated accidents, the conservative assumptions used in the FSAR analysis were considered. It is possible that occurrence of some of the postulated accidents results in a classification lower in severity.

4-4 Revision xx xx/ xx

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY Abnormal Rad AUI AAI AS1 AGI Levels I Unplanned release of Unplanned release of gaseous Offsite dose resulting from an Offsite dose resulting from an Radiological jaseous or liquid or liquid radioactivity to the actual or imminent release of actual or imminent release of Effluent -adioactivity to the environment that exceeds 20 x gaseous radioactivity exceeds gaseous radioactivity exceeds 3nvironment that exceeds 2 ODCM limit for 215 minutes 100 mR TEDE or 500 mR I000 mR TEDE or 5000 mR Y ODCM limit for 260 CDE Thyroid for the actual or CDE Thyroid for the actual or Plant Mode: 1,2,3,4,5,D ninUtes projected duration of the projected duration of the release using actual release using actual Plant Mode: 1,2,3,4,5,D meteorology meteorology Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D AU2 AA2 Jnexpected increase in Release of radioactive material 3lant radiation or increase in radiation levels Plant Mode: 1,2,3,4,5,D within the facility that impedes operation of systems required to maintain or establish safe operations or cold shutdown Plant Mode: 1,2,3,4,5,D AA3 Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the RPV Plant Mode: I , 2,3,4,5,D

'ission Product FUI FA1 FSI FGI 3arrier -oss or Potential Loss of Loss or Potential Loss of either ,oss or Potential Loss of any -oss of any two Fission legradation Jrimary Containment Fuel Clad or Reactor Pressure wo Fission Product Barriers Jroduct Barriers with Loss or Boundary Plant Mode: 1,2,3 Jotential Loss of third barrier.

Plant Mode: 1,2,3 Plant Mode: 1, 2,3 Plant Mode: 1,2,3 Plant Mode 111 Power Operation Startup Hot Shutdown 141 Cold Shutdown /51 Refueling Defueled 4-5 Revision xx xx/xx

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station RECOGNITION UNUSUAL SITE AREA GENERAL CATEGORY EVENT ALERT EMERGENCY EMERGENCY Hazards and Other HUI HA1 HSI HGI Conditions Confirmed security event Confirmed security event in a Confirmed security event in a Security event resulting in loss 4ffecting Plant which indicates a potential plant Protected Area plant Vital Area 2f physical control of the facility Safety degradation in the level of Plant Mode: I ,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,0 safety of the plant.

Plant Mode: 1,2,3,4,5,D HU2 HA2 HS2 HG2 Conditions exist which in the Conditions exist which in the Conditions exist which in the >onditions exist which in the judgment of the Emergency judgment of the Emergency judgment of the Emergency udgment of the Emergency Director warrant declaration Director warrant declaration of Director warrant declaration of lirector warrant declaration of of an Unusual Event. an Alert. a Site Area Emergency. 3 General Emergency.

Plant Mode: I , 2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode: I ,2,3,4,5,D Plant Mode: 1,2,3,4,5,D HA3 HS3 Control Room evacuation has Control Room evacuation has been initiated. been initiated and plant control cannot be established.

Plant Mode: 1,2,3,4,5,D Plant Mode: 1,2,3,4,5,D HU3 HA4 Natural or destructive Natural or destructive phenomena affecting the phenomena affecting a Vital Protected Area. Area Plant Mode: I ,2,3,4,5,D Plant Mode: 1,2,3,4,5,D Plant Mode II)Power Operation Startup Hot Shutdown Cold Shutdown Refueling a Defueled 4-6 Revision xx xx/ xx

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station Hazards and Other HU4 HA5 Conditions Fire within the power block Fire within the power block Affecting Plant lot extinguished within 15 affecting the operability of plant Safety (cont) minutes of detection. safety systems required to establish or maintain safe Plant Mode: 1,2,3,4,5,D shutdown.

Plant Mode: 1,2,3,4,5,D HU5 HA6 Release of toxic or Release of toxic or flammable flammable gases deemed gases within or contiguous to a jetrimental to safe operation Vital Area which jeopardizes 3f the plant. operation of safety systems required to establish or Plant Mode: 1,2,3,4,5,D maintain safe shutdown.

Plant Mode: 1,2,3,4,5,D System su1 SA1 ss1 SGI Malfunction -oss of all offsite power to AC Power to Div 1&11 ESF Loss of all offsite and onsite Prolonged loss (>4hours) of all ESF Busses for >I 5 Minutes busses reduced to a single power to Div 1&11 ESF busses. Dffsite and onsite power to Div power source for > I 5 minutes 1&11 ESF busses.

Plant Mode: 1,2,3,4,5 Plant Mode: 1,2,3 such that any additional single Plant Mode: 1,2,3 failure would result in loss of AC power to Div I & I I ESF busses.

Plant Mode: 1,2,3 SA2 Loss of all offsite and onsite power to Div I & I I ESF busses.

Plant Mode: 4,5,D Plant Mode /?/ Power Operation Startup Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-7 Revision xx xx/xx

GG FSAR Table 4-1 INITIATING CONDITIONS for Grand Gulf Nuclear Station System su2 ss2 Malfunction (cont) Unplanned loss of required Loss of all vital DC power DC power for >I 5 minutes Plant Mode: 1,2,3 Plant Mode: 4,5 SA3 ss3 SG2 Failure of reactor protection Failure of reactor protection Failure of reactor protection system to complete or initiate system to complete or initiate system instrumentationto an automatic reactor scram an automatic reactor scram complete an automatic reactor once a reactor protection once a reactor protection scram and manual scram was system setpoint has been system setpoint has been not successful and there is exceeded and manual scram exceeded and manual scram indication of an extreme was successful. was not successful. challenge to the ability to cool Plant Mode: 1,2 Plant Mode: 1,2 the core.

Plant Mode: I,2 su3 SA4 ss4 SG3 Loss of RPV inventory Loss of RPV inventory with Loss of RPV inventory Loss of RPV inventory affectinc irradiated fuel in the RPV affecting core decay heat fuel clad integrity with Plant Mode: 1,2,3 removal capability with containment challenged with Plant Mode: 4,5 su4 irradiated fuel in the RPV irradiated fuel in the RPV Unplanned loss of RPV Plant Mode: 4,5 Plant Mode: 4,5 inventory Planf Mode: 4 su5 Unplanned loss of RPV inventory with irradiated fuel in the RPV Plant Mode: 5 SU6 SA5 ss5 Jnplanned loss of decay Inability to maintain plant in cold Complete loss of heat removal Teat removal capability with shutdown with irradiated fuel in capability.

rradiated fuel in the RPV the RPV Plant Mode: 1,2,3 Plant Mode: 4,5 Plant Mode: 4,5 Plant Mode 111 Power Operation Startup 131 Hot Shutdown 141 Cold Shutdown 151 Refueling Defueled 4-8 Revision xx xx/xx

GG FSAR Table 4-1 INITIATING CONDITIONSfor Grand Gulf Nuclear Station System su7 Vlalfunction (cont)

Inadvertent criticality Plant Mode: 3,4,5 SU8 SA6 SS6 Unplanned loss of most or Unplanned loss of most or ail Inability to monitor a all safety system safety system annunciation or significant transient in annunciation or indication in indication in the control room progress.

the control room for >I 5 with either a significant transienf Plant Mode: 1,2,3 minutes in progress, or compensatory Plant Mode: 1,2,3 non-alarming indicators are unavailable.

Plant Mode: 1,2,3 su9 Unplanned loss of all onsite or offsite communications capabilities.

Plant Mode: 1,2,3,4,5 SUlO Fuel clad degradation Plant Mode: 1,2, 3,4,5 su11 Inability to reach required shutdown within technical specification limits.

Plant Mode: 1,2,3 PlantMode 111 Poweroperation Startup Hot Shutdown 141 ColdShutdown 151 Refueling Defueled 4-9 Revision xx xx/ xx

GG FSAR TABLE 4-2 Classification of FSAR Design Bases Accidents Design Bases Accident Classification II I II Seizure of one recirculation pump Unusual Event Recirculation pump shaft break Unusual Event Rod drop accident Alert Instrument line break Unusual Event Steam system pipe break outside containment Site Area Emergency 1 LOCA within reactor coolant pressure boundary 1 7 -

I I

Site Area Emergency /I II Feedwater line break outside containment Site Area Emergency Main condenser Off Gas treatment system failure Site Area Emergency

/I Liquid radwaste tank failure I Alert l Fuel handling accident outside primary containment Site Area Emergency Fuel handling accident inside primary containment Alert Note:

This table is provided for example purposes only. Classification was determined by applying implementing Procedure 10-S-01-1 criteria to each FSAR Design Bases Accident. This table is not procedurally implemented.

4-10 Revision xx xx/ xx

Attachment 3 to GNRO-2003100067 GGNS Proposed EALs - To Be Incorporated in Procedure

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I Page 1 of 10 EMERGENCY CLASSIFICATIONS TABLE OF CONTENTS NOTE Any changes made to information in Attachment I may require changes to EPP 01-02 (EAL Matrix).

Grand Gulf Nuclear Station Emergency Plan Procedure lo-s-01-1 I Revision xx Attachment I I page2 of I 1 BNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT I Plant Modes: [I;i Power Operations Startup fl Hot Shutdown Cold Shutdown Refueling Defueled 1Al 9ffsite dose resulting from an actual or imminent Iffsite dose resulting from an actual or imminent Jnplanned release of gaseous or liquid Unplanned release of gaseous or liquid

-elease of gaseous radioactivity exceeds 1000 mR slease of gaseous radioactivity exceeds 100 mR adioactivity to the environment that exceeds *adioactivityto the environment that exceeds TEDE or 5000 mR CDE Thyroid for the actual or rEDE or 500 mR CDE Thyroid for the actual or !O x ODCM limit 1 15 minutes 2 x ODCM limit for 1 6 0 minutes xojected duration of the release using actual xojected duration of the release using actual Emergency Action Level:

Emergency Action Level:

meteorology neteorology

1. Liquid release > 40 x High High Alarm set 1. Liquid release > 4 x High High Alarm set Emergency Action Level: Emergency Action Level: point on G17-RR-R521 with failure of point on G17-RR-R521with failure of 1, Dose projection of > IOOOmR TEDE at or 1. Dose projection of > 100mR TEDE at or G17-F355 to close for 1 15 minutes G17-F355 to close for 1 60 minutes beyond site boundary based on in plant or beyond site boundary based on in plant or -

field team data field team data OR OR

2. High High Alarm on one or more of the 2. High High Alarm on one or more of the OR -

OR following: following:

2. Dose projection of > 5000mR CDE Thyriod at 2. Dose projection of > 500mR CDE Thyriod at OG Radwst Vent--------- (P601-19A-A8) OG/Radwaste Vent ------ (P601-19A-A8) or beyond site boundary based on in plant or or beyond site boundary based on in plant or field team data field team data FH Area Vent --------------I-- (P601-19A-C11) FHA Vent------------- (P601-19A-C1I)

Ctmt Vent-------------------- (P601-I 9A-G9) Ctmt Vent (P601-19A-Gg)

Turb Bldg Vent ----------- (P601-19A-FlI) Turb Bldg Vent ------------ (P601-19A-Fll)

AND AND Summation of all monitors (including SBGT A Summation of all monitors (including SBGT A

& B) exceeds 20 x TRM Spec limit (6.11.4) for & B) exceeds 2 x TRM Spec limit (6.1 I.4) for 1 15 minutes 1 60 minutes OR OR

3. Confirmed sample analysis for gaseous or 3. Confirmed sample analysis for gaseous or liquid release exceeds 20 x TRM Spec limit liquid release exceeds 2 x TRM Spec limit (6.11.1, 6.11.2, 6.11.4, 6.11.5 or 6.11.6) (6.11.1, 6.11.2, 6.11.4, 6.11.5, 6.11.6) for 1 I 5 minutes for 1 6 0 minutes

Grand Gulf Nuclear Station Emergency Plan Procedure 10-s-01-1 Attachment I I Revision xx I page3 of 11 I BNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT I Plant Modes: Power Operations Startup Hot Shutdown Cold Shutdown Refueling Defueied telease of radioactive material or increase in radiation Unexpected increase in plant radiation evels within the facility that impedes operation of Emergency Action Level:

iystems required to maintain or establish safe

)perations cold shutdown 1. Valid Area Radiation Monitor or survey indicates an unplanned increase in plant Zmergencv Action Level: radiation levels by a factor of 1000 or full

1. Valid radiation level 2 15 mWhr in the Control scale Room

-OR OR 2. Valid indication of uncontrolled water level

2. Valid radiation level 2 80 Whr in the RHR A, B, decrease in Aux Bldg Fuel Pools Upper C, HPCS, LPCS, or RClC Room access is Ctmt Pools with all irradiated fuel assemblies reauired remaining covered by water 9A3 "121"1.151. AND lamage to irradiated fuel or loss of water level that a. Valid Alarm on any of the following:

?as or will result in uncovering of irradiated fuel Ctmt 209 Airlock ------ (P844-I A-AI) wtside the RPV Ctmt Fuel Hdlg Area---- (P844-1A-A3)

Emergency Action Level:

Aux Bldg Fuel Hdlg Area - (P844-1A-A4)

1. Potential spent fuel damaging event with Alarm on one or more of the following: -

OR Ctmt Vent----------------------.-- (P601-19A-G9) b. survey indicates increased radiation level in the associated area FH Area Vent ---- (P601-I9A-Cl I )

1 Ctmt 209 Airlock --------- (P844-I A-AI )

Ctmt Fuel Hdlg Area ------------ (P844-1A-A3)

Aux Bldg Fuel Hdlg Area----- (P844-1A-A4)

OR

2. Valid indication of uncontrolled water level decrease in Aux Bldg Fuel Pools or Upper Ctmt Pools that has or will result in irradiated fuel assemblies becoming uncovered

Grand Gulf Nuclear Station Emergency Plan Procedure I Revision xx 10-s-01-1 Attachment I I ~ a a e 4of 11 1 ISSION PRODUCT BARRIER DEGRADATION Plant Modes: Power Operations Hot Shutdown 1 ~ 1

,oss of any two Fission Product Barriers with Loss Loss or Potential Loss of any two Fission Product Loss or Potential Loss of either Fuel Clad Reactor Loss or Potential Loss of Primary Containment Potential Loss of third barrier Barriers Pressure Boundary Emergency Action Level:

Emergency Action Level: Emergency Action Level: Emergency Action Level: 1, Loss or Potential Loss of Primary

1. Loss or Potential Loss of any two Fission 1. Loss or Potential Loss of either Fuel Clad or Containment I. Loss of any two Fission Product Barriers Reactor Pressure Boundary Product Barriers AND

2. Loss or Potential Loss of third barier.

Fission Product Barrier Matrix Fuel Clad R actor

~

Pressure

_ ~ _

Boundarv Primarv Containment Parameter I Loss Potential Loss Parameter Loss 1 Potential Loss Parameter Loss Potential Loss I Primary Coolant Activity Coolant activity

>300 pcilml dose eq. 1 ~ 3 1 None Drywell Pressure

1.39 psig in drywell with indications of a leak in the drywell I None Primary Ctmt Press Unexplained loss of pressure following initial pressure increase

>22 psig in Pri Ctmt RPV water level cannot RPV water level RPV water level cannot I H2 igniters de-energized RPV Water Level be restored above

-192 in.

cannot be restored above -167 in.

RPV Water Level be restored above

-167 in. with indications of a leakin thedrywell I

~

None Hydrogen Concentration None and either DW H2 ~

or

- Ctmt H2 Unsafe Zone in HDOL 9 %

Unisolable Reactor I Drywell Rad Monitoring I >5000 Whr None Unisolable RClC or MSL break Pressure Boundary leaka e>50 gpm RPV Water Level None Entry into SAP 1, 5 or 6 Reactor Pressure Area TemD or Area Rad MSL Rad level > the Hi Boundary Leak Rate > Alert Valu; in Table Inability to isolate Primary MSL Rad Monitoring Hi Alarm Setpoint (P608- None F1 with confirmed Ctmt when isolation is None 18A-C4, P608-19A-C4) Reactor Pressure required Primary Ctmt Isolation Primary Ctmt venting ED Judgment Other Other SRVs SRV stuck open None Failure or Bypass reauired bv SAPS Area Temp or Area Rad ED Judgment Other Other > SAE I GE Value in Table F l with confirmed I None Reactor Pressure Boundary leak in the area Pri Ctmt Rad Monitorina None >11.500 Whr ED Judgment Other Other

Grand Gulf Nuclear Station Emergency Plan Procedure I 10-s-01-1 Revision xx I Attachment I lPaae5 of 11 I Table F1 Area Temperature Area Radiation Level Parameter Alert Limit SAE I GE Limit 185°F 235°F MSL Pipe Tunnel Temp. (P601-19A/l8A-A3/A4) (E31-N064A,B,C,D,E,F) 165°F 225°F RHR-A Equip Area Temp. (P6O1-2OA-B1) (E31-N068A,N61OA) 165°F 225°F RHR HX A Hatch Rad RHR-B Equip Area Temp. (P601-20A-B1) (E31-N068B,N61OB) 185°F 212°F RClC Equip Area Temp. (P601-21A-G3) (E31-N602A/B) 170°F NA RWCU Pmp Rm 1 Temp (P680-11A-A1) i 7i vn ro A ~

RWCU Pmp Rm 2 Temp NA (P680-11A-A2)

SGTS Fltr Trn Rad 8 x 102MWHR I lP844-1A-C5) I

Grand Gulf Nuclear Station Emergency Plan Procedure I 1n-s-nl-1 I Revision xx I I Attachment I I Page6 of 11 1 IAZARDS AND OTHER MALFUNCTIONS

.is1 111213141511) security event resulting in loss of physical control of >onfirmed security event in a plant Vital Area Confirmed security event in plant protected area Confirmed security event which indicates a potential

he facility jegradation in the level of safety of the plant Emergency Action Level: Emergency Action Level:

1 Emergency Action Level:

Emergency Action Level: 1. Site Security Code Red (Armed adversary Site Security Code Orange (Armed adversary has entered any power block building or Vital attempting to or has crossed protectedarea fence) 1. A credible threat notification received from,

1. Loss of physical control of the Control Room Area) or validated by, a trustworthy source (FBI, due to a security event NRC, Claiborne County Sheriffs Office, OR Plant Management, Site Security, etc.)

Eaxmple: A report from Site Security of an

2. Loss of physical control of the Remote unauthorized attempted PA entry should be Shutdown Panel due to a security event considered a credible threat.

OR OR

3. Loss of physical control of adequate core 2. Site Security Code Yellow (Armed cooling or reactivity control capability adversary attempting to or has entered company property)

HG2 11121314rJTc HA2 ~

HU2 ~

Conditions exist which in the judgment of the Conditions exist which in the judgment of the Conditions exist which in the judgment of the Conditions exist which in the judgment of the Emergency Director warrant declaration of a Emergency Director warrant declaration of a Emergency Director warrant declaration of an Alert Emergency Director warrant declaration of an General Emergency Site Area Emergency Unusual Event Emergency Action Level:

Emergency Action Level: Lrgency Action Level: Emergency Action Level:

1. Conditions exist which in the judgment of the

1. Conditions exist which in the judgment of the 1. Conditions exist which in the judgment of the Emergency Director indicate that events are in 1. Conditions exist which in the judgment of the Emergency Director indicate that events are in Emergency Director indicate that events are in progress or have occurred which involve actual or Emergency Director indicate that events are in progress or have occurred which involve actual progress or have occurred which involve actual potential substantial degradation of the level of progress or have occurred which indicate a or imminent substantial core degradationor or likely major failures of plant functions safety of the plant. Any releases are expected to be potential degradation of the level of safety of melting with potential loss of containment needed for protection of the public. Any releases limited to small fractions of the EPA Protective the plant. No releases of radioactive material integrity. Releases can be reasonably expected are not expected to result in exposure levels Action Guideline exposure limits. requiring offsite response or monitoring are to exceed EPA ProtectiveAction Guideline which exceed EPA Protective Action Guideline expected unless further degradation of safety exposure levels offsite for more than the exposure levels beyond the site boundary. systems occur immediate area.

HA3 Control Room evacuation has been Initiated and Control Room evacuation has been initiated plant control cannot be established Emergency Action Level:

Emergency Action Level: 1. Control Room evacuation has been directed p

1. Control Room evacuation has been directed per 0!j-1-02-ll-1 , Shutdown from the Remote Shutdown 05-1-02-11-1, Shutdown from the Remote Panel Shutdown Panel, and control of the plant c be established in < I 5 minutes

Grand Gulf Nuclear Station Emergency Plan Procedure 104-01-1 I Revision xx Attachment I I ~ a a e 7of 11 dA4 qatural or destructive phenomena affecting a qatural or destructive phenomena affecting the dital Area irotected area Emergency Action Level: Emergency Action Level:

1. Verified earthquake detected by in plant seismic 1. Verified earthquake detected by in plant instrumentation greater than OBE seismic instrumentation

-OR -

OR

2. Tornado resulting in visual damage to a vital area 2. Tornado observed in protected area OR -

OR

3. Vehicle crash into a vital area structure resulting 3. Vehicle crash into a power block structure in visual damage to vital area -

OR OR 4. Explosion within the protected area causing

4. Explosion causing visual damage to vital area damage to power block structure or equipment OR

-OR

5. Main turbine failure-generated missile resulting in visible damage to safety related equipment 5. Main turbine failure resulting in visual turbine Fire within the power block affecting the operability of plant safety systems required to establish or maintain HU4 casing or generator seal damage 11121314/511:

Fire within the power block not extinguished within 15 minutes of detection safe shutdown Emergency Action Level:

Emergency Action Level: 1. Fire in power block not extinguished within

1. Fire in the power block causing visual damage to 15 minutes of either:

plant safety equipment required to establish

a. Main control room notification maintain safe shutdown.

b. Verification of annunciators HA6 1 11 . " .HU5 111213141511:

Release of toxic or flammable gases within or Release of toxic flammable gases deemed contiguous to a Vital Area which jeopardizes operation detrimental to safe operation of the plant of safety systems required to establish or maintain safe shutdown. Emergency Action Level:

1. Determination of toxic, oxygen displacing or Emergency Action Level:

flammable gases in amount sufficient to

1. Determination of toxic, oxygen displacing or disrupt normal plant operation flammable gases in a Vital Area, that must be manned for safe operation of the plant, immediately dangerous to life and health or

> lower flammability limit

Grand Gulf Nuclear Station Emergency Plan Procedure 10-s-01-1 I Revision xx Attachment I I Page8 of 11 Dlant Modes: Power Operations tartup Hot Shutdown Cold Shutdown Refueling @ Defueled l1r213/ p4J 1 ~ 1 ~

'rolonged loss (>4 hrs) of all offsite and onsite AC ,oss of all offsite and onsite AC power to Div I & II 4C power to Div I & II ESF busses reduced to a single -oss of all offsite power to ESF busses for lower to Div I & II ESF busses ESF busses Dower source for > I 5 minutes such that any additional

I 5 minutes single failure would result in loss of AC power to both Emergency Action Level: Div I & I I ESF busses Emerqencv Action Level:

fmernencv Action Level:

1. Loss of AC power to 15AA and 16AB I. Loss of AC power to 15AA a 16AB Emerqencv Action Level:

1. Loss of power from E S F I I and ESF21 and AND ESFl2 transformers for >15 minutes AND 1. AC power to 15AA and 16AB reduced to only Failure to restore power to either 15AA or one of the following sources for >15 minutes:

Either: 16AB within 15 minutes from the time of loss

a. ESFl1 gr ESF21 gr ESF12 transformers

a. Restoration of power to either 15AA gr of both offsite and onsite AC power 16AB within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely -

OR OR b. DGI 1 or DG12 diesel generators

b. Conditions are imminent that a loss of two fission product barriers and loss or SA2 m]

potential loss of the third (FGI) is Loss of all offsite and onsite AC power to Div I & II expected to occur prior to restoration of ESF busses power to either 15AA or 16AB. Emerqencv Action Level:

1. Loss of AC power to 15AA and 16AB AND Failure to restore power to either 15AA a 16AB within 15 minutes from the time of loss of both offsite and onsite AC power Loss of all vital DC power Unplanned loss of required DC power for

I 5 minutes Emernencv Action Level:

1. 1IDA and 11DB <I05 VDC for > I 5 minutes. Emergency Action Level:

1. Unplanned reduction in 11DA and 11DB to 4 0 5 VDC AND

2. Unable to restore either 11DA 11DB battery charger within 15 minutes after reaching 105 VDC

Grand Gulf Nuclear Station Emergency Plan Procedure lo-$01 -1 I Revision xx Attachment I I Paae9 of 11 MALFUNCTIONS lant Modes: Power Operations 11_1 Startup 13IHot Shutdown U

141 U

Cold Shutdown IslRefueling UDefueled

-s3 iA3 ailure of the reactor protection system to complete ailure of reactor protection system to complete 'ailure of reactor protection system to complete n automatic scram and manual scram was not iitiate an automatic reactor scram once a reactor iitiate an automatic reactor scram once a reactor uccessful gICJ there is indication of an extreme rotection system setpoint has been exceeded and irotection system setpoint has been exceeded hallenge to the ability to cool the core ianual scram was not successful 2anual scram was successful Emergency Action Level: ,mergencyAction Level: fmergency Action Level:

1. Automatic gICJ manual scram failed to rapidly 1. Automatic scram and manual failed to rapidly 1. Automatic scram failed to rapidly insert sufficient insert sufficient control rods to bring the insert sufficient control rods to bring the control rods to bring the reactor subcritical, and a reactor subcritical reactor subcritical manual scram was successful AND

a. RPV parameters requiring entry into SAPS OR

b. RPV pressure and suppression pool temperature cannot be maintained in the HCTL Safe Zone is4 su3

,ass of RPV inventory affecting fuel clad integrity .oss of RPV inventory affecting core decay heat .ass of RPV inventory with irradiated fuel in the RPV Loss of RPV inventory with containment challenged with irradiated fuel in emoval capability with irradiated fuel in the RPV Emerqency Action Level: Emergency Action Level:

he RPV Imergency Action Level:

1. Loss of RPV inventory as indicated by RPV level 1. Unidentified or pressure boundary leakage Imergency Action Level: 1. a. Loss of RPV inventory <-150.3 in. (Level 1) > 10 gpm

1. RPV level: AND -

OR OR

2. Identified leakage > 35 gpm

a. <-I67 in. for >30 minutes b. RPV level cannot be monitored for >30 2. a. Loss of RPV inventory OR minutes AND E Unplanned loss of RPV inventory

b. cannot be monitored with indication of -

OR b. RPV level cannot be monitored for > I 5 core uncovery for >30 minutes Emergency Action Level:

2. a. RPV level e-156.3in. with containment minutes AND closure not established 1. RPV water level cannot be restored and maintained above 11.4 in.

2. a. Containment closure not established -

OR OR b. RPV level <-I67 in. with containment su5 closure established

b. Containment pressure >22 psig Unplanned loss of RPV inventory with irradiated OR fuel in the RPV

c. Containment hydrogen concentration > I 9% Emergency Action Level:

OR 1. Unplanned RPV level decrease below the RPV flange for > I 5 minutes

d. Any EP-4 radiation monitor reading above -

OR its Max Safe Value 2. a. Loss of RPV inventory AND

b. RPV level cannot be monitored

Grand Gulf Nuclear Station Emergency Plan Procedure 10-s-01-1 I Revision xx Attachment I I Page10 of 11 ISYSTEM MALFUNCTIONS Blant Modes: MPower Operations Startup MHot Shutdown Cold Shutdown HRefueling UDefueled is5 m LlJ m

LJJ Zomplete loss of heat removal capability nability to maintain plant in Cold Shutdown with Jnplanned loss of decay heat removal capability radiated fuel in the RPV with irradiated fuel in the RPV imergency Action Level:

imergency Action Level: Emergency Action Level:

1. Inability to maintain Suppression Pool temperature in the HCTL Safe Zone requiring 1. An unplanned event results in reactor coolant 1. An unplanned event results in reactor Emergency Depressurization per EP-3 temperature >200 O F without CTMT gncJ Reactor coolant temperature >200 O F Pressure Boundary integrity OR OR

2. An unplanned event results in reactor coolant

2. Loss of reactor coolant temperature and RPV level indication for > I 5 minutes temperature >200 O F for >20 minutes SeeNote with CTMT integrity and without Reactor Pressure Boundary integrity

-OR

3. An unplanned event results in reactor coolant temperature >200 O F for >60 minutes See Note -or results in RPV pressure increase > I 0 psig Inadvertent criticality Emergency Action Level:

1 . An unplanned sustained positive period observed on nuclear instrumentation 5A6 [ ~ l Inability to monitor a significant transient in Unplanned loss of most or all safety system Unplanned loss of most or all safety system progress mnunciation or indication in control room with either annunciation or indication in the control room for Emerpency Action Level: 2 significant transient in progress, compensatory > I 5 minutes ion-alarming indicators are unavailable

1. a. Loss of most or all annunciators on EmerGency Action Level:

IH13-P680,1H13-P601 1H13-P870 Emergency Action Level: 1. Unplanned loss of most or all safety system for > 15 minutes 1. Unplanned loss of most or all annunciators or annunciators or indication on 1H I3-P680, j4NJ indicators on 1H I3-P680, 1H I3-P601 gncJ 1H13-P601 m pJ 1H13-P870 for > I 5 minutes 1H I3-P870 for > 15 minutes

b. Indications needed to monitor criticality j4NJ core heat removal or fission product barrier are unavailable a. A significant transient is in progress AND -

OR

c. A significant transient is in progress b. Compensatory non-alarming indications are AND unavailable

d. Compensatory non-alarming indications are unavailable Note: If a decay heat removal system is in operation within this time frame and reactor coolant temperature is being reduced then this EiAL is not applicable.

Grand Gulf Nuclear Station Emergency Plan Procedure 10-s-01-1 I Page11 Revision xx of I1 Attachment I

'lant Modes: MPower Operations Startup H H o t Shutdown Cold Shutdown WRefueling IDIDefueled Table S1 Table S2 Onsite Communications Equipment Offsite Communications Equipment Unplanned loss of all onsite or offsite

'lant Radio System 411 telephone lines (commercial & fiber optic) communications capabilities

'lant Paging System Satellite telephone Emergency Action Level:

Sound Powered Phones 3HL I.Unplanned loss of all onsite n-plant Telephones NRC phones (ENS, HPN, MCL, RSCL, PMCL) communications equipment (See Table S1)

Cellular Phones -

OR UHF Radios 2. Unplanned loss of all offsite communications capability (See Table S2)

SUIO ~

Fuel clad degradation Emergency Action Level:

1. Offgas isolation due to valid Offgas Post Treatment monitor signal.

(1H13-P601-19A-C8)

Of?

2. Coolant sample activity >4.0 VCilml dose equivalent [I3' Inability to reach required shutdown within technical specification time limits Emergency Action Level:

1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time

Attachment 4 to GNRO-2003100067 GGNS Proposed EALs Bases - To Be Incorporated in Procedure

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION BASES for EMERGENCY CLASSIFICATIONS TABLE OF CONTENTS RECOGNITION CATEGORY PAGE

1. Abnormal Rad Levels I Radiological Effluents 4-13

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE I 10-s-01-1 1 Revision xx 1 Attachment II Page 2of88 SYSTEM MALFUNCTION

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 3of88 SYSTEM MALFUNCTION

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION AUI Initiating Condition -- UNUSUAL EVENT Unplanned release of gaseous liquid radioactivity to the environment that exceeds 2 x ODCM limit for 260 minutes Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1-or 2 -

or 3)

1. Liquid release > 4 x High High Alarm set point Gl?-RR-R521 (Discharge Radiation High High, SH22-P089-1B-D8) with failure of Gl?-F355 (Drain Basin Isolation Valve) to close for 2 60 minutes

2. High High Alarm on one or more of the following:

3. Confirmed sample analysis for gaseous a liquid release exceeds 2 x TRM Spec limit (6.11.1, 6.11.2, 6.11.4, 6.11.5, 6.11.6) for 1 6 0 minutes Basis:

This IC addresses a potential or actual decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. These controls are located in the Offsite Dose Calculation Manual (ODCM).

The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revisionxx Attachment II Page 5of88 SYSTEM MALFUNCTION AU I(cont)

The ODCM multiples are specified in ICs AUI and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NOT the magnitude of the associated dose or dose rate. Releases should not be prorated or averaged. For example, a release exceeding 4x TRM Spec limit for 30 minutes does not meet the threshold for this IC.

UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points, etc.) on the applicable permit. The Emergency Director should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the Emergency Director should, in the absence of data to the contrary, assume that the release has exceeded 60 minutes.

EAL #Iaddresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed two times the TRM Spec. limit and releases are not terminated within 60 minutes.

This alarm setpoint is associated with a planned batch release. The setpoint is established by the ODCM to alarm at 50% of the TRM Spec. limit. Thus four times the setpoint corresponds with two times the TRM Spec. limit.

EAL #2 addresses normal effluent monitoring on release pathways for which a discharge permit would not normally be prepared. The set points for these release paths are established by the ODCM to alarm at 25% of the TRM Spec. limit. Use of the High High Alarm for any one of the release pathways provided early warning of a potential radiological release. Requiring a summation of all monitors including the non-routine SBGT release pathway ensures that all release pathways are considered when calculating the total release.

EAL #3 addresses uncontrolled releases that are detected by sample analysis, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage into river water systems, etc.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 6of88 SYSTEM MALFUNCTION AU2 Initiating Condition -- UNUSUAL EVENT Unexpected increase in plant radiation 0perating Mode Ap pI icabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1 o r 2 )

1. Valid Area Radiation Monitor survey indicates an unplanned increase in plant radiation levels by a factor of I000 full scale

2. Valid indication of uncontrolled water level decrease in Aux Bldg Fuel Pools Upper Ctmt Pools with irradiated fuel assemblies remaining covered by water AND

a. Valid Alarm on any of the following:

Aux Bldg Fuel Hdlg Area ---------------- (P844-lA-A4)

b. survey indicates increased radiation level in the associated area Basis:

EAL #Iaddresses UNPLANNED increases in in-plant radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, the reading on an area radiation monitor located on the containment floor may increase due to planned evolutions such as head lift. Generally, increased radiation monitor indications will need to combined with another indicator (or personnel report) of water loss. The term Full scale was included in the EAL to address those areas where the ARM range will not allow the determination of an increase by a factor of 1000 (i.e., the ARM range is too small). This event escalates to an Alert per IC AA2 if the increase in dose rates impedes personnel access necessary for safe operation.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 7of88 SYSTEM MALFUNCTION EAL #2 addresses a verified uncontrolled water level decrease in the Aux Bldg Fuel Pools (Spent fuel pool, fuel transfer canal, and cask storage pool) or the Upper Ctmt Pools (Reactor cavity, drier storage pool, and fuel transfer canal). The key word is uncontrolled. Planned level changes during refueling evolutions would not require entry into this IC.

When in Mode 5 EAL #2 addresses increased radiation levels as a result of water level decreases above the RPV flange or events that have resulted, or may result, in unexpected increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and may represent a potential degradation in the level of safety of the plant.

For Mode 5 events where the water level drops below the RPV flange classification would be via SU4.

This event escalates to an Alert per IC AA2 if irradiated fuel outside the reactor vessel is uncovered. For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Matrix in Modes 1-3.

J:ADM -SRVS/TECH~PU3/REVISION/lO/lOSOll.DOC

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 8of88 SYSTEM MALFUNCTION AA1 Initiating Condition - ALERT Unplanned release of gaseous or liquid radioactivity to the environment that exceeds 20 x ODCM limit for 215 minutes 0perat ing Mode AppI icabiI ity: Mode 1 ............. Power Operation Mode 2 ............. Startup Mode 3 ............. Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1-or 2 -

or 3)

1. Liquid release >40 x High High Alarm set point on G17-RR-R521 with failure of G15-F355 to close for 1 15 minutes

2. High High Alarm on one or more of the following:

AND Summation of all monitors (including SBGT A & B) exceeds 20 x TRM Spec limit (6.11.4) for 1 15 minutes

3. Confirmed sample analysis for gaseous or liquid release exceeds 20 x TRM Spec limit (6.11.1, 6.11.2, 6.11.4, 6.11.5, or 6.11.6 for 1 1 5 minutes Basis:

This IC addresses a potential or actual decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. These controls are located in the Offsite Dose Calculation Manual (ODCM),

The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 I Revision xx Attachment II Page 9of88 SYSTEM MALFUNCTION The multiples are specified in ICs AUI and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NOT the magnitude of the associated dose or dose rate. Releases should not be prorated or averaged.

UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoint, etc.) on the applicable permit. The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 15 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the Emergency Director should, in the absence of data to the contrary, assume that the release has exceeded 15 minutes.

EAL #Iaddresses radioactivity releases that for whatever reason cause effluent radiation monitor readings that exceed twenty times the alarm setpoint established by the radioactivity discharge permit.

This alarm setpoint may be associated with a planned batch release, or a continuous release path. In either case, the setpoint is established by the ODCM to warn of a release that is not in compliance.

Indexing the EAL threshold to the ODCM setpoint in this manner insures that the EAL threshold will never be less than the setpoint established by a specific discharge permit.

EAL #2 is similar to EAL #I, but is intended to address effluent or accident radiation monitors on non-routine release pathways (i-e., for which a discharge permit would not normally be prepared). The ODCM establishes a methodology for determining effluent radiation monitor setpoint. The ODCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing compliance with the regulatory commitments. Each of the identified vent monitors is set to alarm at 25% of the ODCM limit which provides an early warning for this EAL. A summation of all release points is required to determine the total release.

EAL #3 addresses uncontrolled releases that are detected by sample analysis, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage into river water systems, etc.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 10 of 88 SYSTEM MALFUNCTION AA2 Initiating Condition -- ALERT Release of radioactive material or increases in radiation levels within the facility that impedes operation of systems required to maintain safe operations or to establish or maintain cold shutdown Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1 o r 2 )

1. Valid radiation level 2 15 mWhr in the Control Room

2. Valid radiation level 2 80 Whr in the RHR A, B, C, HPCS, LPCS, or RClC room and access is required Basis:

This IC addresses increased radiation levels that impede necessary access to operating stations, or other areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain safe operation or perform a safe shutdown. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels is not a concern of this IC. The Emergency Director must consider the source or cause of the increased radiation levels and determine if any other IC may be involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself.

However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, an SAE or GE may be indicated by the fission product barrier matrix ICs.

This IC is not meant to apply to anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, etc.)

The value of 15mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section 111.0.3 of NUREG-0737, %larification of TMl Action Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert.

For areas requiring infrequent access, the value corresponds to the Max Safe Values in Table 3, 05-S-01-EP-4, Auxiliary Building Area Parameters. As used here, impede, includes hindering or interfering provided that the interference or delay is sufficient to significantly threaten the safe operation of the plant.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revisionxx Attachment II Page 11 of88 SYSTEM MALFUNCTION AA3 Initiating Condition - ALERT Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the reactor vessel Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Levels: (1 or3

1. Potential spent fuel damaging event with High High Alarm on one or more of the following:

2. Valid indication of uncontrolled water level decrease in Aux Bldg Fuel Pools that has =will result in irradiated fuel assemblies becoming uncovered

= Upper Ctmt Pools Basis:

This IC addresses specific events that have resulted, or may result, in unexpected increases in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment.

These events represent a loss of control over radioactive material and represent a degradation in the level of safety of the plant. These events escalate from IC AU2 in that fuel activity has been released, or is anticipated due to fuel heat up.

EAL # I addresses increased radiation monitor indications coincident with a potential fuel damaging event. Increased readings on ventilation monitors may be indication of a radioactivity release from the fuel, confirming that damage has occurred. Application of this Initiating Condition requires understanding of the actual radiological conditions present in the vicinity of the monitor. For example, the monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head EAL #2 indications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. If available, video cameras may allow remote observation.

Escalation would occur via IC AS1 or AGI or Emergency Director judgment.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 12 of 88 SYSTEM MALFUNCTION AS1 Initiating Condition -- SITE AREA EMERGENCY Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds I 0 0 mR TEDE or 500 mR CDE Thyroid for the actual projected duration of the release using actual meteorology.

0perat ing Mode AppI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1 or2) 1, Dose projection of > 100 mR TEDE at or beyond site boundary based on plant or field team data

2. Dose projection of > 500 mR CDE Thyroid at or beyond site boundary based on plant or field team data Basis:

This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed a small fraction of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. While these failures are addressed by other ICs, this IC provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone, e.g., fuel handling accident in spent fuel building.

The TEDE and CDE thyroid doses are set at 10% of the EPA PAG.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment i I Page 13 of 88 SYSTEM MALFUNCTION AGI Initiating Condition -- GENERAL EMERGENCY Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR TEDE or 5000 mR CDE Thyroid for the actual or projected duration of the release using actual meteorology.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (1 o r 2 )

1. Dose projection of > 1000 mR TEDE at or beyond site boundary based on plant or field team data

2. Dose projection of > 5000 mR CDE Thyroid at or beyond site boundary based on plant or field team data Basis:

This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. While these failures are addressed by other ICs, this IC provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone.

It is important to note that, for the more severe accidents, the release may be unmonitored or there may be large uncertainties associated with the source term andlor meteorology.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 14 of 88 SYSTEM MALFUNCTION FUI Initiating Condition -- UNUSUAL EVENT Loss Potential Loss of Primary Containment Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Emergency Action Level:

1. Loss or Potential Loss of Primary Containment Basis:

The Primary Containment barrier includes connections up to and including the outermost containment isolation valves.

See Primary Containment Parameters section for additional information.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION FA1 Initiating Condition -- ALERT Loss Potential Loss of either Fuel Clad Reactor Pressure Boundary Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Loss a Potential Loss of either Fuel Clad a Reactor Pressure Boundary Basis:

See Fuel Clad or Reactor Pressure Boundary Parameters sections for additional information.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 16 of 88 SYSTEM MALFUNCTION FS1 Initiating Condition - SITE AREA EMERGENCY Loss or Potential Loss of any two Fission Product Barriers 0perat ing Mode AppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Emergency Action Level:

1. Loss a Potential Loss of any two Fission Product Barriers Basis:

Loss two Fission Product Barriers represents a major failure of plant systems needed to protect public health and safety.

See Primary Containment, Fuel Clad or Reactor Pressure Boundary Parameters sections for additional information.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 17 of 88 SYSTEM MALFUNCTION FGI Initiating Condition - GENERAL EMERGENCY Loss of any two Fission Product Barriers with Loss Potential Loss of third barrier Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Loss of any two Fission Product Barriers

2. Loss Potential Loss of third barrier Basis:

Conditions required to cause loss of two Fission Product Barriers with Loss or Potential Loss of the third barrier could reasonably be expected to cause or create a potential to cause a radiological release exceeding the EPA Protective Action Guidelines.

See Primary Containment, Fuel Clad or Reactor Pressure Boundary Parameters sections for additional information.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 18 of 88 SYSTEM MALFUNCTION Fuel Clad Parameters Parameter:

Primary Coolant Activity Level 0perating Mode A ppI icabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Coolant activity >300 pCilml dose equivalent Potential Loss: None Basis:

LOSS:

This amount of coolant activity is well above that expected for iodine spikes and corresponds to less than 5% fuel clad damage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad Barrier is considered lost.

POTENTIAL LOSS:

There is no equivalent "Potential Loss" EAL for this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 19 of 88 SYSTEM MALFUNCTION Fuel Clad Parameters Parameter.

RPV Water Level Operating Mode Applicability: Mode 1 ............. Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: RPV water level cannot be restored above -192 in Potential Loss: RPV water level cannot be restored above -167 in Basis:

LOSS:

The -192 in. value corresponds to the level which is used in EOPs to indicate challenge of core cooling.

This corresponds to the Minimum Steam Cooling RPV Water Level. This is the minimum RPV water that assures maximum peak cladding temperature will not exceed 1500°F. This temperature is considered to be the cladding perforation threshold below which loss of cladding integrity due to oxidation pitting is not expected to occur.

POTENTIAL LOSS:

The -167in. value corresponds to the Top of Active Fuel RPV Water Level and is the same level value used in the Reactor Pressure Boundary barrier Loss EAL. If there is indication of a leak in the drywell, this level indicates a Loss of Reactor Pressure Boundary and a Potential Loss of the Fuel Clad barriers.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Fuel Clad Parameters Parameter:

Drywell Radiation Monitoring Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: ~ 5 0 0 0fUhr Potential Loss: None Basis:

LOSS:

A reading in excess of 5000 R/hr in he drywell is ,,idicative of approximately 5% clai failure an(

therefore is indicative of a loss of the fuel cladding barrier.

POTENTIAL LOSS:

There is no "Potential Loss" EAL associated with this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 21 of 88 SYSTEM MALFUNCTION Fuel Clad Parameters Parameter:

Main Steam Line Radiation Monitoring 0perat ing Mode AppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Main Steam Line Radiation level > Hi Hi Alarm Setpoint (P608-18A-C4, P608-19A-C4)

Potential Loss: None Basis:

LOSS:

The purpose of the Main Steam Line Radiation Monitoring system is to monitor for the gross release of fission products from the fuel indicating a loss of fuel cladding. The Main Steam Line Radiation Monitor setpoint [3xFPB] is selected high enough above background radiation levels to avoid spurious annunciations, yet low enough to promptly detect a gross release of fission products from the fuel.

POTENTIAL LOSS:

There is no "Potential Loss" EAL associated with this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 22of88 SYSTEM MALFUNCTION Fuel Clad Parameters Parameter:

Emergency Director Judgment Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Other Potential Loss: Other Basis:

LOSS or POTENTIAL LOSS:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the Fuel Clad barrier is lost or potentially lost. The inability to monitor the barrier should also be considered in this EAL as a factor in the Emergency Directors judgment that the barrier may be considered lost or potentially lost. The emphasis is on the need for an accurate assessment recoqnizinq that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Parameter:

Drywell Pressure 0perating Mode Ap pIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: >1.39 psig in the drywell with indications of a leak in the drywell Potential Loss: None Basis:

LOSS:

The drywell pressure is based on the drywell high pressure set point [I -39psig] which indicates a LOCA and automatically initiates the ECCS. The requirement to determine that a leak exists concurrently with the high pressure in the drywell assures that this EAL is limited to actual loss of Reactor Pressure Boundary barrier and not implemented during testing, loss of drywell cooling, etc.

POTENTIAL LOSS:

There is no "Potential Loss" EAL corresponding to this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 24of88 SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Parameter:

RPV Water Level 0perat ing Mode A ppIicabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: RPV water level cannot be restored above -167 in. with indications of a leak in the drywell Potential Loss: None Basis:

The -167 in. value is the same as the Fuel Clad barrier "Potential Loss" EAL and corresponds to the Top of Active Fuel RPV Water Level. The requirement to determine that a leak exists concurrently with the RPV low level assures that this EAL is limited to actual loss of Reactor Pressure Barrier events making it consistent with other EALs in this category. (See Reactor Pressure Boundary, Drywell Pressure EAL).

POTENTIAL LOSS:

There is no "Potential Loss" EAL corresponding to this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 25of88 SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Parameter:

Reactor Pressure Boundary Leak Rate 0perat ing Mode AppI icab iI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Unisolable RCIC a Main Steam Line break Potential Loss: Unisolable Reactor Pressure Boundary leakage >50 gpm Area Temp a Area Rad > Alert Value in Table F1 with confirmed Reactor Pressure Boundary leakage in the area.

Basis:

An unisolable RCIC or Main Steam Line break is a breach of the Reactor Pressure Boundary barrier.

Thus, this EAL is included for consistency with the Alert emergency classification.

POTENTIAL LOSS:

Potential loss of Reactor Pressure Boundary based on leakage is set at a level indicative of a small breach of the Reactor Pressure Boundary but is well within the makeup capability of normal and emergency high pressure systems. Core uncovery is not a significant concern for a 50 gpm leak, however, break propagation leading to significantly larger loss of inventory is possible. If primary system leak rate information is unavailable, other indicators of Reactor Pressure Boundary leakage should be used.

Potential loss of Reactor Pressure Boundary based on primary system leakage outside the primary containment is determined from Table F1. The Alert Limit column contains area temperatures and area radiation values in the areas of the main steam line tunnel, RCIC, etc., which indicate a direct path from the Reactor Pressure Boundary to areas outside primary containment. These values are the same as the Operating Limit in Table 3 of EP-4. The indicators should be confirmed to be caused by Reactor Pressure Boundary leakage in the area.

{Continued next page)

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I1 Page 26of88 SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Reactor Pressure Boundary Leak Rate (cont)

The area temperature or radiation values in the Alert Limit column are to be used to declare an Alert classification if no other barrier degradation is observed.

The GE / SAE Limit column contains the same values as the Max Safe Value in Table 3 of EP-4. The values in this column should be used when escalating to Site Area Emergency or General Emergency as multiple barriers degrade.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Parameter:

Safety Relief Valves Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: SRV stuck open Potential Loss: None Basis:

LOSS:

The SRV stuck open EAL identifies a SRV failure mode that results in a loss of the Reactor Pressure Boundary barrier. All methods of closing the SRV (switch in closed position, pulling fuses, etc.) should be exhausted before the Shift Manager declares the SRV stuck open.

POTENTIAL LOSS:

There is no "Potential Loss" EAL corresponding to this item.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 28of88 SYSTEM MALFUNCTION Reactor Pressure Boundary Parameters Parameter.

Emergency Director Judgment Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Other Potential Loss: Other Basis:

LOSS or POTENTIAL LOSS:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the Reactor Pressure Boundary barrier is lost or potentially lost. The inability to monitor the barrier should also be considered in this EAL as a factor in the Emergency Directors judgment that the barrier may be considered lost or potentially lost. The emphasis is on the need for an accurate assessment recognizing that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 29of88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter:

Primary Containment Pressure 0perat ing Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Unexplained loss of pressure following initial pressure increase Potential Loss: >22 psig in Primary Containment Basis:

Unexplained loss of pressure (Le., not attributable to containment spray or condensation effects) following an initial pressure increase indicates a loss of containment integrity. Containment pressure should increase as a result of mass and energy release into containment from a LOCA. Thus, containment pressure not increasing under these conditions indicates a loss of containment integrity.

This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated and could occur at less than the 22 psig used for the potential loss. The unexpected response is important because it is the indicator for a containment bypass condition. Due to the size of the Mark Ill containment small breaks may not be able to be detected by this EAL. Smaller breaks are addressed in the Primary Ctmt Isolation Failure Bypass EAL POTENTIAL LOSS:

The 22 psig value used for potential loss of containment is used in the EOPs and is based on the containment vent isolation valve operational limits. If containment vent valves are required to be operated above this pressure, damage to the valve may occur preventing the re-establishment of containment integrity.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 30of88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter:

Hydrogen Concentration 0perat ing Mode AppI icabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: None Potential Loss: H2igniters de-energized and either Drywell H2>9% or Containment H2in HDOL Unsafe Zone 6asis:

LOSS:

There is no "Loss" EAL corresponding to this item.

POTENTIAL LOSS:

Without hydrogen igniters in operation, the existence of a hydrogen concentration in the drywell or primary containment that exceeds the respective Hydrogen Deflagration Overpressurization Limit identifies a condition that could result in over pressurization of the drywell or containment if a hydrogen burn were to occur.

Conversely, with the hydrogen igniters in operation, hydrogen concentrations in excess of these limits indicates that sufficient hydrogen combustion has occurred to lower the oxygen concentration below the concentration needed to support further combustion. Under these conditions, as long as the hydrogen igniters remain in operation, any action that results in the addition of oxygen to the space will result in controlled hydrogen removal by combustion. Therefore, with hydrogen igniters in operation, there is no "Potential Loss" EAL for this item regardless of hydrogen concentration.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 31 of 88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter.

RPV Water Level Operating Mode Applicability: Mode I.............Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Emergency Action Level:

Loss: None Potential Loss: Entry into SAP 1 , 5 or 6 Basis:

LOSS:

There is no "Loss" EAL corresponding to this item.

POTENTIAL LOSS:

Entry into the Severe Accident Procedures (SAPs) indicates reactor vessel water level can not be restored and that core melt could occur. EOPs direct the operators to enter SAPs when Reactor Vessel Level cannot be restored and maintained greater than -192 in. Entry into the SAPs is a logical escalation in response to the inability to maintain reactor vessel level.

Even though entry into the SAPs is an indication that adequate core cooling may no longer exist and that core melt may eventually occur, under certain plant conditions there is confidence that the core will remain in the RPV. These plant conditions are identified by which SAP is entered. Entry into SAPs 5 or 6 are indicative of plant conditions that no longer provide confidence that the core will remain in the vessel thus creating a potential for containment failure if plant conditions do not improve. Entry into SAP 1 is indicative that vessel failure, due to molten core debris, has occurred which creates a potential for containment failure.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 I Revision xx Attachment II Page 32of88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter:

Primary Containment Isolation Failure or Bypass 0perat ing Mode A ppI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: Inability to isolate Primary Ctmt when isolation is required OR Primary Containment venting required by SAPs Area Temp Area Rad >SAE/GE Value in Table F-I with confirmed Reactor Pressure Boundary leak in the area.

Potential Loss: None Basis:

LOSS:

This EAL is intended to cover the inability to isolate the containment when containment isolation is required. In addition, the presence of area radiation or temperature alarms indicating unisolable primary system leakage outside the drywell are covered after a containment isolation. The indicators should be confirmed to be caused by Reactor Pressure Boundary leakage.

An intentional venting of primary containment for pressure control per SAPs to the secondary containment and/or the environment is considered a loss of containment due to the potential for a large radioactivity inventory to be present in the containment. Containment venting for pressure control when in the EOPs should not be considered a loss of containment because no significant radioactivity inventory is expected to be present in the containment when operating within the EOP limits.

POTENTIAL LOSS:

There is no "Potential Loss" EAL corresponding to this item.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 33of88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter:

Primary Containment Radiation Monitoring Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

Loss: None Potential Loss: > I WHr 1,500 Basis:

LOSS:

There is no "Loss" EAL corresponding to this item.

POTENTIAL LOSS:

In order to reach this dose rate in the containment, significant fuel damage well in excess of that required for loss of Reactor Pressure Boundary and Fuel Clad must have occurred. A major release of radioactivity, requiring offsite protective actions, from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant.

Regardless of whether containment is physically challenged or not, this amount of activity in the primary containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 34of88 SYSTEM MALFUNCTION Primary Containment Parameters Parameter:

Emergency Director Judgment 0perat ing Mode Ap pIicabiIity: Mode 1 ............. Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Emergency Action Level:

Loss: Other Potential Loss: Other Basis:

LOSS or POTENTIAL LOSS:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the Primary Containment barrier is lost or potentially lost. The inability to monitor the barrier should also be considered in this EAL as a factor in the Emergency Directors judgment that the barrier may be considered lost or potentially lost. The emphasis is on the need for an accurate assessment recognizinq that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION HUI Initiating Condition - UNUSUAL EVENT Confirmed security event which indicates a potential degradation in the level of safety of the plant Operating Mode Applicability: Mode 1 ............. Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Levels: (I or 2)

1. A credible threat notification received from, or validated by, a trustworthy source (FBI, NRC, Claiborne County Sheriffs Office, Plant Management, Site Security, Etc.) Example: A report from Site Security of an unauthorized attempted protected area entry should be considered a credible threat.

2. Site Security Code Yellow (Armed adversary attempting to or has entered company property)

Basis:

The intent of EAL 1 is to ensure that appropriate notifications for the security threat are made in a timely manner. The determination of credible is made by the Shift Manager (Emergency Director) with assistance from the Security Superintendent. Additional resources may be necessary to assist in this determination. These additional resources could include other sites, corporate, law enforcement or federal resources. The threat must be specific to Grand Gulf. Consideration should be given to the following types of events during the determination of credible: sabotage, hostage, extortion, civil disturbance, strike action, etc. EAL 1 is limited to security events that do not involve an armed attack (attempted entry by force) against the plant.

EAL 2, Site Security Code Yellow (Armed adversary attempting to or has entered company property) is limited to security events involving an armed attack against the plant. An armed attack against the plant is a unique security emergency that is expected to be an extremely fast moving event which presents an immediate and serious threat to human life. A site security code system is used to enhance communication for this event and allows immediate recognition and rapid notification for this event. It is imperative for personnel to take cover immediately to minimize loss of life. A Site Security Code Orange would result in escalation to an Alert.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 36of88 SYSTEM MALFUNCTION HU2 Initiating Condition - UNUSUAL EVENT Conditions exist which in the judgment of the emergency director warrant declaration of an Unusual Event.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occur.

Basis:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the plant conditions warrant declaration of an Unusual Event. The inability to monitor identified parameters should also be considered in this EAL as a factor in the Emergency Directors judgment that the hazard actually exists. The emphasis is on the need for an accurate assessment recoqnizing that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I1 Page 37of88 SYSTEM MALFUNCTION HU3 Initiating Condition -- UNUSUAL EVENT Natural destructive phenomena affecting the protected area Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level: (1 or 2 or 3 or 4 or 5)

1. Verified earthquake detected by in plant seismic instrumentation.

2. Tornado observed in the protected area.

3. Vehicle crash into a power block structure.

4. Explosion within the protected area causing damage to power block structure or equipment

5. Main turbine failure resulting in visual turbine casing or generator seal damage.

Basis:

The EALs in this IC are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. Areas identified in the EALs define the location of the event based on the potential for damage to equipment contained therein. Escalation of the event to an Alert occurs when the magnitude of the event is sufficient to result in damage to equipment contained in the specified location.

EAL #Idamage may be caused to some portions of the site, but should not affect ability of safety functions to operate. Method of detection can be based on in plant instrumentation, validated by a reliable source, or operator assessment. As defined in the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, a "felt earthquake" is:

An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.

EAL #2 is based on the assumption that a tornado striking (touching down) within the protected area may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 38of88 SYSTEM MALFUNCTION HU3(cont)

EAL #3 is intended to address crashes of vehicle types large enough to cause significant damage to plant structures containing functions and systems required for safe shutdown of the plant. If the crash is confirmed to have caused damage in a plant Vital Area, the event may be escalated to Alert.

EAL #4 only those explosions of sufficient force to damage permanent structures or equipment within the power block should be considered. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage is sufficient for declaration. The Emergency director also needs to consider any security aspects of the explosion, if applicable.

EAL #5 is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires and flammable gas build up are appropriately classified via HU4 and HU5.

Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by missiles generated by the failure or by the radiological releases. These latter events would be classified by the Radiological ICs or Fission Product Barrier ICs.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 39of88 SYSTEM MALFUNCTION HU4 Initiating Condition -- UNUSUAL EVENT Fire within power block not extinguished within 15 Minutes of detection.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. FIRE in protected area not extinguished within 15 minutes of either:

a. Main control room notification

b. Verification of annunciators Basis:

The purpose of this IC is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. As used here, Detection is visual observation and report by plant personnel or sensor alarm indication. The 15 minute time period begins with a credible notification that a fire is occurring, or indication of a valid fire detection system alarm. Verification of a fire detection system alarm includes actions that can be taken within the control room to ensure that the alarm is not spurious. A verified alarm is assumed to be an indication of a fire unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the fire and to discriminate against small fires that are readily extinguished (e.g., smoldering waste paper basket). The intent of this IC is not to include buildings (i.e,, warehouses) or areas that are not contiguous (in actual contact with or immediately adjacent) to plant Vital Areas. This excludes fires within administration buildings, waste-basket fires, and other small fires of no safety consequence.

Escalation to a higher emergency class is by IC HA5, "Fire affecting the operability of plant safety systems required to establish or maintain safe shutdown".

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 40of88 SYSTEM MALFUNCTION HU5 Initiating Condition - UNUSUAL EVENT Release of toxic or flammable gases deemed detrimental to normal operation of the plant.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Levels:

1. Determination of toxic, oxygen displacing or flammable gases in amount sufficient to disrupt normal plant operation.

Basis:

This IC is based on the existence of uncontrolled releases of toxic, oxygen displacing or flammable gas that may enter the site boundary and affect normal plant operations. It is intended that releases of toxic, oxygen displacing or flammable gases are of sufficient quantity, and the release point of such gases is such that normal plant operations would be affected. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation. The EAL is intended to not require significant assessment or quantification. The IC assumes an uncontrolled process that has the potential to affect plant operations, or personnel safety.

Escalation of this EAL is via HA6, which involves a quantified release of toxic or flammable gases within or contiguous to a vital area which jeopardizes operation of safety systems required to establish or maintain safe shutdown.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 41 of 88 SYSTEM MALFUNCTION HA1 Initiating Condition - ALERT Confirmed security event in plant protected area 0perat ing Mode Ap pIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 ............. Refueling Mode D .............Defueled Emergency Action Levels:

1. Site Security Code Orange (Armed adversary attempting to or has crossed the protected area fence)

Basis:

Site Security Code Orange (Armed adversary attempting to or has crossed the protected area fence) is limited to security events involving an armed attack against the plant. An armed attack against the plant is a unique security emergency that is expected to be an extremely fast moving event which presents an immediate and serious threat to human life. A site security code system is used to enhance communication for this event and allows immediate recognition and rapid notification for this event. It is imperative for personnel to take cover immediately to minimize loss of life. A Site Security Code Red would result in escalation to a Site Area Emergency.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision M Attachment II Page 42of88 SYSTEM MALFUNCTION HA2 Initiating Condition -- ALERT Conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Basis:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the plant conditions warrant declaration of an Alert. The inability to monitor identified parameters should also be considered in this EAL as a factor in the Emergency Directors judgment that the hazard actually exists. The emphasis is on the need for an accurate assessment recognizing that over-classification, as well as under-classification. is to be avoided.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 43of88 SYSTEM MALFUNCTION HA3 Initiating Condition -- ALERT Control room evacuation has been initiated.

0perat in g Mode Ap pI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Level:

1. Control Room evacuation has been directed per 05-I-02-11-1, Shutdown from the Remote Shutdown Panel.

Basis:

With the control room evacuated, additional support, monitoring and direction through the Technical Support Center or other emergency response facilities is desirable. Inability to establish plant control from outside the control room will escalate this event to a Site Area Emergency per IC HS3.

J:ADM-SRVS/TECH-PUB/REVISION/IO/IOSOII.DOC

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION HA4 Initiating Condition -- ALERT Natural a destructive phenomena affecting the plant Vital Area Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Levels: (1-or 2 - or 3 -or 4 a 5)

1. Verified earthquake detected by in plant seismic instrumentation greater than OBE

2. Tornado resulting in visual damage to a vital area

3. Vehicle crash into a vital area structure resulting in visual damage to vital area

4. Explosion causing visual damage to vital area

5. Main turbine failure-generated missiles resulting in visual damage to safety related equipment Basis:

The occurrence of visible damage and/or degraded system response is intended to discriminate against lesser events. The EALs in this IC escalate from the EALs in HU3 in that the occurrence of the event has resulted in visible damage to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control indications of degraded system response or performance.

The initial "report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Escalation to higher classifications may occur on the basis of other ICs (e.g., System Malfunction).

EAL #Iis based on UFSAR design basis. Seismic events of this magnitude can result in a plant Vital Area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

EAL #2 is based on observation of visible damage within a vital area believed to be caused by tornadic winds and is an escalation of EAL HU3.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 45of88 SYSTEM MALFUNCTION EAL #3 is intended to address crashes of vehicle types large enough to cause significant damage to plant structures containing functions and systems required for safe shutdown of the plant.

EAL#4 addresses an explosion and not the degradation in performance of affected systems. System degradation is addressed in the System Malfunction EALs. The reference to visual damage is used to identify the magnitude of the explosion and to discriminate against minor explosions. The reference to vital area is included to discriminate against explosions in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the explosion was large enough to cause damage to these systems. Thus, the designation of a single train was intentional and is appropriate when the explosion is large enough to affect more than one component.

This situation is not the same as removing equipment for maintenance that is covered by a plant's Technical Specifications. Removal of equipment for maintenance is a planned activity controlled in accordance with procedures and, as such, does not constitute a substantial degradation in the level of safety of the plant. An explosion is an unplanned activity and, as such, does constitute a substantial degradation in the level of safety of the plant. In this situation, an Alert classification is warranted.

EAL#5 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. This EAL is, therefore, consistent with the definition of an Alert in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 46of88 SYSTEM MALFUNCTION HA5 Initiating Condition 9- ALERT Fire in the power block affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Operating Mode ApplicabiI ity: Mode I.............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Level:

Fire in the power block causing visual damage to plant safety equipment required to establish or maintain safe shutdown Basis:

Site-Specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown. This will make it easier to determine if the fire is potentially affecting one or more redundant trains of safety systems. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radiological Effluent, or Emergency Director Judgment ICs.

This EAL addresses a fire and not the degradation in performance of affected systems. System degradation is addressed in the System Malfunction EALs. The reference to damage of systems is used to identify the magnitude of the fire and to discriminate against minor fires. The reference to safety systems is included to discriminate against fires in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the fire was large enough to cause damage to these systems. Thus, the designation of a single train was intentional and is appropriate when the fire is large enough to affect more than one component.

This situation is not the same as removing equipment for maintenance that is covered by a plant's Technical Specifications. Removal of equipment for maintenance is a planned activity controlled in accordance with procedures and, as such, does not constitute a substantial degradation in the level of safety of the plant. A fire is an unplanned activity and, as such, does constitute a substantial degradation in the level of safety of the plant. In this situation, an Alert classification is warranted.

The inclusion of a "report of visible damage" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION HA6 Initiating Condition -- ALERT Release of toxic flammable gases within or contiguous to a vital area which jeopardizes operation of safety systems required to establish maintain safe shutdown.

0perat ing Mode Ap pI icabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Levels:

Determination of toxic, oxygen displacing or flammable gasses in a vital area, that must be manned for safe operation of the plant, immediately dangerous to life and health > lower flammability limit.

Basis:

This IC is based on gases that affect the safe operation of the plant. This IC applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas (Le., Standby Service Water basin or pump house). The intent of this IC is not to include buildings (e.g., warehouses) or other areas that are not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radioactive Effluent, or Emergency Director Judgment ICs.

EAL is met if measurement of toxic or oxygen displacing gas concentration results in an atmosphere that is IDLH within a vital area or any area or building contiguous to vital area. Exposure to an IDLH atmosphere will result in immediate harm to unprotected personnel, and would preclude access to any such affected areas.

Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems or to repair equipment/components. This EAL addresses concentrations at which gases can ignite/support combustion. An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Once it has been determined that an uncontrolled release is occurring, then sampling must be done to determine if the concentration of the released gas is within this range.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 48of88 SYSTEM MALFUNCTION HSI Initiating Condition - SITE AREA EMERGENCY Confirmed security event in a plant vital area 0perat ing Mode AppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 ............. Refueling Mode D .............Defueled Emergency Action Levels:

1. Site Security Code Red (Armed adversary has entered any power block building or vital area)

Basis:

Site Security Code Red (Armed adversary has entered any power block building or vital area) is limited to security events involving an armed attack against the plant. An armed attack against the plant is a unique security emergency that is expected to be an extremely fast moving event which presents an immediate and serious threat to human life. A site security code system is used to enhance communication for this event and allows immediate recognition and rapid notification for this event. It is imperative for personnel to take cover immediately to minimize loss of life. A security event resulting in loss of physical control of the facility would result in escalation to a General Emergency.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 49of88 SYSTEM MALFUNCTION HS2 Initiating Condition - SITE AREA EMERGENCY Conditions exist which in the judgment of the Emergency Director warrant declaration of Site Area Emergency.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Basis:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the plant conditions warrant declaration of a Site Area Emergency. The inability to monitor identified parameters should also be considered in this EAL as a factor in the Emergency Directors judgment that the hazard actually exists. The emphasis is on the need for an accurate assessment recoqnizinq that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 50of88 SYSTEM MALFUNCTION HS3 Initiating Condition - SITE AREA EMERGENCY Control Room evacuation has been initiated and plant control cannot be established.

0perat ing Mode A ppI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. Control Room evacuation has been directed per 05-1-02-11-1, Shutdown from the Remote Shutdown Panel, control of the plant cannot be established in < 15 minutes Basis:

The intent of this IC is to capture those events where control of the plant cannot be re-established in a timely manner. This time should not exceed 15 minutes without additional justification. The determination of whether or not control is established at the remote shutdown panel is based on Emergency Director (ED) judgment. The ED is expected to make a reasonable, informed judgment within the site-specific time for transfer that the licensee has control of the plant from the remote shutdown panel.

The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions. Typically, these safety functions are reactivity control (ability to shutdown the reactor and maintain it shutdown), reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink).

Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological Effluent, or Emergency Director Judgment ICs.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 51 of88 SYSTEM MALFUNCTION HGI Initiating Condition - GENERAL EMERGENCY Security event resulting in loss of physical control of the facility 0pe rat ing Mode A p p I ic a b iIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level: (1 or 2 or 3)

1. Loss of physical control of the Control Room due to a security event

2. Loss of physical control of the Remote Shutdown Panel due to a security event

3. Loss of physical control of adequate core cooling or reactivity control capability Basis:

This IC encompasses conditions under which a hostile force has taken physical control of vital areas (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. Typically, these safety functions are reactivity control (ability to shut down the reactor and keep it shutdown) reactor water level and decay heat removal (ability to cool the core). Loss of both SSW systems does not by itself constitute loss of decay heat removal capability. Example: In an extended Station Blackout condition using RCIC to maintain RPV water level above Minimum Steam Cooling Water Level, decay heat is removed by steam through an SRV to the suppression pool. If containment pressure increases due to suppression pool heat up, the containment can be vented to the environs if necessary to maintain containment pressure within EOP limits with no significant radiological consequences.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 52of88 SYSTEM MALFUNCTION HG2 Initiating Condition - GENERAL EMERGENCY Other conditions existing which in the judgment of the Emergency Director warrant declaration of General Emergency.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D .............Defueled Emergency Action Level:

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Basis:

This EAL is not intended to be used to anticipate conditions already identified in other EALs. This EAL is intended to address unanticipated conditions, not addressed explicitly elsewhere, that can be used by the Emergency Director in determining whether the plant conditions warrant declaration of a General Emergency. The inability to monitor identified parameters should also be considered in this EAL as a factor in the Emergency Directors judgment that the hazard actually exists. The emphasis is on the need for an accurate assessment recoqnizinq that over-classification, as well as under-classification, is to be avoided.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 53of88 SYSTEM MALFUNCTION SUI Initiating Condition -- UNUSUAL EVENT Loss of all offsite power to ESF busses for > I 5 Minutes Operating Mode Applicability: Mode 1 ............. Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 ............. Cold Shutdown Mode 5 .............Refueling Emergency Action Level:

1, Loss of power from ESF-11 and ESF-21 and ESF-12 transformers for > I 5 minutes Basis:

Prolonged loss of offsite AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Loss of AC Power. This IC is met even if all emergency diesel generators start and provide AC power to the ESF busses. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the event to an Alert, due to subsequent loss of diesel generators such that only one source remains, will occur in accordance with IC SAI , (AC power capability to Div I & ll ESF busses reduced to a single power source for > I 5 minutes such that any additional single failure would result in loss of AC power to both Div & Div II ESF busses).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 54of88 SYSTEM MALFUNCTION su2 Initiating Condition -- UNUSUAL EVENT Unplanned loss of required DC power for > I 5 Minutes 0perat ing Mode A ppIicabiIity: Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Level:

1. Unplanned reduction in 11DA 1I D B voltage to 4 0 5 VDC AND Unable to restore either 1IDA 11DB battery charger within 15 minutes after reaching 105 VDC Basis:

The purpose of this IC and its associated EAL is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations.

This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

Unplanned is included in this IC and EAL to preclude the declaration of an emergency as a result of planned maintenance activities. Routinely plants will perform maintenance on a Train related basis during shutdown periods. It is intended that the loss of the operating (operable) train is to be considered.

The 105 VDC is based on the minimum bus voltage necessary for the operation of safety related equipment.

Escalation of the event to an Alert, if the loss results in the inability to maintain cold shutdown, will occur in accordance with SA5 (Inability to Maintain Plant in Cold Shutdown with Irradiated Fuel in the RPV).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 55 of 88 SYSTEM MALFUNCTION su3 Initiating Condition -- UNUSUAL EVENT Reactor Pressure Boundary leakage Operating Mode Applicability: Mode 1 ............. Power Operation Mode 2 .............Startup Mode 3 ............. Hot Shutdown Emergency Action Levels:

1. Unidentified or pressure boundary leakage >10 gpm

2. Identified leakage >35 gpm Basis:

This IC is included because it may be a precursor of more serious conditions and is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified and pressure boundary leakage was selected because it is greater than the minimum detectable amount used as the Technical Specification limit and is expected to be observable with normal control room indications without lengthy calculations.

The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage. The 35 gpm value for the unidentified and pressure boundary leakage was selected because it is greater than the minimum detectable amount used as the Technical Specification limit and is expected to be observable with normal control room indications without lengthy calculations.

The difference between IC SU3 and IC SU5 addresses the different Reactor Pressure Boundary conditions that exist between refueling and other operating modes. In other operating modes the Reactor Pressure Boundary will be intact and RPV level monitoring means are normally available. In the refueling mode the Reactor Pressure Boundary is not intact and RPV level is monitored by different means.

Escalation of the event to an Alert, in Modes 1, 2, & 3, will occur in accordance with IC FA1 (Loss or potential loss of any two barriers).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION su4 Initiating Condition -- UNUSUAL EVENT Unplanned loss of RPV inventory 0perat in g Mode Ap pIicabiI ity: Mode 4 .............Cold Shutdown Emergency Action Levels:

1. RPV water level cannot be restored and maintained above 11.4 in.

Basis:

This IC is included because it may be a precursor of more serious conditions and is considered to be a potential degradation of the level of safety of the plant. The words cannot be restored and maintained are use to be consistent with directions in the EOPs. The word unplanned is used to ensure planned evolutions which reduce RPV water level below 11.4 in. do not meet the criteria of this EAL.

Escalation of the event to an Alert, due to prolonged loss of RPV inventory in Mode 4, may occur in accordance with IC SA4 (Loss of RPV inventory with irradiated fuel in the RPV).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 570f 88 SYSTEM MALFUNCTION Initiating Condition -- UNUSUAL EVENT Unplanned loss of RPV inventory with irradiated fuel in the RPV Operating Mode Applicability: Mode 5 .............Refueling Emergency Action Levels:

1. Unplanned RPV level decrease below the RPV flange for > 15 minutes OR

2. a. Loss of RPV inventory and

b. RPV level cannot be monitored Basis:

This IC is included because it may be a precursor of more serious conditions and is considered to be a potential degradation of the level of safety of the plant. Refueling evolutions that decrease RPV water level below the RPV flange are carefully planned and procedurally controlled. An unplanned event that results in water level decreasing below the RPV flange warrants declaration of an Unusual Event due to the reduced RPV inventory that is available to keep the core covered. The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of refill that should be available. If level cannot be restored in this time frame then it may indicate a more serious condition exists.

The difference between IC SU3 and IC SU5 addresses the different Reactor Pressure Boundary conditions that exist between refueling and other operating modes. In other operating modes the Reactor Pressure Boundary will be intact and RPV normal level monitoring means are available. In the refueling mode the Reactor Pressure Boundary is not intact and RPV level is monitored by different means. In the refueling mode, normal means of core temperature indication and RPV level indication may not be available. Redundant means of RPV level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RPV inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RPV leakage.

EAL#I involves a decrease in RPV level below the top of the RPV flange that continues for >15 minutes due to an unplanned event. This EAL is not applicable to decreases in flooded reactor cavity level (covered by IC AU2 EAL1) until such time as the level decreases to the level of the vessel flange

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 58of88 SYSTEM MALFUNCTION Escalation of the event to an Alert, due to continued loss of RPV Inventory, will occur in accordance with either IC SA4 (Loss of RPV inventory with Irradiated Fuel in the RPV) or IC SA5 (Inability to Maintain Plant in Cold Shutdown with Irradiated Fuel in the RPV).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 59of88 SYSTEM MALFUNCTION SU6 Initiating Condition -- UNUSUAL EVENT Unplanned loss of decay heat removal capability with irradiated fuel in the RPV Operating Mode Applicability: Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Levels:

I. An unplanned event results in reactor coolant temperature exceeding 200°F OR

2. Loss of all reactor coolant temperature and RPV level indication for > 15 minutes Basis:

This IC is included as a NOUE because it may be a precursor of more serious conditions and is considered to be a potential degradation of the level of safety of the plant. In cold shutdown the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RPV inventory. Since the Reactor Pressure Boundary usually remains intact in the cold shutdown mode a large inventory of water is available to keep the core covered.

During refueling the level in the RPV will normally be maintained above the RPV flange. Refueling evolutions that decrease water level below the RPV flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in reactor coolant temperatures depending on the time since shutdown. Unlike the cold shutdown mode, normal means of core temperature indication and RPV level indication may not be available in the refueling mode. Redundant means of RPV level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted. However, if all level and temperature indication were to be lost in either the cold shutdown of refueling modes, EAL 2 would result in declaration of a NOUE if either temperature or level indication cannot be restored within 15 minutes from the loss of both means of indication.

Escalation of the event to an Alert, due to continued loss of RPV Inventory or reactor coolant temperature increase, will occur in accordance with IC SA5 (Inability to Maintain Plant in Cold Shutdown with Irradiated Fuel in the RPV).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 60of88 SYSTEM MALFUNCTION su7 Initiating Condition -- UNUSUAL EVENT Inadvertent criticality OPERATING MODE APPLICABILITY Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Level:

1. An unplanned sustained positive period observed on nuclear instrumentation.

Basis:

This IC addresses inadvertent criticality events. While the primary concern of this IC is criticality events that occur in Cold Shutdown or Refueling modes (NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States), the IC is applicable in other modes in which inadvertent criticalities are possible. This IC indicates a potential degradation of the level of safety of the plant, warranting a NOUE classification. This IC excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated).

This condition can be identified using period monitors. The term "sustained" is used in order to allow exclusion of expected short term positive periods from planned control rod movements. (Example: Short term positive periods as the result of the increase in neutron population due to subcritical multiplication)

Escalation of the event to an Alert will occur in accordance with either IC FA1 (Loss of potential loss of any two barriers) or IC HA6 (Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SU8 Initiating Condition -- UNUSUAL EVENT Unplanned loss of most or all safety system annunciation or indication in the control room for > I 5 minutes 0perat ing Mode AppI ica biIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Unplanned loss of most or all safety system annunciators or indication on 1H I3-P680, 1H I3-P601 and 1H I 3-P870 for >I 5 minutes Basis:

This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Quantification of "Most" is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

Escalation of the event to an Alert, if a transient is in progress during the loss of annunciation or indication, will occur in accordance with IC SA6 (Unplanned loss of most or all safety system annunciation or indication in control room wither either (1) a significant transient in progress, or (2) compensatory non-alarming indicators are unavailable).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 62of88 SYSTEM MALFUNCTION su9 Initiating Condition -- UNUSUAL EVENT Unplanned loss of all onsite or offsite communications capabilities Operating Mode Ap plicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Levels:

1. Loss of all onsite communications equipment (See Table S1)

2. Loss of all offsite communications equipment (See Table S2)

Table S1 Onsite Communications Equipment Plant Radio System Plant Paging System Sound Powered Phones In-plant telephones Table S2 Offsite Communications Eauipment All telephone lines (commercial and fiber optic)

Satellite telephone OHL NRC telephones (ENS, HPN, MCL, RSCL, PMCL)

Cellular phones UHF radios Basis:

The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 63of88 SYSTEM MALFUNCTION The availability of one method of ordinary offsite communications is sufficient to inform state and local authorities of plant problems. This EAL is intended to be used only when extraordinary means (e.g.,

relaying of information from radio transmissions, individuals being sent to offsite locations, etc.) are being utilized to make communications possible.

The list for onsite communications loss encompasses the loss of all means of routine communications (e.g., commercial telephones, sound powered phone systems, page party system (Gaitronics) and radios / walkie talkies).

The list for offsite communications loss encompasses the loss of all means of communications with offsite authorities. This should include the ENS, commercial telephone lines, telecopy transmissions, and dedicated phone systems.

There is no escalation above the Unusual Event for this event.

J:mM SRVS/TECH~PvB/REVISION/lO/lOSOll.DOC

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SUIO Initiating Condition -- UNUSUAL EVENT Fuel Clad Degradation.

0perat ing Mode Ap pI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Levels:

1. Offgas isolation due to valid Offgas Post Treatment monitor signal.

(1H13-P601-19A-C8)

OR

2. Coolant sample activity >4.0 WCilml dose equivalent.

Basis:

This IC is included as a NOUE because it is considered to be a potential degradation in the level of safety of the plant and a potential precursor of more serious problems. EAL # I addresses Modes 1, 2, &

3 radiation monitor readings that provide indication of fuel clad integrity. EAL #2 addresses coolant samples exceeding coolant technical specifications for iodine spike.

Escalation of the event to an Alert in Modes 1, 2, & 3 will occur in accordance with IC FA1 (Loss of potential loss of any two barriers)

There is no escalation above the Unusual Event for this event in Modes 4 & 5.

GFUND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SUll Initiating Condition -- UNUSUAL EVENT Inability to reach required shutdown within technical specification time limits 0perat ing Mode A ppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time Basis:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specifications requires a one hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications.

An immediate Unusual Event declaration is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of a Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed.

There is no escalation above the Unusual Event for this event.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 66of88 SYSTEM MALFUNCTION SA1 Initiating Condition -- ALERT AC power capability to Div I & II ESF busses reduced to a single power source for > I 5 minutes such that any additional single failure would result in loss of AC power to both Div I & I I ESF busses.

Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. AC power to 15AA j m c

J 16AB busses reduced to only one of the following sources for >I 5 minutes

a. ESFI 1 or ESF21 or ESF12 transformers

b. DGI 1 or DG12 diesel generators Basis:

This IC and the associated EALs are intended to provide an escalation from IC SUI, (Loss of All Offsite Power To ESF Busses for > 15 Minutes). The condition indicated by this IC is the degradation of the offsite and onsite power systems such that any additional single failure would result in a station blackout.

Escalation of the event to a Site Area Emergency will occur in accordance with IC SSI, (Loss of all offsite and onsite AC power to Div 1&11 ESF busses).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 67of88 SYSTEM MALFUNCTION SA2 Initiating Condition -- ALERT Loss of all offsite and onsite AC Power to Div I & II ESF Busses 0perat ing Mode Ap pIica biI ity: Mode 4 .............Cold Shutdown Mode 5 .............Refueling Mode D.............Defueled Emergency Action Level:

1. Loss of power to 15AA and 16AB busses Failure to restore power to either 15AA or 16AB bus within 15 minutes from the time of loss of both offsite and onsite AC power Basis:

Loss of AC power to Div 1&11 compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to essential busses. Even though an essential bus may be energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not operable on the energized bus then the bus should not be considered operable.

There is no escalation above the Alert for this event.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 68of88 SYSTEM MALFUNCTION SA3 Initiating Condition -- ALERT Failure of reactor protection system instrumentation to complete or initiate an automatic reactor scram once a reactor protection system setpoint has been exceeded manual scram was successful 0perat ing Mode A ppI icabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Emergency Action Level:

1, Automatic scram failed to rapidly insert sufficient control rods to bring the reactor subcritical, and a manual scram was successful Basis:

This condition indicates failure of the automatic protection system to scram the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded.

An Alert is indicated because conditions exist that could lead to potential loss of fuel clad or Reactor Pressure Boundary. Reactor protection system setpoint being exceeded, rather than limiting safety system setpoint being exceeded, is specified here because failure of the automatic protection system is the issue.

A scram performs two functions:

(1) The first function is to initiate a rapid control rod insertion which immediately inserts a step change of negative reactivity into the core to immediately turn reactor power and bring the reactor subcritical.

Subcritical conditions are indicated by reactor power level below the APRM downscale and continuing to decrease. The first function provides the necessary core protection in response to a plant transient and is the criteria used to determine if the automatic and/or manual scram was successful.

(2) The second function is, following the initiation of control rod insertion, to continue to insert control rods until sufficient negative reactivity is inserted to assure adequate shutdown margin. The second function is monitored by IC SU6 (Inadvertent Criticality).

A manual scram is any set of actions by the reactor operator(s) at the reactor control console which causes sufficient control rods to be rapidly inserted into the core and brings the reactor subcritical (e.g.,

Scram Push Buttons, Reactor Mode Switch, Alternate Rod Insertion).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Escalation of the event to a Site Area Emergency will occur in accordance with iC SS3,(Failure of reactor protection system instrumentation to complete or initiate an automatic reactor scram once a reactor protection system setpoint has been exceeded and manual scram was not successful).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SA4 initiating Condition -- ALERT Loss of RPV inventory with irradiated fuel in the RPV Operating Mode Applicability: Mode 4 .............Cold Shutdown Mode 5 .............Refuel Emergency Action Levels:

1. Loss of RPV inventory as indicated by RPV level 4 5 0 . 3 in. (Level 1)

2. a. Loss of RPV inventory

b. RPV level cannot be monitored for >15 minutes Basis:

These EALs serve as precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RPV level decrease and potential core uncovery. This condition will result in a minimum classification of Alert. The Low-Low ECCS Actuation Setpoint was chosen because it is a standard setpoint at which all available injection systems automatically start. The inability to restore and maintain level after reaching this setpoint would therefore be indicative of a failure of the Reactor Pressure Boundary barrier.

In the cold shutdown mode, normal RPV level and RPV level instrumentation systems will normally be available. In the refueling mode, normal means of RPV level indication may not be available.

Redundant means of RPV level indication will be normally installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost, during a loss of RPV inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of Reactor Pressure Boundary leakage. The 15-minute duration for the loss of level indication was chosen because it is half of the IC SS4 (Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV) duration. The 15-minute duration allows this EAL to be an effective precursor to CSI. Significant fuel damage is not expected to occur until the core has been uncovered for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per the analysis referenced in the SS4 basis. Therefore this EAL meets the definition for an Alert emergency.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Escalation of the event to a Site Area Emergency, if RPV level continues to decrease, will occur in accordance with IC SS4 (Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision M Attachment II Page 72of88 SYSTEM MALFUNCTION SA5 Initiating Condition -- ALERT Inability to Maintain Plant in Cold Shutdown with Irradiated Fuel in the RPV 0perat ing Mode A ppIicabiIity: Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Levels:

1. An unplanned event results in reactor coolant temperature >200 O F without CTMT and without Reactor Pressure Boundary integrity

2. An unplanned event results in reactor coolant temperature >200 O F for >20 minutes SeaNote with CTMT integrity without Reactor Pressure Boundary integrity

3. An unplanned event results in reactor coolant temperature >200 O F for >60 minutes sw Note or results in RPV pressure increase > 10 psig Note: If a decay heat removal system is in operation within this time frame and reactor coolant temperature is being reduced then this EAL is not applicable Basis:

EAL 1 addresses complete loss of functions required for core cooling during refueling and cold shutdown modes when neither containment closure nor Reactor Pressure Boundary integrity are established. Reactor Pressure Boundary integrity is in place when the Reactor Pressure Boundary pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). No delay time is allowed for EALI because the evaporated reactor coolant that may be released into the Containment during this heatup condition could also be directly released to the environment.

EAL 2 addresses the complete loss of functions required for core cooling for =. 20 minutes during refueling and cold shutdown modes when containment closure is established but R Reactor Pressure Boundary CS integrity is not established. As in EAL 1, Reactor Pressure Boundary integrity should be assumed to be in place when the Reactor Pressure Boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The allowed 20 minute time frame was included to allow operator action to restore the heat removal function, if possible. The allowed time frame is consistent with the guidance provided by Generic Letter 88-17, "Loss of Decay Heat Removal" (discussed later in this basis) and is believed to be conservative given that a low pressure containment barrier to fission product release is established. The Note indicates that EAL 2 is not applicable if

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment I I Page 73of88 SYSTEM MALFUNCTION SAS(cont) actions are successful in restoring a decay heat removalsystem to operation and reactor coolant temperature is being reduced within the 20 minute time frame.

EAL 3 addresses complete loss of functions required for core cooling for > 60 minutes during refueling and cold shutdown modes when Reactor Pressure Boundary integrity is established. As in EAL 1 and 2, Reactor Pressure Boundary integrity should be considered to be in place when the Reactor Pressure Boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The status of containment closure in this EAL is immaterial given that the Reactor Pressure Boundary is providing a high pressure barrier to fission product release to the environment. The 60 minute time frame should allow sufficient time to restore cooling without there being a substantial degradation in plant safety. The >I 0 psig pressure increase covers situations where, due to high decay heat loads, the time provided to restore temperature control, could be less than 60 minutes. RPV pressure would have to be monitored on the Plant Data System computer to determine the 10 psig pressure increase. The Note indicates that EAL 3 is not applicable if actions are successful in restoring a decay heat removal system to operation and reactor coolant temperature is being reduced within the 60 minute time frame assuming that the RPV pressure increase has remained less than 10 psig A loss of Technical Specification components alone is not intended to constitute an Alert. The same is true of a momentary unplanned excursion above 200°F when the heat removal function is available.

Escalation of the event to a Site Area Emergency, should boiling result in significant RPV level loss leading to core uncovery, will occur in accordance with IC SS4 (Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION Initiating Condition -- ALERT Unplanned loss of most or all safety system annunciation or indication in control room with either a significant transient in progress, compensatory non-alarming indicators are unavailable Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 ............. Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Unplanned loss of most or all safety system annunciators or indication on 1H13-P680, 1H13-P601 and 1H13-P870 for > I 5 minutes

a. A significant transient is in progress.

b. Compensatory non-alarming indications are unavailable.

Basis:

This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (e.g., SPDS, plant computer, etc.).

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification of "Most" is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Supervisor be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that plant design provides redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators may be more

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, a NOUE should be declared based on IC SUlO (Inability to reach required shutdown within technical specification time limits).

"Compensatory non-alarming indications" in this context includes computer based information such as SPDS. This should include any computer systems available for this use. If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

Escalation of the event to a Site Area Emergency will occur in accordance with IC SS6 (Inability to monitor a significant transient in progress).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 76of88 SYSTEM MALFUNCTION ss1 Initiating Condition -- SITE AREA EMERGENCY Loss of all offsite and onsite AC power to Div I & II ESF busses Operating Mode Applicability: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Loss of power to 15AA & 16AB busses Failure to restore power to either 15AA or 16AB bus within 15 minutes from the time of loss of both offsite & onsite AC power Basis:

Loss of AC power to Div I&ll compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power can cause core uncovering and loss of containment integrity, thus this event can escalate to a General Emergency. The 15 minute time duration was selected to exclude transient or momentary power losses.

Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to essential busses. Even though an essential bus may be energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not operable on the energized bus then the bus should not be considered operable. If this bus is the only energized bus then a Site Area Emergency per SS1 should be declared.

Escalation of the event to a General Emergency will occur in accordance with IC SGI, (Prolonged loss

(>4 hrs) of all offsite and onsite AC power to Div 1&11 ESF busses).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 77of88 SYSTEM MALFUNCTION Initiating Condition -- SITE AREA EMERGENCY Loss of all vital DC power 0perat ing Mode AppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. 11DA and 11DB <I05 VDC for > I 5 minutes Basis:

Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power may cause core uncovering or loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. 15 minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the event to a General Emergency will occur in accordance with either IC AGI (Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR TEDY or 5000 mR Thyroid CDE for the actual or projected duration of the release using actual meteorology), IC FGI (Loss of any two barriers and loss or potential loss of third barrier), or IC HG2 (Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency).

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION ss3 Initiating Condition -- SITE AREA EMERGENCY Failure of reactor protection system instrumentation to complete or initiate an automatic reactor scram once a reactor protection system setpoint has been exceeded and manual scram was not successful.

Operating Mode Applicability: Mode I.............Power Operation Mode 2 .............Startup Emergency Action Level:

1. Automatic scram a manual scram failed to rapidly insert sufficient control rods to bring the reactor subcritical Basis:

Under the conditions of EAL 1, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed. A Site Area Emergency is indicated because conditions exist that could lead to imminent or potential loss of both fuel clad and Reactor Pressure Boundary. Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

A scram performs two functions:

(1) The first function is to initiate a rapid control rod insertion which immediately inserts a step change of negative reactivity into the core to immediately turn reactor power and bring the reactor subcritical.

Subcritical conditions are indicated by reactor power level below the APRM downscale and continuing to decrease. The first function provides the necessary core protection in response to a plant transient and is the criteria used to determine if the automatic and/or manual scram was successful.

(2) The second function is, following the initiation of control rod insertion, to continue to insert control rods until sufficient negative reactivity is inserted to assure adequate shutdown margin. The second function is not applicable in EAL 1 because both automatic and manual actions have failed to successfully perform the first function.

A manual scram is any set of actions by the reactor operator(s) at the reactor control console which causes sufficient control rods to be rapidly inserted into the core and brings the reactor subcritical (e.g.,

Scram Push Buttons, Reactor Mode Switch, Alternate Rod Insertion).

Escalation of the event to a General Emergency will occur in accordance with IC SG2 (Failure of the reactor protection system to complete an automatic scram and manual scram was not successful and there is indication of an extreme challenge to the ability to cool the core

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 79of88 SYSTEM MALFUNCTION ss4 Initiating Condition -- SITE AREA EMERGENCY Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV Operating Mode Applicability: Mode 4 .............Cold Shutdown Mode 5 .............Refueling Emergency Action Level:

1. a. Loss of RPV inventory

b. RPV level cannot be monitored for >30 minutes OR

2. a. RPV level <-156.3 in. with containment closure not established or

b. RPV level <-167 in. with containment closure established Basis:

Under the conditions specified by this IC, continued decrease in RPV level is indicative of a loss of inventory control. Inventory loss may be due to an RPV breach, pressure boundary leakage, or continued boiling in the RPV.

In the cold shutdown mode, normal reactor vessel level indication systems will normally be available.

However, if all level indication were to be lost during a loss of RPV inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes.

Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of Reactor Pressure Boundary leakage.

A number of variables such as initial vessel level, or shutdown heat removal system design can have a significant impact on heat removal capability challenging the fuel clad barrier. The 30-minute duration allows sufficient time for actions to be performed to recover needed cooling equipment and is considered to be conservative.

Escalation to a General Emergency is via SG3 (Loss of RPV inventory affecting fuel clad integrity with containment challenged with irradiated fuel in the RPV ) or radiological effluent IC AGI (Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR TEDE or 5000 mR Thyroid CDE for the actual or projected duration of the release using actual meteorology).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 80of88 SYSTEM MALFUNCTION ss5 Initiating Condition -- SITE AREA EMERGENCY Complete loss of heat removal capability.

0perat ing Mode A ppI icabiIity: Mode 1 .............Power Operation Mode 2 ............. Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Inability to maintain Suppression Pool temperature in the HCTL Safe Zone requiring Emergency Depressurization per EP-3 Basis:

This EAL addresses complete loss of functions, including ultimate heat sink, required for hot shutdown with the reactor at pressure and temperature. Loss of heat removal function is indicated by the inability to maintain Suppression Pool temperature within the Heat Capability Temperature Limit as prescribed in EP-3. Under these conditions, there is an actual major failure of a system intended for protection of the public.

Escalation to General Emergency is via IC AGI (Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR TEDE or 5000 mR Thyroid CDE for the actual or projected duration of the release using actual meteorology), IC FGl(Loss of any two barriers and loss or potential loss of third barrier), or IC HG2 ( Other conditions existing which in the judgment of the Emergency Director warrant declaration of General Emergency).

J:ADM SRVS/TECH PUl3/REVISION/lO/lOSOll.DOC

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 81 of 88 SYSTEM MALFUNCTION SS6 Initiating Condition -- SITE AREA EMERGENCY Inability to monitor a significant transient in progress 0perat ing Mode Ap pI icabiI ity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. a. Loss of most a all annunciators or indication on 1H13-P680, 1H I 3-P601 & 1H I 3-P870 for

> I 5 minutes

b. Indications needed to monitor criticality a core heat removal fission product barrier status are unavailable

c. A significant transient is in progress AND

d. Compensatory non-alarming indications are unavailable Basis:

This IC and its associated EAL is intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public.

"Compensatory non-alarming indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

Indications needed to monitor safety functions necessary for protection of the public include control room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the Reactor Pressure Boundary intact, and to maintain containment intact.

Quantification of "Most" is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision M Attachment II Page 82of88 SYSTEM MALFUNCTION instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Supervisor be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

There is no escalation above the Site Area Emergency for this event.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SGI Initiating Condition -- GENERAL EMERGENCY Prolonged Loss (>4 hrs) of all offsite and onsite AC power to Div I & II ESF busses.

0perat ing Mode A ppIicabiIity: Mode 1 .............Power Operation Mode 2 .............Startup Mode 3 .............Hot Shutdown Emergency Action Level:

1. Loss of AC power to 15AA and 16AB busses, AND Either:

a. Restoration of AC power to either 15AA a 16AB within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely or

b. Conditions are imminent that a Loss of two fission product barriers and loss potential loss of third (FGI) is expected to occur prior to restoration of AC power to either 15AA or 16AB.

Basis:

Loss of AC power to Div 1&11 compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power could lead to loss of fuel clad, Reactor Pressure Boundary, and containment. The four (4) hours to restore AC power is based on a site blackout coping analysis performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.I 55, Station Blackout. Appropriate allowance for offsite emergency response including evacuation of surrounding areas should be considered. Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

This IC is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revision xx Attachment II Page 84of88 SYSTEM MALFUNCTION S G I (cont)

In addition, under these conditions, fission product barrier monitoring capability may be degraded.

Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Director a reasonable idea of how quickly (s)he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that loss or potential loss of fission product barriers is imminent?

2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on fission product barrier monitoring with particular emphasis on Emergency Director judgment as it relates to imminent loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers.

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment II Page 85of88 SYSTEM MALFUNCTION SG2 Initiating Condition -- GENERAL EMERGENCY Failure of the reactor protection system to complete an automatic scram gcJ manual scram was not successful gcJ there is indication of an extreme challenge to the ability to cool the core Operating Mode Applicability: Mode 1 ............. Power Operation Mode 2 ............. Startup Emergency Action Level:

1. Automatic scram and manual failed to rapidly insert sufficient control rods to bring the reactor subcritical Either:

a. RPV parameters cannot be maintained within EP-2A limits

b. RPV pressure suppression pool temperature cannot be maintained in the HCTL Safe Zone Basis:

A scram performs two functions:

(1) The first function is to initiate a rapid control rod insertion which immediately inserts a step change of negative reactivity into the core to immediately turn reactor power and bring the reactor subcritical.

Subcritical conditions are indicated by reactor power level below the APRM downscale and continuing to decrease. The first function provides the necessary core protection in response to a plant transient and is the criteria used to determine if the automatic and/or manual scram was successful.

(2) The second function is, following the initiation of control rod insertion, to continue to insert control rods until sufficient negative reactivity is inserted to assure adequate shutdown margin. The second function is not applicable in EAL 1 because both automatic and manual actions have failed to successfully perform the first function.

A manual scram is any set of actions by the reactor operator(s) at the reactor control console which causes sufficient control rods to be rapidly inserted into the core and brings the reactor subcritical (e.g.,

Scram Push Buttons, Reactor Mode Switch, Alternate Rod Insertion).

GRAND GULF NUCLEAR STATION 10-s-01-1 Revision xx Attachment I I Page 86of88 SYSTEM MALFUNCTION Under the conditions of this IC, efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat than the maximum decay heat load for which the safety systems were designed. Although there are capabilities away from the reactor control console, such as standby liquid control and actions to insert control rods per EP-;ZA, the continuing parameter degradation indicates that these capabilities have not been effective. This situation could be a precursor for a core melt sequence.

The extreme challenge to the ability to cool the core is intended to mean that the reactor vessel water level cannot be restored and maintained above Minimum Steam Cooling RPV Water Level as described in the EOP bases.

Another consideration is the inability to initially remove heat during the event. Considerations include inability to remove heat via the main condenser, or via the suppression pool.

In the event either of these challenges exist at a time that the reactor has not been brought below the power associated with the safety system design (APRM downscale) a core melt sequence could exist. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE SYSTEM MALFUNCTION SG3 Initiating Condition -- GENERAL EMERGENCY Loss of RPV inventory affecting fuel clad integrity with containment challenged with irradiated fuel in the RPV 0perat ing Mode A ppIicability: Mode 4 ............. Cold Shutdown Mode 5 .............Refueling Emergency Action Level:

1. RPV level:

a. <-I617 in. for > 30 minutes or

b. RPV level cannot be monitored with indication of core uncovery for >30 minutes AND

2. a. Containment closure is not established or

b. Containment pressure >22 psig or

c. Containment hydrogen concentration ~ 1 9 %

d. Any EP-4 radiation monitor reading above the Max Safe Value Basis:

EAL 1 represents the inability to restore and maintain RPV level to above the top of active fuel. Fuel damage could occur if RPV level cannot be restored, because decay heat will cause boiling, further reducing the RPV level.

GRAND GULF NUCLEAR STATION EMERGENCY PLAN PROCEDURE 10-s-01-1 Revisionxx Attachment II Page 88of88 SYSTEM MALFUNCTION A number of variables, such as initial vessel level, or the amount of decay heat can have a significant impact on heat removal capability and any challenge to the fuel clad barrier. Analysis indicates that core damage may occur within an hour following continued core uncovery therefore, conservatively, 30 minutes was chosen.

As water level in the RPV lowers, the dose rate above the core will increase. The dose rate due to this core shine is expected to result in increasing Containment High Range Monitor indication and possible alarm. Additionally, post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

The General Emergency is declared on the occurrence of the loss or imminent loss of function of three barriers. Based on the above discussion, Reactor Pressure Boundary barrier failure resulting in core uncovery for 30 minutes or more may cause fuel clad failure. With the containment breached or challenged, the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment. This is consistent with the definition of a General Emergency.

In EAL 2 containment closure is the action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Shutdown contingency plans provide for re-establishing containment closure following a loss of heat removal or RPV inventory functions. If the closure is re-established prior to exceeding the level threshold of EAL 1, escalation to General Emergency would not occur.

The pressure at which containment is considered challenged per the Emergency Operating Procedures is 22 psig.

The EP-4 Maximum Safe radiation monitor values are used are used to provide indication of increased release that may be indicative of a challenge to secondary containment.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gasses in containment. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists.

Attachment 5 to GNRO-2003/00067 GGNS NEI 99-01, Rev. 4 to Plant Specific ComeIations, Differences, Deviations, and J ust ifications

Grand Gulf NucIear Station NEI 99=01,Rev 4 To Plant Specific Correlations, Differences, Deviations, and Justifications

NEI 99-01 Operating Modes: Power Operation Startup Hot Standby Hot Shutdown Cold Shutdown Refueling Defueled Grand Gulf Operating Modes: 1--------- Power Operation 2 --------- Startup 3--------- Hot Shutdown 4 --------- Cold Shutdown 5--------- Refueling D -------- Defueled Note: The Hot Standby Mode is only applicable to PWRs

Grand Gulf Nuclear Station Abnormal Rad Levels /

Radiological Effluent This section contains the correlation between NEI 99-01 and Grand Gulf ICs and EALs in the Abnormal Rad Levels / Radiological Effluent Recognition Category. It includes a statement of the NEI IC or EAL, a statement of the corresponding Grand Gulf IC or EAL, and sufficient discussion to describe any difference or to justify any deviation.

A- 1

Grand Gulf Nuclear Station Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Effluent Technical Specifications for 60 Minutes or Longer Applicability: All Grand Gulf: A U I Unplanned release of ga eous or liquid radioactivit! to the environment that exceeds 2 x ODCM limit for 160 minutes Applicability: 1, 2, 3, 4, 5,D Differences:

Grand Gulf uses the Offsite Dose Calculation Manual (ODCM) instead of the Radiological Effluent Technical Specifications (RETS)

Deviations:

None A-2

Grand Gulf Nuclear Station VALID reading on any effluent monitor that exceeds two times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer Applicability: All Grand Gulf: A U I , EAL #I Liquid release > 4 x High High Alarm set point G17-RR-R521 with failure of GI?-

F355 to close for 2 60 minutes Applicability: 1, 2, 3, 4, 5, D Differences:

The setpoint is established by the ODCM to alarm at 50% of the TRM limit. Thus four times the setpoint corresponds to two times the TRM limit.

Deviations:

None A-3

Grand Gulf Nuclear Station VALID reading on one or more of the following radiation monitors that exceeds the reading shown for 60 minutes or longer Applicability: All Grand Gulf: A U I , EAL #2 High High Alarm on one or more of the following:

Applicability: 1, 2, 3, 4, 5, D Differences:

The setpoint for each of the listed release paths is established by the ODCM to alarm at 25% of the TRM Spec. limit. Use of the High High Alarm for any one of the release pathways provides early warning of a potential radiological release.

Requiring a summation of all monitors including the non-routine SBGT release pathway ensures that all release pathways are considered when calculating the total release. Use of two times the TRM Spec. limit ensures consistency with AUI.

Deviations:

None A-4

Grand Gulf Nuclear Station I,Example EAL #3 Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates, with a release duration of 60 minutes or longer, in excess of two times (site-specific technical specifications).

Applicability: All Grand Gulf: AUI, EAL #3 Confirmed sample analysis for gaseous or liquid release exceeds 2 x TRM Spec limit (6.11.1, 6.11.2, 6.11.4, 6.11.5, 6.11.6) for 2 60 minutes Applicability: 1, 2, 3, 4, 5,D Differences:

None Deviations:

None A-5

Grand Gulf Nuclear Station

-01: A M , Exa VALID reading on perimeter radiation monitoring system greater than 0.10 mWhr above normal background sustained for 60 minutes or longer [for sites having telemetered perimeter monitors]

Applicability: All Grand Gulf: NA None Applicability: N/A Differences:

Grand Gulf does not have telemetered perimeter monitors Deviations:

None A-6

Grand Gulf Nuclear Station VALID indication on automatic real-time dose assessment capability greater than (site-specific value) for 60 minutes or longer [for sites having such capability]

Applicability: All Grand Gulf: NA None Applicability: NIA Differences:

Grand Gulf does not use automatic dose assessment Deviations:

None A-7

Grand Gulf Nuclear Station El : AU2 Unexpected Increase in Plant Radiation Applicability: All Grand Gulf: AU2 Unexpected increase in plant radiation Applicability: 1, 2, 3, 4, 5,D Differences:

None Deviations:

None A-8

Grand Gulf Nuclear Station El I:AlJ2, Exa VALID (site-specific) indication of uncontrolled water level decrease in the reactor refueling cavity, spent fuel pool, or fuel transfer canal with all irradiated fuel assemblies remaining covered by water.

AND Unplanned VALID (site-specific) Direct Area Radiation Monitor reading increases Applicability: All Grand Gulf: AU2, EAL #2 Valid indication of uncontrolled water level decrease in Aux Bldg Fuel Pools or Upper Ctmt Pools with irradiated fuel assemblies remaining covered by water AND Ctmt Fuel Hdlg Area --_-_--_-_-_- -------(P844-IA-A3)

Aux Bldg Fuel Hdlg Area --------------(P844-I A-A4)

Or

b. survey indicates increased radiation level in the associated area Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AU2, EAL#I is implemented by Grand Gulf AU2, EAL#2 (Formatting only)

Deviations:

None A-9

Grand Gulf Nuclear Station El 1: AU2, Exa Unplanned VALID Direct Area Radiation Monitor readings increases by a factor of 1000 over normal* levels.

Normal levels can be considered as the highest reading in the past twenty-four hours excluding the current peak value.

Applicability: All Grand Gulf: AU2, EAL ##I Valid Area Radiation Monitor or survey indicates an unplanned increase in plant radiation levels by a factor of 1000 or full scale Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AU2, EAL#2 is implemented by Grand Gulf AU2, EAL#I (Formatting only)

Some of the Area Radiation Monitors installed at Grand Gulf do not have sufficient range to allow the determination of an increase by a factor of 1000. Therefore for these ARMS full scale is conservatively used in lieu of the factor of 1000.

Deviations:

None A-I0

Grand Gulf Nuclear Station Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Radiological Effluent Technical Specifications for 15 Minutes or Longer Applicability: All Grand Gulf: A A I Unplanned release of gaseous or liquid radioactivity to the environment that exceeds 20 x ODCM limit for 215 minutes Applicability: 1, 2, 3, 4, 5, D Differences:

Grand Gulf uses the Offsite Dose Calculation Manual (ODCM) instead of the Radiological Effluent Technical Specifications (RETS).

Deviations:

When the NEI 99-04 factor of 200 was used it was discovered that the resulting Alert threshold value was much closer to the Site Area Emergency threshold than to the Unusual Event threshold. A factor of 20 was used in lieu of 200 to provide a more logical and evenly spacing of the thresholds in this category. Using a factor of 20 results in an approximate increase of a factor of 10 between all four classification levels which implements the perceived intent of this Initiating Condition.

A-I1

Grand Gulf Nuclear Station El I:A A I , Exa EAL #I VALID reading on any effluent monitor that exceeds 200 times the alarm setpoint established by a current radioactivity discharge permit for 15 minutes or longer.

Applicability: All Grand Gulf: A A I , EAL #I Liquid release >40 x High High Alarm set point on G17-RR-R521 with failure of G15-F355 to close for 2 15 minutes Applicability: 1, 2, 3, 4, 5, D Differences:

The setpoint is established by the ODCM to alarm at 50% of the TRM limit. Thus forty times the setpoint corresponds to twenty times the TRM limit. Use of twenty times the TRM Spec. limit ensures consistency with Grand Gulf AA1 .

Deviations:

None A-I2

Grand Gulf Nuclear Station El . ple EAL #2 VALID reading on one or more of the following radiation monitors that exceeds the reading shown for 15 minutes or longer:

(site-specific list)

Applicability: All Grand Gulf: A A I , EAL #2 High High Alarm on one or more of the following:

Applicability: 1, 2, 3, 4, 5, D Differences:

The setpoint for each of these release paths is established by the ODCM to alarm at 25% of the TRM Spec. limit. Use of the High High Alarm for any one of the release pathways provides early warning of a potential radiological release.

Requiring a summation of all monitors including the non-routine SBGT release pathway ensures that all release pathways are considered when calculating the total release. Use of twenty times the TRM Spec. limit ensures consistency with AA1 .

Deviations:

None A - 13

Grand Gulf Nuclear Station Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates, with a release duration of 15 minutes or longer, in excess of 200 times (site-specific technical specifications).

Applicability: All Grand Gulf: A A I , EAL #3 Confirmed sample analysis for gaseous or liquid release exceeds 20 x TRM Spec limit (6.11.1, 6.11.2, 6.11.4, 6.11.5 or 6.11.6) for 2 15 minutes Applicability: 1, 2, 3, 4, 5, D Differences:

Use of twenty times the TRM Spec. limit ensures consistency with Grand Gulf AA1 Deviations:

None A-I4

Grand Gulf Nuclear Station El VALID reading on perimeter radiation monitoring system greater than 10 mWhr above normal background sustained for 15 minutes or longer [for sites having telemetered perimeter monitors]

Applicability: All Grand Gulf: NA None A ppIicabiIity : NIA Differences:

Grand Gulf does not have telemetered perimeter monitors Deviations:

None A - 15

Grand Gulf Nuclear Station

, Example EAL #5 VALID indication on automatic real-time dose assessment cap bility greater than (site-specific value) for 15 minutes or longer [for sites having such capability]

Applicability: All Grand Gulf: NA None Applicability: N/A Differences:

Grand Gulf does not use automatic dose assessment Deviations:

None A-I6

Grand Gulf Nuclear Station Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

Applicability: All Grand Gulf: AA3 Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the RPV Applicability: I,2, 3, 4, 5, D Differences:

NEI AA2 is implemented by Grand Gulf AA3 (Formatting only)

Deviations:

None A-17

Grand Gulf Nuclear Station El EAL #I A VALID (site-specific) alarm or reading on one or more of the following radiation monitors: (site-specific monitors)

Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Refueling Bridge Area Radiation Monitor Applicability: All Grand Gulf: AA3, EAL #I Potential spent fuel damaging event with Alarm on one or more of the following:

Applicability: I,2, 3, 4, 5, D Differences:

NEI AA2, EAL#I is implemented by Grand Gulf AA3, EAL#I (Formatting only)

NEI 99-01 bases for Example EAL #clearly I states that application of this EAL requires understanding of actual radiological conditions present in the vicinity of the monitor. The words Potential spent fuel damaging event with were added to the Grand Gulf EAL to capture this EAL to capture the Damage to irradiated fuel wording in NEI AA2.

Deviations:

None A-I8

Grand Gulf Nuclear Station I:

Water level less than (site-specific) feet for the reactor refueling cavity, spent fuel pool and fuel transfer canal that will result in irradiated fuel uncovering Applicability: All Grand Gulf: AA3, EAL #2 Valid indication of uncontrolled water level decrease in Aux Bldg Fuel Pools Upper Ctmt Pools that has or will result in irradiated fuel assemblies becoming uncovered Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AA2, EAL#2 is implemented by Grand Gulf AA3, EAL#2 (Formatting only)

Grand Gulf does not have installed level indication that would allow direct reading of a level that would uncover irradiated fuel. An uncontrolled water level decrease would be detected long before fuel uncovering actually occurs. Combining this with a judgment that fuel has or will become uncovered meets the intent of the NEI EAL.

Deviations:

None A-I9

Grand Gulf Nuclear Station I:

Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown Applicability: All Grand Gulf: AA2 Release of radioactive material a increases in radiation levels within the facility that impedes operation of systems required to maintain a establish safe operations cold shutdown Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AA3 is implemented by Grand Gulf AA2 (Formatting only)

Deviations:

None A - 20

Grand Gulf Nuclear Station 1: 3, Exa EAL #I VALID (site-specific) radiation monitor readings GREATER THAN 15 mWhr in areas requiring continuous occupancy to maintain plant safety functions:

(Site-specific) list Ap piicabiIity : All Grand Gulf: AA2, EAL #I Valid radiation level 2 15 mWhr in the Control Room Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AA3, EAL#I is implemented by Grand Gulf AA2, EAL#I (Formatting only)

Deviations:

None A - 21

Grand Gulf Nuclear Station El 3, Example EAL If2 VALID (site-specific) radiation monitor readings GREATER THAN <site specific>

values in areas requiring infrequent access to maintain plant safety functions.

(Site-specific) list Applicability: All Grand Gulf: AA2, EAL #2 Valid radiation level 2 80 Rlhr in RHR A, B, C, HPCS, LPCS, or RClC room access is required Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AA3, EAL#2 is implemented by Grand Gulf AA2, EAL#2 (Formatting only)

Specified that EAL is only met if access is required to maintain plant safety function.

Deviations:

None A-22

Grand Gulf Nuclear Station El : AS1 Offsite Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mR TEDE or 500 mR Thyroid CDE for the Actual or Projected Duration of the Release.

Applicability: All Grand Gulf: AS1 Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 100 mR TEDE or 500 mR CDE Thyroid for the actual or projected duration of the release using actual meteorology.

Applicability: 1, 2, 3, 4, 5, D Differences:

The words using actual meteorology are included in the Grand Gulf IC because they are included in the NEI AS1 example EAL #2 and to provide wording consistency with Grand Gulf AS! And AGI. The Grand Gulf dose assessment computer program uses actual meteorology when calculating dose projections.

Deviations:

None A-23

Grand Gulf Nuclear Station El EAL #I VALID reading on one or more of the following radiation monitors that exceeds or is expected to exceed the reading shown for 15 minutes or longer:

(site-specific list)

Note: If dose assessment results are available at the time of declaration, the classification should be based on EAL #2 instead of EAL # I . While necessary declarations should not be delayed awaiting results, the dose assessment should be initiated /

completed in order to determine if the classification should be subsequently escalated.

Applicability: All Grand Gulf: NA None Applicability: N/A Differences:

NA Deviations:

Grand Gulf has multiple ground level release points instead of a single elevated release point. The Alarm Response Instruction for each release point directs the performance of a summation of release points, to determine total release, upon receipt of the HI-HI Alarm, which is set at 25% of TRM 6.1 1.4 instantaneous dose limit at site boundary. Each release point is monitored by both low range and high range radiation monitors. The low range monitors are used to meet AUI EAL#2 and AA1 EAL#2 (See bases for AUI EAL#2 and AA1 EAL#2 for more information).

The low range radiation monitors will peg out high before the Site Area Emergency threshold is reached, therefore the high range radiation monitors must be used for both the Site Area and General Emergency classifications. The summation of the multiple high range radiation monitors must be performed by the dose assessment software.

Activation of the dose assessment computer has been repeatedly demonstrated to be less than 10 minutes during drills and exercises. At Site Area Emergency radiation levels, the low range radiation monitoring instruments would be pegged high requiring use of the dose assessment computer to perform the required summation. Thus for Site Area Emergency and above, dose assessment results are always available at the time of declaration, therefore NEI 99-01 EAL # I is not implemented as allowed by NEI 99-01 EAL # I Note.

A-24

Grand Gulf Nuclear Station Grand Gulf dose assessment computers are available in five (5) different locations.

Three of these locations have backup battery power supplies and/or have emergency diesel generator backup power. Procedural guidance exists to provide continuous dose assessment in the event one or more of the dose assessment computer stations fails. Each dose assessment station is inter-connected to the PDS such that when activated, it continuously obtains required data and performs dose assessments once every 60 seconds or instantly upon demand.

A 25

Grand Gulf Nuclear Station Dose assessment using actual meteorology indicates doses greater than 100 mR TEDE or 500 mR thyroid CDE at or beyond the site boundary.

Applicability: All Grand Gulf: A S I , EAL #I & #2 I. Dose projection of 2 100 mR TEDE at or beyond site boundary based on plant or field team data

2. Dose projection of 2 500 mR CDE Thyroid at or beyond site boundary based on plant or field team data Applicability: 1, 2, 3, 4, 5, D Differences:

NEI ASI, EAL#Z is implemented by Grand Gulf ASI, EAL#I & #2 (Formatting only)

The words using actual meteorology are not included in the Grand Gulf EAL because they were included in IC AS1 and to provide wording consistency with Grand Gulf ASI, EAL # I & #2 and AGI, EAL # I & #2. The Grand Gulf dose assessment computer program uses actual meteorology when calculating dose projections.

Deviations:

None A-26

Grand Gulf Nuclear Station A VALID reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 100 mWhr. [for sites having telemetered perimeter monitors]

Applicability: All Grand Gulf: NA None Applicability: NIA Differences:

Grand Gulf does not have telemetered perimeter monitors Deviations:

None A-27

Grand Gulf Nuclear Station El AL #4 Field survey results indicate closed window dose rates exceeding 100 mWhr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 500 mR for one hour of inhalation, at or beyond the site boundary.

Applicability: All Grand Gulf: ASI, EAL # I & #2 I. Dose projection of 1 100 mR TEDE at or beyond site boundary based on plant or field team data

2. Dose projection of 2 500 mR CDE Thyroid at or beyond site boundary based on plant or field team data Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AS1 , EAL#4 is implemented by Grand Gulf AS1 , EAL#I & #2 (Formatting only)

A dose projection must be performed using field team data in order to evaluate the projected dose associated with a field reading. Dose assessment stations will always be manned prior sending monitoring teams into the field. Therefore Grand Gulf EALs #I & #2 satisfy this EAL.

Deviations:

None A-28

Grand Gulf Nuclear Station 1

Offsite Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds I000 mR TEDE or 5000 mR Thyroid CDE for the Actual or Projected Duration of the Release Using Actual Meteorology.

Applicability: All Grand Gulf: AG1 Offsite dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR TEDE or 5000 mR CDE Thyroid for the actual or projected duration of the release using actual meteorology.

Applicability: 1, 2, 3, 4, 5, D Differences:

None Deviations:

None A-29

Grand Gulf Nuclear Station El . , Example EAL VALID reading on one or more of the following radiation monitors that exceeds or is expected to exceed the reading shown for 15 minutes or longer:

(site-specific list)

Note: If dose assessment results are available at the time of declaration, the classification should be based on EAL #.2 instead of EAL #?.While necessary declarations should not be delayed awaiting results, the dose assessment should be initiated /

completed in order to determine if the classification should be subsequently escalated.

Applicability: All Grand Gulf: NA None Applicability: N/A Diffe renees:

None Deviations:

Grand Gulf has multiple ground level release points instead of a single elevated release point. The Alarm Response Instruction for each release point directs the performance of a summation of release points, to determine total release, upon receipt of the HI-HI Alarm, which is set at 25% of TRM 6.1 1.4 instantaneous dose limit at site boundary. Each release point is monitored by both low range and high range radiation monitors. The low range monitors are used to meet AUI EAL#2 and AAI EAL#2 (See bases for AUI EAL#2 and AA1 EAL#2 for more information).

The low range radiation monitors will peg out high before the Site Area Emergency threshold is reached, therefore the high range radiation monitors must be used for both the Site Area and General Emergency classifications. The summation of the multiple high range radiation monitors must be performed by the dose assessment software.

Activation of the dose assessment computer has been repeatedly demonstrated to be less than I 0 minutes during drills and exercises. At Site Area Emergency radiation levels, the low range radiation monitoring instruments would be pegged high requiring use of the dose assessment computer to perform the required summation. Thus for Site Area Emergency and above, dose assessment results are always available at the time of declaration, therefore NEI 99-01 EAL # I is not implemented as allowed by NEI 99-01 EAL # I Note.

A 30

Grand Gulf Nuclear Station Grand Gulf dose assessment computers are available in five (5) different locations.

Three of these locations have backup battery power supplies andlor have emergency diesel generator backup power. Procedural guidance exists to provide continuous dose assessment in the event one or more of the dose assessment computer stations fails. Each dose assessment station is inter-connected to the PDS such that when activated, it continuously obtains required data and performs dose assessments once every 60 seconds or instantly upon demand.

A - 31

Grand Gulf Nuclear Station Ell Dose assessment using actual meteorology indicates doses greater than 1000 mR TEDE or 5000 mR thyroid CDE at or beyond the site boundary.

A pplicabi Iity : All Grand Gulf: A G I , EAL #I & #2

1. Dose projection of 2 1000 mR TEDE at &r beyond site boundary based on plant or field team data

2. Dose projection of 2 5000 mR CDE Thyroid at or beyond site boundary based on plant or field team data Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AGI, EAL#2 is implemented by Grand Gulf AG1 , EAL#I & #2. (Formatting only)

The words using actual meteorology are not included in the Grand Gulf EAL because they were included in AGI. The Grand Gulf dose assessment computer program uses actual meteorology when calculating dose projections.

Deviations:

None A 32

Grand Gulf Nuclear Station 3

A VALID reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 1000 mWhr. [for sites having telemetered perimeter monitors]

Applicability: All Grand Gulf: NA None Applicability: NIA Differences:

Grand Gulf does not have telemetered perimeter monitors Deviations:

None A - 33

Grand Gulf Nuclear Station El EAL #4 Field survey results indicate closed window dose rates exceeding 100 mWhr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 500 mR for one hour of inhalation, at or beyond the site boundary.

Applicability: All Grand Gulf: AGI, EAL # I & #2

1. Dose projection of 2 1000 mR TEDE at or beyond site boundary based on plant or field team data

2. Dose projection of 2 5000 mR CDE Thyroid at or beyond site boundary based on plant or field team data Applicability: 1, 2, 3, 4, 5, D Differences:

NEI AGI, EAL#$ is implemented by Grand Gulf AGI, EAL#I & #2 (Formatting only)

A dose projection must be performed using field team data in order to evaluate the field reading. Dose assessment stations will always be manned prior sending monitoring teams into the field. Therefore Grand Gulf EALs # I & #2 satisfy this EAL.

Deviations:

None A-34

Grand Gulf Nuclear Station Cold Shutdown /

Refueling System Malfunction This section contains the correlation between NEI 99-01 and Grand Gulf ICs and EALs in the Cold Shutdown / Refueling System Malfunction Recognition Category. It includes a statement of the NEI IC or EAL, a statement of the corresponding Grand Gulf IC or EAL, and sufficient discussion to describe any difference or to justify any deviation.

The Cold Shutdown Operating Mode does not meet the same criteria used to establish previous NEI Recognition Categories. Recognition Categories are based on events not operating modes. Therefore the Cold Shutdown/ Refueling System Malfunctions were combined with the System Malfunction recognition category to address human factors issues and make the System Malfunction recognition category consistent with the remaining recognition categories. Changing the numbering format does not create a deviation from NEI 99-01.

Grand Gulf Nuclear Station El RCS Leakage Applicability: Cold Shutdown Grand Gulf: SU4 Unplanned loss of RPV inventory Applicability: 4 Differences:

NEI CU1 is implemented by Grand Gulf SU4 (Formatting only)

Changed RCS Leakage to Unplanned loss of RPV inventory to be consistent with terminology used in other EALs.

Deviations:

None C-2

Grand Gulf Nuclear Station

c le EAL #I Unidentified or pressure boundary leakage greater than 10 gpm Applicability: Cold Shutdown Grand Gulf: SU4, EAL #I RPV water level cannot be restored and maintained above 11.4 in.

Applicability: 4 Differences:

NEI CU1 , EAL #1 is implemented by Grand Gulf SU4, EAL #1 (Formatting only)

Deviations:

There is no practical method at Grand Gulf to monitor for 10 gpm leakage while in Mode 4. Normal leakage detection systems may not be available because Technical Specifications does not require leakage detection systems to be operable in Mode 4. Normal maintenance that occurs in Mode 4 will often preclude the use of leakage detection systems either due to excessive in-leakage from the maintenance or due to the addition of temporary sump pumps. RPV level control in Mode 4 also precludes use of a RPV level decrease rate of change. Therefore a RPV water level of 11.4 in. was chosen to implement this EAL. 11.4 in. is the level for the automatic reactor scram and the shutdown cooling system automatic isolation. Both of these have annuciators which will alert the operator to the condition. In addition at -41.6 in. a Primary Containment Isolation will occur should leakage be from a source other than the Shutdown Cooling system. Use of level in Mode 4 instead of a leakage rate is consistent with all other Mode 4 & 5 Reactor Pressure Boundary Leakage EALs.

Should RPV level continue to decrease escalation to an Alert would occur if level decreased to -150.3 in. per SA4.

c - 3

Grand Gulf Nuclear Station Identified leakage greater than 25 gpm Applicability: Cold Shutdown Grand GulC: SU4, EAL #I RPV water level cannot be restored and maintained above 11.4 in.

Appl icabiIity: 4 Differences:

NEI CUI, EAL #2 is implemented by Grand Gulf SU4, EAL #I (Formatting only)

Deviations:

There is no practical method at Grand Gulf to monitor for 25 gpm leakage while in Mode 4. Normal leakage detection systems may not be available because Technical Specifications does not require leakage detection systems to be operable in Mode 4. Normal maintenance that occurs in Mode 4 will often preclude the use of leakage detection systems either due to excessive in-leakage from the maintenance or due to the addition of temporary sump pumps. RPV level control in Mode 4 also precludes use of a RPV level decrease rate of change. Therefore a RPV water level of 11.4 in. was chosen to implement this EAL. 11.4 in. is the level for the automatic reactor scram and the shutdown cooling system automatic isolation. Both of these have annuciators which will alert the operator to the condition. In addition at -41.6 in. a Primary Containment Isolation will occur should leakage be from a source other than the Shutdown Cooling system. Use of level in Mode 4 instead of a leakage rate is consistent with all other Mode 4 & 5 Reactor Pressure Boundary Leakage EALs.

Should RPV level continue to decrease escalation to an Alert would occur if level decreased to -150.3 in. per SA4.

c-4

Grand Gulf Nuclear Station UNPLANNED Loss of RCS Inventory with Irradiated Fuel in the RPV Applicability: Refueling Grand Gulf: Sufi Unplanned loss of RPV inventory with irradiated fuel in the RPV Applicability: 5 Differences:

NEI CU2 is implemented by Grand Gulf SU5 (Formatting only)

Changed RCS to RPV to reflect BWR terminology.

Deviations:

None c-5

Grand Gulf Nuclear Station UNPLANNED RCS level decrease below the RPV flange for1' 5 minutes Applicability: Refueling Grand Gulf: SU5, EAL #I Unplanned RPV level decrease below the RPV flange for > 15 minutes Applicability: 5 Differences:

NEI CU2, EAL #isI implemented by Grand Gulf SU5, EAL #I (Formatting only)

Changed RCS to RPV to reflect BWR terminology.

Deviations:

None C-6

Grand Gulf Nuclear Station

a. Loss of RPV inventory as indicated by unexplained {site-specific} sump and tank level increase AND

b. RPV level cannot be monitored Applicability: Refueling Grand Gulf: SU5, EAL #2

a. Loss of RPV inventory

b. RPV level cannot be monitored Applicability: 5 Differences:

NEI CU2, EAL #2 is implemented by Grand Gulf SU5, EAL #2 (Formatting only)

It does not matter what means are used to determine that inventory is being lost therefore specific means for determining loss of inventory are not included in the Grand Gulf EAL.

Deviations:

None c-7

Grand Gulf Nuclear Station El Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes Applicability: Cold Shutdown, Refueling Grand Gulf: S U I Loss of all offsite power to ESF busses for > 15 Minutes Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU3 is implemented by Grand Gulf SUI (Formatting only)

Applicability includes modes 1,2, and 3 as well as modes 4 and 5 because Grand Gulf SU! Also implements NEI SUI.

Deviations:

None C-8

Grand Gulf Nuclear Station I: le #I

a. Loss of power to (site-specific) transformers for greater than 15 minutes.

AND

b. At least (site-specific) emergency generators are supplying power to emergency busses Applicability: Cold Shutdown, Refueling Grand Gulf: S U I , EAL #I Loss of power from ESF-11 and ESF-21 and ESF-12 transformers for > I 5 Minutes Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU3, EAL # I is implemented by Grand Gulf SU1, EAL # I (Formatting only)

The second part of the NEI 99-01 Example EAL At least (site-specific) emergency generators are supplying power to emergency busses is not required because loss of power to the indicated ESF transformers for > I 5 minutes requires the declaration of at least an Unusual Event regardless of the condition to the emergency diesel generators.

If the diesel generators are available and supplying the ESF busses within 15 minutes after the loss of the ESF transformers, then declaration of an Unusual Event is required. If the diesel generators are not supplying the ESF busses within 15 minutes after the loss of the ESF transformers then the event escalates to an Alert classification per NEI 99-01 CA3 and Grand Gulf SA2.

Deviations:

None c-9

Grand Gulf Nuclear Station UNPLANNED Loss of Decay Heat Removal Capability with Irradiated Fuel in the RPV Applicability: Cold Shutdown, Refueling Grand Gulf: SU6 Unplanned loss of decay heat removal capability with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CU4 is implemented by Grand Gulf SU6 (Formatting only)

Deviations:

None c-10

Grand Gulf Nuclear Station El An UNPLANNED event results in RCS temperature exceeding the Technical Specification cold shutdown temperature limit Applicability: Cold Shutdown, Refueling Grand Gulf: SU6, EAL #I An unplanned event results in RCS temperature >2OO0F Applicability: 4, 5 Differet ces:

NEI CU4, EAL #is I implemented by Grand Gulf SU6, EAL #I(Formatting only) 200°F is the Grand Gulf cold shutdown temperature limit.

Deviations:

None C-ll

Grand Gulf Nuclear Station El 1: CU4, Exa Loss of all RCS temperature and RPV level indication for > 15 minutes Applicability: Cold Shutdown, Refueling Grand Gulf: SU6, EAL #2 Loss of all reactor coolant temperature RPV level indication for > 15 minutes Applicability: 4, 5 Differences:

NEI CU4, EAL #2 is implemented by Grand Gulf SU6, EAL #2 (Formatting only)

Deviations:

None c-12

Grand Gulf Nuclear Station El I:c Fuel Clad Degradation Applicability: Cold Shutdown, Refueling Grand Gulf: SUlO Fuel Clad Degradation.

Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU5 is implemented by Grand Gulf SUIO (Formatting only)

Applicability also includes modes I,2, and 3 as well as modes 4 and 5 because Grand Gulf SU9 also implements NEI SU4.

Deviations:

None C-13

Grand Gulf Nuclear Station (Site-specific) radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits Applicability: Cold Shutdown, Refueling Grand Gulf: SUIO, EAL #I Offgas isolation due to valid Offgas Post Treatment monitor signal.

(1H13-P601-19A-C8)

Applicability: I, 2, 3, 4, 5 Differences:

NEI CU5, EAL # I is implemented by Grand Gulf SUIO, EAL # I (Formatting only)

Deviations:

None C-14

Grand Gulf Nuclear Station I 99-01; cu5, xarnple EAL ##

(Site-specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.

Ap plicabiI ity : Cold Shutdown, Refueling Grand Gulf: SUIO, EAL #2 Coolant sample activity >4.0 t.Ci/rnl dose equivalent Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU5, EAL #2 is implemented by Grand Gulf SUIO, EAL #2 (Formatting only)

Deviations:

None C-15

Grand Gulf Nuclear Station UNPLANNED Loss of All Onsite or Offsite Communications Capabilities Applicability: Cold Shutdown, Refueling Grand Gulf: SU9 Unplanned loss of all onsite offsite communications capabilities Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU6 is implemented by Grand Gulf SU9 (Formatting only)

Applicability also includes modes 1, 2, and 3 as well as modes 4 and 5 because Grand Gulf SU8 also implements NEI SU6.

Deviations:

None C-16

Grand Gulf Nuclear Station I 99-01: CU6, Example EAL #I Loss of all (site-specific list) onsite communications capability affecting the ability to perform routine operations Applicability: Cold Shutdown, Refueling Grand Gulf: SU9, EAL #I Unplanned loss of all onsite communications equipment (See Table S1)

Table S1 Onsite Communications Equipment Plant Radio System Plant Paging System Sound Powered Phones In-plant telephones Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU6, EAL #is I implemented by Grand Gulf SU9, EAL #I (Formatting only)

Deviations:

None c-17

Grand Gulf Nuclear Station Loss of all (site-specific list) offsite communications capability A pplicabiIity : Cold Shutdown, Refueling Grand Gulf: SU9, EAL #2 Unplanned loss of all offsite communications equipment (See Table S2)

Table S2 Onsite Communications Equipment All telephone lines (commercial & fiber optics)

Satellite phone OHL NRC phones (ENS, HPN, MCL, RSCL, PMCL)

Cellular Phones UHF Radios Applicability: 1, 2, 3, 4, 5 Differences:

NEI CU6, EAL #2 is implemented by Grand Gulf SU9, EAL #2 (Formatting only)

Deviations:

None C-18

Grand Gulf Nuclear Station 7

UNPLANNED Loss of Required DC Power for Greater than 15 Minutes Applicability: Cold Shutdown, Refueling Grand Gulf: SU2 Unplanned loss of required DC power for > I 5 Minutes Applicability: 4, 5 Differences:

NEI CU7 is implemented by Grand Gulf SU2 (Formatting only)

Deviations:

None (2-19

Grand Gulf Nuclear Station El I:

UNPLANNED Loss of Vital DC power to required DC busses based on (site-specific) bus voltage indications ND Failure to restore power to at least one required DC bus within 15 minutes from the time of loss Applicability: Cold Shutdown, Refueling Grand Gulf: SU2, EAL #I Unplanned reduction in 11DA 11DB voltage to 4 0 5 VDC Unable to restore either 11DA or 11DB battery charger within 15 minutes after reaching 105 VDC Applicability: 4, 5 Differences:

NEI CU7, EAL # I is implemented by Grand Gulf SU2, EAL # I (Formatting only)

Deviations:

None c - 20

Grand Gulf Nuclear Station Inadvertent Criticality Applicability: Cold Shutdown, Refueling Grand Gulf: SU7 Inadvertent criticality Applicability: 3, 4, 5 Differences:

NEI CU8 is implemented by Grand Gulf SU7 (Formatting only)

Applicability also includes mode 3 because Grand Gulf SU6 also implements NEI SU8.

Deviations:

None c - 21

Grand Gulf Nuclear Station le #I An UNPLANNED extended positive period observed on nuclear instrumentation Applicability: Cold Shutdown, Refueling Grand Gulf: SU7, EAL #I An unplanned sustained positive period observed on nuclear instrumentation Applicability: 3, 4, 5 Differences:

NEI CU8, EAL #is I implemented by Grand Gulf SU7, EAL #I (Formatting only)

Extended change to sustained because it better describes critical period characteristic.

Deviations:

None c - 22

Grand Gulf Nuclear Station le ##

An UNPLANNED sustained positive startup rate observed on nuclear Instrumentation Applicability: Cold Shutdown, Refueling Grand Gulf: N/A None Applicability: N/A Differences:

The Grand Gulf nuclear instrumentation does not provide startup rate indication.

Startup rate indication is only applicable to PWRs.

Deviations:

None C - 23

Grand Gulf Nuclear Station I: I Loss of RCS Inventory Applicability: Cold Shutdown Grand Gulf: SA4 Loss of RCS inventory with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CAI is implemented by Grand Gulf SA4 (Formatting only)

NEI 99-01 contains two ICs (CAI & CA2) that deal with Lossof RCS inventory.

CAI is applicable in the Cold Shutdown mode whereas CA2 is applicable in the Refueling Mode. The NEI basis explains that the difference between CAI & CA2 deals with different means available for monitoring RCS inventory and level. Since the concern in this EAL is loss of inventory, it does not matter what means are used to determine that inventory is being lost. Therefore both NEI CAI & CA2 are implemented in Grand Gulf SA4.

NEI CAI does not include the words with irradiated fuel in the R P V which are contained in NEI CA2. By definition irradiated fuel is in the RPV in the Cold Shutdown mode. Therefore omission of with irradiated fuel in the R P V does not alter the intent or concept of NEI CAI.

Deviations:

None C - 24

Grand Gulf Nuclear Station Loss of RCS inventory as indicated by RPV level less than {site-specific level}.

(low-low ECCS actuation setpoint) (BWR)

Applicability: Cold Shutdown Grand Gulf: SA4, EAL #I Loss of RPV inventory as indicated by RPV level >-150.3 in (Level 1)

Applicability: 4, 5 Differences:

NEI CAI, EAL # I is implemented by Grand Gulf SA4, EAL # I (Formatting only)

Deviations:

None C - 25

Grand Gulf Nuclear Station Loss of RCS inventory as indicated by unexplained {site-specific} sump and tank level increase AND RCS level cannot be monitored for > 15 minutes Applicability: Cold Shutdown Grand Gulf: SA4, EAL #2 Loss of RPV inventory and RPV level cannot be monitored for > I 5 minutes Applicability: 4, 5 Differences:

NEI CAI , EAL #2 is implemented by Grand Gulf SA4, EAL #2 (Formatting only)

It does not matter what means are used to determine that inventory is being lost therefore specific means for determining loss of inventory are not included in the Grand Gulf EAL.

Deviations:

None C 26

Grand Gulf Nuclear Station 2

Loss of RCS Inventory With Irradiated Fuel in the RPV Ap piicabiI ity : Refueling Grand Gulf: SA4 Loss of RCS inventory with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CA2 is implemented by Grand Gulf SA4 (Formatting only)

NEI 99-01 contains two ICs (CAI & CA2) that deal with Loss of RCS inventory.

CAI is applicable in the Cold Shutdown mode whereas CA2 is applicable in the Refueling Mode. The NEI basis explains that the difference between CAI & CA2 deals with different means available for monitoring RCS inventory and level. Since the concern in this EAL is loss of inventory, it does not matter what means are used to determine that inventory is being lost. Therefore both NEI CAI & CA2 are implemented in Grand Gulf EAL SA4.

NEI CAI does not include the words with irradiated fuel in the R P V which are contained in NEI CA2. By definition irradiated fuel is in the RPV in the Cold Shutdown mode. Therefore omission of with irradiated fuel in the R P V does not alter the intent or concept of NEI CAI.

Deviations:

None C - 27

Grand Gulf Nuclear Station Loss of RCS inventory as indicated by RPV level less than {site-specific level}.

(low-low ECCS actuation setpoint) (BWR)

Applicability: Refueling Grand Gulf: SA4, EAL #I Loss of RPV inventory as indicated by RPV level >-150.3 in (Level 1)

Applicability: 4, 5 Differences:

NEI CA2, EAL #I is implemented by Grand Gulf SA4, EAL #(Formatting I only)

Deviations:

None C - 28

Grand Gulf Nuclear Station 1:

Loss of RCS inventory as indicated by unexplained {site-specific} sump and tank level increase AND RCS level cannot be monitored for > I 5 minutes A pplicabiI ity : Refueling Grand Gulf: SA4, EAL #2 Loss of RPV inventory and RPV level cannot be monitored for > I 5 minutes Applicability: 4, 5 Differences:

NEl CA2, ELA #2 is implemented by Grand Gulf SA4, EAL #2 (Formatting only)

It does not matter what means are used to determine that inventory is being lost therefore specific means for determining loss of inventory are not included in the Grand Gulf EAL.

Deviations:

None C - 29

Grand Gulf Nuclear Station 1: CA3 Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Busses Applicability: Cold Shutdown, Refueling, Defueled Grand Gulf: SAIL Loss of all offsite and onsite AC Power to Div I & II ESF Busses Applicability: 4, 5, D Differences:

NEI CA3 is implemented by Grand Gulf SA2 (Formatting only)

Deviations:

None C - 30

Grand Gulf Nuclear Station I : CA3, Exa Loss of power to (site-specific) transformers AND Failure of (site-specific) emergency generators to supply power to emergency busses AND Failure to restore power to at least one emergency bus within 15 minutes from the time of loss of both offsite and onsite AC power Applicability: Cold Shutdown, Refueling, Defueled Grand Gulf: SAIL, EAL #I Loss of power to 15AA and 16AB busses AND Failure to restore power to either 15AA 16AB bus within 15 minutes from the time of loss of both offsite and onsite AC power Applicability: 4, 5, D Differences:

NEI CA3, EAL #I is implemented by Grand Gulf SA2, EAL # I (Formatting only)

The Grand Gulf EAL utilizes the words Loss of power to ESF busses in lieu of the NEI Example EAL Loss of power to (site specific) transformers and Failure of (site-specific) emergency generators to supply power to emergency busses in order to simplify this EAL.

Deviations:

None C - 31

Grand Gulf Nuclear Station El 1: GA Inability to Maintain Plant in Cold Shutdown with Irradiated Fuel in the RPV Applicability: Cold Shutdown, Refueling Grand Gulf: SA5 Inability to maintain plant in cold shutdown with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CA4 is implemented by Grand Gulf SA5 (Formatting only)

Deuiat ions:

None C - 32

Grand Gulf Nuclear Station With CONTAINMENT CLOSURE and RCS integrity not established an UNPLANNED event results in RCS temperature exceeding the Technical Specification cold shutdown temperature limit.

Applicability: Cold Shutdown, Refueling Grand Gulf: SA5, EAL #I An unplanned event results in reactor coolant temperature >200 O F without CTMT and Reactor Pressure Boundary integrity Applicability: 4, 5 Differences:

NEI CA4, EAL #I is implemented by Grand Gulf SA5, EAL #(Formatting I only)

Changed RCS integrity to Reactor Pressure Boundary integrity.

Changed RCS temperature to reactor coolant temperature Deviations:

None c - 33

Grand Gulf Nuclear Station Ei 2 With CONTAINMENT CLOSURE established RCS integrity established RCS inventory reduced an UNPLANNED event results in RCS temperature exceeding the Technical Specification cold shutdown temperature limit for greater than 20 minutes.

Note: if an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced then this EAL is not applicable.

Applicability: Cold Shutdown, Refueling Grand Gulf: SA5, EAL #2 An unplanned event results in reactor coolant temperature >200 O F for >20 minutes See Note with CTMT integrity and without Reactor Pressure Boundary integrity Note: If a decay heat removal system is in operation within this time frame and reactor coolant temperature is being reduced then this EAL is not applicable Applicability: 4, 5 Differences:

NEI CA4, EAL #2 is implemented by Grand Gulf SA5, EAL #2 (Formatting only)

There is no reference to RCS reduced inventory in the Grand Gulf EAL because that type of operation is only applicable to PWRs.

Changed RCS temperature to reactor coolant temperature.

Changed RCS integrity to Reactor Pressure Boundary integrity.

Deviations:

None c - 34

Grand Gulf Nuclear Station El An UNPLANNED event results in RCS temperature exceeding the Technical Specification cold shutdown temperature limit for greater than 60 minutes' or results in an RCS pressure increase of greater than {site specific) psig.

'Note: if an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced then this EAL is not applicable.

Applicability: Cold Shutdown, Refueling Grand Gulf: SA5, EAL #3 An unplanned event results in reactor coolant temperature ~ 2 0 O0 F for >60 minutes See or results in RPV pressure increase > 10 psig Note -

Note: If a decay heat removal system is in operation within this time frame and reactor coolant temperature is being reduced then this EAL is not applicable Applicability: 4, 5 Differences:

NEI CA4, EAL #3 is implemented by Grand Gulf SA5, EAL #3 (Formatting only)

Changed RCS temperature to reactor coolant temperature.

Changed RCS pressure to RPV pressure.

Deviations:

None c - 35

Grand Gulf Nuclear Station Loss of RPV Inventory Affecting Core Decay Heat Removal Capability Applicability: Cold Shutdown Grand Gulf: SS4 Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV Applicability: 4,5 Differences:

NEI CS1 is implemented by Grand Gulf SS4 (Formatting only)

NEI 99-01 contains two ICs (CSI & CS2) that deal with Loss of RCS inventory.

CS1 is applicable in the Cold Shutdown mode whereas CS2 is applicable in the Refueling Mode. The NEI basis explains that the difference between CS1 & CS2 deals with different means available for monitoring RCS inventory and level. Since the concern in this EAL is loss of inventory, it does not matter what means are used to determine that inventory is being lost. Therefore both NEI CS1 & CS2 are implemented in Grand Gulf SS4.

NEI CS1 does not include the words with irradiated fuel in the R P V which are contained in NEl CS2. By definition irradiated fuel is in the RPV in the Cold Shutdown mode. Therefore omission of with irradiated fuel in the R P V does not alter the intent or concept of NEI CSI.

Deviations:

None C 36

Grand Gulf Nuclear Station With CONTAINMENT CLOSURE not established:

a. RPV inventory as indicated by RPV level less than {site-specific level}

(6 below the low-low ECCS actuation setpoint) (BWR)

(6 below the bottom ID of the RCS loop) (PWR)

OR

b. RPV level cannot be monitored for > 30 minutes with a loss of RPV inventory as indicated by unexplained {site-specific} sump and tank level increase Applicability: Cold Shutdown Grand Gulf: SS4 EAL #I Loss of RCS inventory AND RPV level cannot be monitored for >30 minutes Applicability: 4, 5 Differences:

NEI CS1, EAL # I is implemented by Grand Gulf SS4, EAL # I (Formatting only)

There are two NEI CS1 Example EALs. EAL #I is applicable when containment closure is not established and EAL #2 is applicable when containment closure is established. The b. parts of both Example EALs are identical. Therefore if RPV level cannot be monitored for >30 minutes with a loss of RCS inventory, the b. part of each NEI Example EAL is met regardless of containment closure.

The Grand Gulf SS4 EAL # I has implemented the b. parts of the NEI Example EAL # I & #2 as a single EAL without conditioning it on containment closure.

Deviations:

None c - 37

Grand Gulf Nuclear Station El EAL #2 With CONTAINMENT CLOSURE established

a. RPV inventory as indicated by RPV level less than TOAF

b. RPV level cannot be monitored for > 30 minutes with a loss of RPV inventory as indicated by either:

0 Unexplained {site-specific} sump and tank level increase 0 Erratic Source Range Monitor Indication Applicability: Cold Shutdown Grand Gulf: SS4 EAL #2 RPV level C-156.3 in with containment closure not established OR RPV level <-I67 in with containment closure established Applicability: 4, 5 Differences:

NEI CSI, EAL #2 is implemented by Grand Gulf SS4, EAL #2 (Formatting only)

There are two NEI CS1 Example EALs. # I is applicable when containment closure is not established and #2 is applicable when containment closure is established.

The Grand Gulf SS4 EAL #2 has implemented the a. parts of the NEI Example EAL # I & #2 as a single EAL with two parts conditioning each part on containment closure status.

Deviations:

None C 38

Grand Gulf Nuclear Station Loss of RPV Inventory Affecting Core Decay Heat Removal Capability with irradiated fuel in the RPV Applicability: Refueling Grand Gulf: SS4 Loss of RPV inventory affecting core decay heat removal capability with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CS2 is implemented by Grand Gulf SS4 (Formatting only)

NEI 99-01 contains two ICs (CSI & CS2) that deal with Loss of RCS inventory.

CS1 is applicable in the Cold Shutdown mode whereas CS2 is applicable in the Refueling Mode. The NEI basis explains that the difference between CS1 & CS2 deals with different means available for monitoring RCS inventory and level. Since the concern in this EAL is loss of inventory, it does not matter what means are used to determine that inventory is being lost. Therefore both NEI CS1 & CS2 are implemented in Grand Gulf SS4.

Deviations:

None c - 39

Grand Gulf Nuclear Station With CONTAINMENT CLOSURE not established:

a. RPV inventory as indicated by RPV level less than {site-specific level}

(6 below the low-low ECCS actuation setpoint) (BWR)

(6 below the bottom ID of the RCS loop) (PWR)

b. RPV level cannot be monitored for > 30 minutes with a loss of RPV inventory as indicated by unexplained {site-specific} sump and tank level increase Applicability: Refueling Grand Gulf: SS4 EAL #I Loss of RCS inventory AND RPV level cannot be monitored for >30 minutes Applicability: 4, 5 Differences:

NEI CS2, EAL #I is implemented by Grand Gulf SS4, EAL #I (Formatting only)

There are two NEI CS2 Example EALs. #is I applicable when containment closure is not established and #2 is applicable when containment closure is established. The b. parts of both of the Example EALs are identical. Therefore if RPV level cannot be monitored for >30 minutes with a loss of RCS inventory, the

b. part of each NEI Example EAL is met regardless of containment closure.

The Grand Gulf SS4 EAL #I has implemented the b. parts of the NEI Example EAL #& I#2 as a single EAL without conditioning it on containment closure.

See the discussion for CSI Example EAL #2 for discussion regarding implementation of the a. parts of the NEI CS2 Example EALs.

Deviations:

None C - 40

Grand Gulf Nuclear Station rn xarnple EAL With CONTAINMENT CLOSURE established

a. RPV inventory as indicated by RPV level less than TOAF

b. RPV level cannot be monitored for > 30 minutes with a loss of RPV inventory as indicated by either:

Unexplained {site-specific} sump and tank level increase Erratic Source Range Monitor Indication Applicability: Refueling Grand Gulf: SS4 EAL #2 RPV level <-156.3 in with containment closure not established OR RPV level <-I 67 in with containment closure established Applicability: 4, 5 Differences:

NEI CS2, EAL #2 is implemented by Grand Gulf SS4, EAL #2 (Formatting only)

There are two NEI CS2 Example EALs. # I is applicable when containment closure is not established and #2 is applicable when containment closure is established.

The Grand Gulf SS4 EAL #2 has implemented the a, parts of the NEI Example EAL # I & #2 as a single EAL with two parts conditioning each part on containment closure status.

Deviations:

None C - 41

Grand Gulf Nuclear Station El Loss of RPV Inventory Affecting Fuel Clad Integrity with Containment Challenged with Irradiated Fuel in the RPV.

Applicability: Cold Shutdown, Refueling Grand Gulf: SG3 Loss of RPV inventory affecting fuel clad integrity with containment challenged with irradiated fuel in the RPV Applicability: 4, 5 Differences:

NEI CGI is implemented by Grand Gulf SG3 (Formatting only)

Deviations:

None C - 42

Grand Gulf Nuclear Station AL ##I Loss of RPV inventory as indicated by unexplained {site-specific} sump and tank level increase Applicability: Cold Shutdown, Refueling Grand Gulf: NIA None Applicability: N/A Differences:

The NEI Example EAL #I is redundant to the conditions described in NEI Example EALs #2 & #3. RPV level c than Top of Active Fuel (TAF) or the inability to monitor RPV level, with indication of core uncovery, for > 30 minutes are indicative of loss of RPV inventory regardless of how it is determined.

Deviations:

None c - 43

Grand Gulf Nuclear Station le ##

RPV Level:

a. less than TOAF for > 30 minutes OR

b. cannot be monitored with Indication of core uncovery for > 30 minutes as evidenced by one or more of the following:

0 Containment High Range Radiation Monitor reading > {site-specific}

setpoint 0 Erratic Source Range Monitor indication 0 Other {site-specific} indications Applicability: Cold Shutdown, Refueling Grand Gulf: SG3, EAL #I RPV level:

a. <-I67 in for > 30 minutes or

b. cannot be monitored with indication of core uncovery for >30 minutes Applicability: 4, 5 Differences:

NEI CGI, EAL #2 is implemented by Grand Gu SG3, EAL # I (Formatting only Deviations:

None c - 44

Grand Gulf Nuclear Station El 1: C G 1 , E x a AL #3

{Site specific} indication of CONTAINMENT challenged as indicated by one or more of the following:

0 Explosive mixture inside containment 0 Pressure above {site specific} value 0 CONTAINMENT CLOSURE not established 0 Secondary Containment radiation monitors above {site specific} value (BWR only)

Applicability: Cold Shutdown, Refueling Grand Gulf: S G 3 , EAL #2

a. Containment closure is not established or

b. Containment pressure >22 psig or

c. Containment hydrogen concentration >19%

or

d. Any EP-4 radiation monitor reading above the Max Safe Value Applicability: 4, 5 Differences:

NEI CGI, EAL #3 is implemented by Grand Gulf SG3, EAL #2 (Formatting only)

The Grand Gulf EP-4 procedure is the Secondary Containment Emergency Operating Procedure. The Maximum Safe Operating Water values are the highest parameter values at which equipment necessary for the safe shutdown of the plant is assumed to fail or personnel access necessary for the safe shutdown of the plant will be precluded.

Deviations:

None c - 45

Grand Gulf Nuclear Station Permanently Defueled Station Malfunction This section is not applicable to or implemented at Grand Gulf.

Grand Gulf Nuclear Station Events Related to ISFSI Malfunction This section is not applicable to or implemented at Grand Gulf.

E-I

Grand Gulf Nuclear Station Fission Product Barrier Degradation F-1

Grand Gulf Nuclear Station ANY Loss or ANY Potential Loss of Containment Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: FUI Loss Potential Loss of Primary Containment Applicability: I,2, 3 Differences:

The Containment is referred to as the Primary Containment at Grand Gulf "ANY is omitted to provide consistency with wording in FSI and FG1.

Deviations:

None F-2

Grand Gulf Nuclear Station ANY Loss or ANY Potential Loss of EITHER Fuel Clad OR RCS Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: FA1 Loss 9Potential Loss of either Fuel Clad or Reactor Pressure Boundary Applicability: I, 2, 3 Differences:

The RCS is called the Reactor Pressure Boundary at Grand Gulf ANY is omitted to provide consistency with wording in FSI and FG1.

Deviations:

None F-3

Grand Gulf Nuclear Station Loss or Potential Loss of ANY Two Barriers Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: FSl Loss or Potential Loss of any two Fission Product Barriers Applicability: 1, 2, 3 Differences:

None Deviations:

None F-4

Grand Gulf Nuclear Station El I: I Loss of ANY Two Barriers AND Loss or Potential Loss of Third Barrier Applicability: Power Operation, Startup, Hot Shutdown Grand GulC: FGI Loss of any two Fission Product Barriers with Loss or Potential Loss of third barrier Applicability: 1, 2, 3 Differences:

None Deviations:

None F-5

Grand Gulf Nuclear Station 1:

Primary Coolant Activity Level This (site-specific) value corresponds to 300 pCi/gm 1131 equivalent. Assessment by the NUMARC EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to less than 5% fuel clad damage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad Barrier is considered lost. The value expressed can be either in mWhr observed on the sample or as uCi/gm results from analysis.

There is no equivalent "Potential Loss" EAL for this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Fuel Clad Barrier EAL #I Primary Coolant Activity Level Loss: Coolant activity >300 pCilm1 dose equivalent Potential Loss: None Applicability: 1, 2, 3 Differences:

Grand Gulf uses vCi/ml Il3' instead of uCi/gm Deviations:

None F-6

Grand Gulf Nuclear Station rrier le Reactor Vessel Water Level The "Loss" EAL (site-specific) value corresponds to the level which is used in EOPs to indicate challenge of core cooling. Depending on the plant this may be top of active fuel or 213 coverage of active fuel. This is the minimum value to assure core cooling without further degradation of the clad. The "Potential Loss" EAL is the same as the RCS barrier "Loss" EAL #2 below and corresponds to the (site-specific) water level at the top of the active fuel. Thus, this EAL indicates a "Loss" of RCS barrier and a "Potential Loss" of the Fuel Clad Barrier. This EAL appropriately escalates the emergency class to a Site Area Emergency. If the "Loss" value is also the Top of Active Fuel, the "Potential Loss" value must be a value indicating a higher level also corresponding to a higher level indicated in the RCS barrier "Loss" EAL #2.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Fuel Clad Barrier EAL #2 Reactor Vessel Water Level Loss: RPV water level cannot be restored above -192 in.

Potential Loss: RPV water level cannot be restored above -167 in.

Applicability: 1, 2, 3 Differences:

The -192 in. value used in the Loss part of the Grand Gulf EAL Corresponds to the Minimum Steam Cooling RPV Water Level (MSCRWL) utilized in the Alternate Level Control Contingency of the Grand Gulf EOPs. Water levels at or above this value assure Peak Cladding Temperature will not exceed 1500°F assuring adequate core cooling without degradation of the fuel clad.

The -167in. value corresponds to the Top of Active Fuel RPV Water Level and is the same level value used in the Reactor Pressure Boundary barrier "Loss" EAL. If there is indication of a leak in the drywell, this level indicates a "Loss" of Reactor Pressure Boundary and a "Potential Loss" of the Fuel Clad barriers.

Deviations:

None F-7

Grand Gulf Nuclear Station El AL #3 Drywell Radiation Monitoring The (site-specific) reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the drywell. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm dose equivalent I-131 or the calculated concentration equivalent to the clad damage used in EAL #I into the drywell atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage. This value is higher than that specified for RCS barrier Loss EAL #4. Thus, this EAL indicates a loss of both Fuel Clad barrier and RCS barrier.

Caution: it is important to recognize that in the event the radiation monitor is sensitive to shine from the reactor vessel or piping, spurious readings will be present and another indicator of fuel clad damage is necessary or compensated for in the threshold value.

There is no "Potential Loss" EAL associated with this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Fuel Clad Barrier EAL #3 Drywell Radiation Monitoring Loss: >5000 Whr Potential Loss: None Applicability: 1, 2, 3 Differences:

None Deviations:

None F-8

Grand Gulf Nuclear Station El EAL #4 Other (Site-Specific) Indications This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the Fuel Clad barrier, including indications from containment air monitors or any other (site-specific) instrumentation.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Fuel Clad Barrier EAL #4 Main Steam Line Radiation Monitoring Loss: Main Steam Line Radiation level > Hi Hi Alarm Setpoint (P608-18A-C4, P608-19A-C4)

Potential Loss: None Applicability: 1, 2, 3 Differences:

The function of the Main Steam Line Radiation Monitoring system is to detect increased MSL radiation level caused by fuel damage.

Dewiat ions:

None F-9

Grand Gulf Nuclear Station 1:

Emergency Director Judgment This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost. (See also IC SGI, "Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power", for additional information.)

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Fuel Clad Barrier EAL #5 Emergency Director Judgment Loss: Other Potential Loss: Other Applicability: 1, 2, 3 Differences:

None Deviations:

None F-10

Grand Gulf Nuclear Station arri AL #I Drywell Pressure The (site-specific) drywell pressure is based on the drywell high pressure set point which indicates a LOCA by automatically initiating the ECCS or equivalent makeup system.

There is no "Potential Loss" EAL corresponding to this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Reactor Pressure Boundary Barrier EAL #I Drywell Pressure Loss: > I psig in the drywell with indications of a leak in the drywell

.39 Potential Loss: None Applicability: 1, 2, 3 Differences:

The NEI Example EAL implies that drywell pressure indicates a LOCA. Grand Gulf included "with indications of a leak in the drywell" in the Grand Gulf EAL to ensure this EAL is not Implemented under non-leak conditions. (Le., loss of drywell cooling without reactor pressure boundary leak)

Deviations:

None F-11

Grand Gulf Nuclear Station 2

Reactor Vessel Water Level This "Loss" EAL is the same as "Potential Loss" Fuel Clad Barrier EAL #2. The (site-specific) water level corresponds to the level which is used in EOPs to indicate challenge of core cooling. Depending on the plant this may be top of active fuel or 213 coverage of active fuel. This EAL appropriately escalates the emergency class to a Site Area Emergency. Thus, this EAL indicates a loss of the RCS barrier and a Potential Loss of the Fuel Clad Barrier.

There is no "Potential Loss" EAL corresponding to this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Reactor Pressure Boundary Barrier EAL #2 Reactor Vessel Water Level Loss: RPV water level cannot be restored above -167in. with indications of a leak in the drywell Potential Loss: None Applicability: 1, 2,3 Differences:

The MSCRWL value of -192in. is used in the Grand Gulf EAL to ensure consistency with the Fuel Clad Barrier EAL #2.

The words "with indications of a leak in the drywell" were added to provide consistency with RCS Barrier EAL #Iand ensure this EAL is not implemented under non-leak conditions. &em,Loss of RPV inventory through SRVs greater than available makeup capability, SBO)

Deviations:

None F-12

Grand Gulf Nuclear Station E 3 RCS Leak Rate An unisolable MSL break is a breach of the RCS barrier. Thus, this EAL is included for consistency with the Alert emergency classification. The potential loss of RCS based on leakage is set at a level indicative of a small breach of the RCS but which is well within the makeup capability of normal and emergency high pressure systems. Core uncovery is not a significant concern for a 50 gpm leak, however, break propagation leading to significantly larger loss of inventory is possible. Many BWRs may be unable to measure an RCS leak of this size because the leak would likely increase drywell pressure above the drywell isolation set point. The system normally used to monitor leakage is typically isolated as part of the drywell isolation and is therefore unavailable. If primary system leak rate information is unavailable, other indicators of RCS leakage should be used.

Potential loss of RCS based on primary system leakage outside the drywell is determined from site-specific temperature or area radiation alarms low setpoint in the areas of the main steam line tunnel, main turbine generator, RCIC, HPCI, etc.,

which indicate a direct path from the RCS to areas outside primary containment.

The indicators should be confirmed to be caused by RCS leakage. The area temperature or radiation low alarm setpoints are indicated for this example to enable an Alert classification. An unisolable leak which is indicated by a high alarm setpoint escalates to a Site Area Emergency when combined with Containment Barrier EAL 3 (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Reactor Pressure Boundary Barrier EAL #3 RCS Leak Rate Loss: Unisolable RCIC Main Steam Line break Potential Loss: Unisolable RCS leakage >50 gpm Applicability: 1, 2, 3 Differences:

None Deviations:

None F-13

Grand Gulf Nuclear Station El 1: arrier Exa L Drywell Radiation Monitoring The (site-specific) reading is a value which indicates the release of reactor coolant to the drywell. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within T/S) into the drywell atmosphere. This reading will be less than that specified for Fuel Clad Barrier EAL

3. Thus, this EAL would be indicative of a RCS leak only. If the radiation monitor reading increased to that value specified by Fuel Clad Barrier EAL #3, fuel damage would also be indicated.

However, if the site specific physical location of the drywell radiation monitor is such that radiation from a cloud of released RCS gases could not be distinguished from radiation from adjacent piping and components containing elevated reactor coolant activity, this EAL should be omitted and other site specific indications of RCS leakage substituted.

There is no "Potential Loss" EAL associated with this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: NlA Applicability: NIA Differences:

The physical location of the Grand Gulf drywell radiation monitor prevents it from distinguishing the radiation source. This EAL is therefore omitted from the Grand Gulf implementation in accordance with the NEI guidance.

Deviations:

None F-14

Grand Gulf Nuclear Station Other (Site-Specific) Indications This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the RCS barrier.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Reactor Pressure Boundary Barrier EAL #4 Safety Relief Valves Loss: SRV stuck open Potential Loss: None Applicability: 1, 2, 3 Differences:

None Deviations:

None F-15

Grand Gulf Nuclear Station El AL #

Emergency Director Judgment This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost. (See also IC SGI, "Prolonged Loss of Offsite Power and Prolonged Loss of All Onsite AC Power", for additional information.)

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Reactor Pressure Boundary Barrier EAL #5 Emergency Director Judgment Loss: Other Potential Loss: Other Applicability: 1, 2, 3 Differences:

None Deviations:

None F-16

Grand Gulf Nuclear Station Ie Drywell Pressure Rapid unexplained loss of pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure increase indicates a loss of containment integrity. Drywell pressure should increase as a result of mass and energy release into containment from a LOCA. Thus, drywell pressure not increasing under these conditions indicates a loss of containment integrity. This indicator relies on the operators recognition of an unexpected response for the condition and therefore does not have a specific value associated. The unexpected response is important because it is the indicator for a containment bypass condition. The (site-specific) PSlG for potential loss of containment is based on the containment drywell design pressure. Existence of an explosive mixture means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. This applies to BWRs with Mark Ill containments, as well as Mark I and II containment designs when they are de-inerted.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Primary Containment Barrier EAL #I &#2 Primary Containment Pressure Loss: Unexplained loss of pressure following initial pressure increase Potential Loss: >22 psig in Primary Containment Hydrogen Concentration Loss: None Potential Loss: H2 igniters de-energized and either Drywell H2 >9% or Containment H2 in HDOL Unsafe Zone Applicability: 1, 2, 3 Differences:

Grand Gulf has a Mark 111 containment design. In the Mark Ill containment design the Primary Containment is referred to as the Primary Containment not the Drywell as in the Mark I & II containment designs.

The use of 22 psig in the potential loss EAL instead of the design pressure of 15 psig ensures consistency with the Grand Gulf EOP Containment Control strategies and with Grand Gulf SG3. The NEI discussion for this EAL does not require the F-17

Grand Gulf Nuclear Station use of containment design pressure but that the site specific number should be based on the containment design pressure. Primary Containment pressure in excess of 22 psig challenges the ability to successfully vent the primary containment due to the primary containment vent valve design and is the bases for the Grand Gulf EOP actions.

The Grand Gulf EAL #2 adds hydrogen concentration and hydrogen igniter condition as a Drywell Pressure potential loss EAL. As long as the hydrogen igniter are energized, hydrogen concentration can only exceed the deflagration limits if the combustion of hydrogen had depleted the oxygen below the minimum concentration required to support combustion (inerted). Hydrogen concentration above the deflagration limits without hydrogen igniter energized is similar to a de-inerted Mark I or ll containment.

Deviations:

None F-18

Grand Gulf Nuclear Station E I: tai L #2 Reactor Vessel Water Level The entry into the Primary Containment Flooding emergency procedure indicates reactor vessel water level can not be restored and that a core melt sequence is in progress. EOPs direct the operators to enter Containment Flooding when Reactor Vessel Level cannot be restored to greater than a Site Specific value (generally 2/3 core height) or is unknown. Entry into Containment Flooding procedures is a logical escalation in response to the inability to maintain reactor vessel level.

The conditions in this potential loss EAL represent imminent core melt sequences which, if not corrected, could lead to vessel failure and increased potential for containment failure. In conjunction with and an escalation of the level EALs in the Fuel and RCS barrier columns, this EAL will result in the declaration of a General Emergency -- loss of two barriers and the potential loss of a third. If the emergency operating procedures have been ineffective in restoring reactor vessel level above the RCS and Fuel Clad Barrier Threshold Values, there is not a "success" path and a core melt sequence is in progress. Entry into Containment flooding procedures is a logical escalation in response to the inability to maintain reactor vessel level.

Severe accident analysis (e.g., NUREG-I 150) have concluded that function restoration procedures can arrest core degradation with the reactor vessel in a significant fraction of the core damage scenarios, and the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow emergency operating procedures to arrest the core melt sequence. Whether or not the procedures will be effective should be apparent within the time provided. The Emergency Director should make the declaration as soon as it is determined that the procedures have been, or will be, ineffective.

There is no "loss" EAL associated with this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Primary Containment Barrier EAL #3 RPV Water Level Loss: None Potential Loss: Entry into SAP I, 5 or 6 Applicability: 1, 2, 3 F-19

Grand Gulf Nuclear Station iffer S:

The Grand Gulf Severe Accident Procedures (SAPS)implement the Primary Containment Flooding strategy referred to in the NEI discussion. Limiting the EAL to entry into SAP I,5 or 6 identifies plant conditions that potentially could challenge primary containment integrity.

Deviations:

None F - 20

Grand Gulf Nuclear Station El I: 3 Containment Isolation Failure or Bypass This EAL is intended to cover the inability to isolate the containment when containment isolation is required. In addition, the presence of area radiation or temperature alarms high setpoint indicating unisolable primary system leakage outside the drywell are covered after a containment isolation. The indicators should be confirmed to be caused by RCS leakage. Also, an intentional venting of primary containment for pressure control per EOPs to the secondary containment andlor the environment is considered a loss of containment. Containment venting for temperature or pressure when not in an accident situation should not be considered.

There is no "Potential Loss" EAL associated with this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Primary Containment Barrier EAL #4 Primary Containment Isolation Failure or Bypass Loss: Inability to isolate Primary Containment when isolation required OR Primary Containment venting required by SAPs Potential Loss: None Applicability: 1, 2, 3 Differences:

The Grand Gulf EAL references primary containment venting required by the SAPs instead of the EOPs. Operation within the limits of the EOPs ensure continued adequate core cooling thus no significant radiological release is expected as a result of controlled venting in the EOPs. This implements the concept described in the last sentence of the NEI Primary Containment Barrier Example EAL #3 discussion.

Deviations:

None F - 21

Grand Gulf Nuclear Station El Significant Radioactive Inventory in Containment The (site-specific) reading is a value which indicates significant fuel damage well in excess of that required for loss of RCS and Fuel Clad. As stated in Section 3.8, a major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted. NUREG-1228, "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents," indicates that such conditions do not exist when the amount of clad damage is less than 20%. Unless there is a (site-specific) analysis justifying a higher value, it is recommended that a radiation monitor reading corresponding to 20% fuel clad damage be specified here.

There is no "Loss" EAL associated with this item.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Primary Containment Barrier EAL #5 Primary Containment Radiation Monitoring Loss: None Potential Loss: > I 1,500 WHr Applicability: 1, 2, 3 Differences:

None Deviations:

None F - 22

Grand Gulf Nuclear Station El I: 5 Other (Site-Specific) Indications This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the containment barrier.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: NIA Applicability: N/A Differences:

None Deviations:

None F - 23

Grand Gulf Nuclear Station Emergency Director Judgment This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the Containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost. (See also IC SGI, "Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power", for additional information.)

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: Primary Containment Barrier EAL #5 Emergency Director Judgment Loss: Other Potential Loss: Other Applicability: 1, 2, 3 Differences:

None Deviations:

None F - 24

Grand Gulf Nuclear Station Hazards and Other Conditions Affecting Plant Safety This section contains the correlation between NEI 99-01 and Grand Gulf ICs and EALs in the Hazards and Other Conditions Affecting Plant Safety Recognition Category. It includes a statement of the NEI IC or EAL, a statement of the corresponding Grand Gulf IC or EAL, and sufficient discussion to describe any difference or to justify any deviation. Grand Gulf has renamed this the Hazards and Malfunction Recognition Category.

H-I

Grand Gulf Nuclear Station I

Natural and Destructive Phenomena Affecting the PROTECTED AREA Applicability: All Grand Gulf: HU3 Natural or destructive phenomena affecting the Protected Area Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HUI is implemented by Grand Gulf HU3 (Formatting only)

Deviations:

None H-2

Grand Gulf Nuclear Station le I (Site-Specific) method indicates felt earthquake.

EAL # I should be developed on site-specific basis. Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.

Method of detection can be based on instrumentation, validated by a reliable source, or operator assessment. As defined in the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, a "felt earthquakeI' is:

An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.

For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01g.

Applicability: All Grand Gulf: HU3, EAL #I Verified earthquake detected by in plant seismic instrumentation.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HUI, EAL # I is implemented by Grand Gulf HU3, EAL # I (Formatting only)

Deviations:

None H-3

Grand Gulf Nuclear Station El Report by plant personnel of tornado or high winds greater than (site-specific) mph striking within PROTECTED AREA boundary EAL #2 is based on the assumption that a tornado striking (touching down) or high winds within the PROTECTED AREA may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant.

The high wind site specific value in EAL#2 should be based on site-specific FSAR design basis. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

Applicability: All Grand Gulf: HU3, EAL #2 Tornado observed in the protected area.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HUI, EAL #2 is implemented by Grand Gulf HU3, ELA #2 (Formatting only)

There is no site-specific value used for high winds in the Grand Gulf EAL. The highest recorded wind speed of record in the Grand Gulf area is 69 mph. This value is below the hurricane minimum sustained wind speed of 74 mph. According to the Hurricane Research Division of the Atlantic Oceanographic and Meteorological Laboratory, damage due to wind speeds of 74 to 95 mph is expected to be limited primarily to shrubbery, tree, foliage, and unanchored homes. No real damage to other structures. The UFSAR only discusses the Design Bases Tornado and does not discuss hurricane force winds therefore only the reference to tornado was retained in the EAL.

Deviations:

None H-4

Grand Gulf Nuclear Station I: EAL #3 Vehicle crash into plant structures or systems within PROTECTED AREA boundary EAL #3 is intended to address crashes of vehicle types large enough to cause significant damage to plant structures containing functions and systems required for safe shutdown of the plant. If the crash is confirmed to affect a plant VITAL AREA, the event may be escalated to Alert.

Applicability: All Grand Gulf: HU3, EAL #3 Vehicle crash into a power block structure Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HUI, EAL #3 is implemented by Grand Gulf HU3, EAL #3 (Formatting only)

All power block structures at grand Gulf are within the Protected Area and contain functions and systems needed for safe shutdown.

Deviations:

None H-5

Grand Gulf Nuclear Station El EAL #

Report by plant personnel of an unanticipated EXPLOSION within PROTECTED AREA boundary resulting in VISIBLE DAMAGE to permanent structure or equipment For EAL #4 only those Explosions of sufficient force to damage permanent structures or equipment within the PROTECTED AREA should be considered. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the EXPLOSION with reports of evidence of damage is sufficient for declaration. The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Applicability: All Grand Gulf: HU3, EAL #4 NEI HUI, EAL #4 is implemented by Grand Gulf HU3, ELA #4 (Formatting only)

Explosion within the protected area causing damage to power block structure or equipment Applicability: 1, 2, 3, 4, 5, D Differences:

None Deviations:

None H-6

Grand Gulf Nuclear Station El . All #

Report of turbine failure resulting in casing penetration or damage to turbine or generator seals EAL #5 is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual FIRES and flammable gas build up are appropriately classified via HU2 and HU3. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.

This EAL is consistent with the definition of a NOUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by missiles generated by the failure or by the radiological releases for a BWR, or in conjunction with a steam generator tube rupture, for a PWR.

These latter events would be classified by the radiological ICs or Fission Product Barrier ICs.

Applicability: All Grand Gulf: HU3, EAL #5 Main turbine failure resulting in visual turbine casing, or generator seal damage Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HUI, EAL #5 is implemented by Grand Gulf HU3, EAL #5 (Formatting only)

Deviations:

None

Grand Gulf Nuclear Station Uncontrolled flooding in (site-specific) areas of the plant that has the potential to affect safety related equipment needed for the current operating mode.

EAL #6 addresses the effect of flooding caused by internal events such as component failures, equipment misalignment, or outage activity mishaps. The site-specific areas include those areas that contain systems required for safe shutdown of the plant, that are not designed to be wetted or submerged. Escalation of the emergency classification is based on the damage caused or by access restrictions that prevent necessary plant operations or systems monitoring. The plant's IPEEE may provide insight into areas to be considered when developing this EAL.

Applicability: All Grand Gulf: NlA AppI icabiI ity : N/A Differences:

Grand Gulf does not have any areas that can flood and affect safety related equipment.

Deviations:

None H-8

Grand Gulf Nuclear Station El I:

(Site-Specific) occurrences affecting the PROTECTED AREA EAL #7 covers other site-specific phenomena such as hurricane, flood, or seiche.

These EALs can also be precursors of more serious events. In particular, sites subject to severe weather as defined in the NUMARC station blackout initiatives, should include an EAL based on activation of the severe weather mitigation procedures (e.g., precautionary shutdowns, diesel testing, staff call-outs, etc.).

Applicability: All Grand Gulf: NIA Applicability: N/A Differences:

Hurricane force winds have never been recorded in the Grand Gulf area.

Grand Gulf does not have any areas that can flood and affect safety related equipment.

Grand Gulf is not subject to seiche.

Deviations:

None H-9

Grand Gulf Nuclear Station FIRE Within PROTECTED AREA Boundary Not Extinguished Within 15 Minutes of Detection.

Applicability: All Grand Gulf: HU4 Fire within power block not extinguished within 15 Minutes of detection.

Applicability: 1,2, 3,4,5, D Differences:

NEI HU2 is implemented by Grand Gulf HU4 (Formatting only)

All power block structures are within the protected area boundary.

Deviations:

None H-10

Grand Gulf Nuclear Station le #I FIRE in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within I 5 minutes of control room notification or verification of a control room alarm:

(Site-specific) list Applicability: All Grand Gulf: HU4, EAL #I FIRE in power block not extinguished within 15 minutes of either:

a. Man control room notification or

b. verification of annunciators Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HU2, EAL # I is implemented by Grand Gulf HU4, EAL # I (Formatting only)

Deviations:

None H-11

Grand Gulf Nuclear Station

. 3 Release of Toxic or Flammable Gases Deemed Detrimental to Normal Operation of the Plant.

Applicability: All Grand Gulf: HU5 Release of toxic or flammable gases deemed detrimental to normal operation of the plant.

Applicability: 1, 2,3,4, 5, D Differences:

NEI HU3 is implemented by Grand Gulf HU5 (Formatting only)

Deviations:

None H-12

Grand Gulf Nuclear Station le I Report or detection of toxic or flammable gases that has or could enter the site area boundary in amounts that can affect NORMAL PLANT OPERATIONS Appli~abi~ity: All Grand Gulf: HU5, EAL #I Determination of toxic, oxygen displacing or flammable gases in amount sufficient to disrupt normal plant operation Applicability: 1, 2, 3,4, 5, D Differences:

NEI HU3, EALI is implemented by Grand Gulf HU5, EAL #(Formatting I only)

Added oxygen displacing to be more encompassing.

Deviations:

None H-13

Grand Gulf Nuclear Station El .

3, Exa EAL #2 Report by Local, County or State Officials for evacuation or sheltering of site personnel based on an offsite event.

Applicability: All Grand Gulf: NIA Applicability: N/A Differences:

There are no industries near the Grand Gulf site that could result in a need for evacuation or sheltering.

Deviations:

None H-I4

Grand Gulf Nuclear Station Confirmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant Applicability: All Grand Gulf: HUI Confirmed security event which indicates a potential degradation in the level of safety of the plant Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HU4 is implemented by Grand Gulf HUI (Formatting only)

Deviations:

None H-15

Grand Gulf Nuclear Station le 1w Security events as determined from (site-specific) Safeguards Contingency Plan and reported by the (site-specific) security shift supervision Applicability: All Grand Gulf: HUI, EAL #2 Site Security Code Yellow (Armed adversary attempting to or has entered company property)

Applicability: 1, 2,3,4, 5, D Differences:

NEI HU4, EAL # I is implemented by Grand Gulf HUI , EAL #2 (Formatting only)

Site Security code system developed for rapid information transfer in fast moving security events.

Deviations:

None H-16

Grand Gulf Nuclear Station El I: AL #2 A credible site specific security threat notification Applicability: All Grand Gulf: HUI, EAL #I A credible threat notification received from, or validated by, a trustworthy source (FBI, NRC, Claiborne County SheriWs Office, Plant Management, Site Security, Etc.) Example: A report from Site Security of an unauthorized attempted PA entry should be considered a credible threat.

Applicability: 1,2, 3, 4, 5, D Differences:

NEI HU4, EAL #2 is implemented by Grand Gulf HUI, EAL # I (Formatting only)

Deviations:

None H-17

Grand Gulf Nuclear Station 5

Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of a NOUE.

A pplicabiIi ty : All Grand Gulf: HU2 Conditions exist which in the judgment of the emergency director warrant declaration of an Unusual Event.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HU5 is implemented by Grand Gulf HU2 (Formatting only)

Deviations:

None H-18

Grand Gulf Nuclear Station El I: EAL ##I Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Applicability: All Grand Gulf: HU2, EAL #I Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occur.

Applicability: 1, 2, 3, 4, 5,D Differences:

NEI HU5, EAL #I is implemented by Grand Gulf HU2, EAL #I (Formatting only)

Deviations:

None H-I9

Grand Gulf Nuclear Station El I: I Natural and Destructive Phenomena Affecting the Plant VITAL AREA Applicability: All Grand Gulf: HA4 Natural or destructive phenomena affecting a plant Vital Area Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA1 is implemented by Grand Gulf HA4 (Formatting only)

Deviations:

None H - 20

Grand Gulf Nuclear Station El 1:

(Site-Specific) method indicates Seismic Event greater than Operating Basis Earthquake (OBE).

Applicability: All Grand Gulf: HA4, EAL #I Verified earthquake detected by in plant seismic instrumentation greater than OBE Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HAI, EAL # I is implemented by Grand Gulf HA4, EAL # I (Formatting only)

Deviations:

None H-21

Grand Gulf Nuclear Station

. I Example EAL Tornado or high winds greater than (site-specific) mph within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the following plant structures I equipment or Control Room indication of degraded performance of those systems Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other (Site-Specific) Structures.

Applicability: All Grand Gulf: HA4, EAL #2 Tornado observed in Protected Area resulting in visual damage to a vital area Applicability: I,2, 3, 4, 5, D Differences:

NEI HAI, EAL #2 is implemented by Grand Gulf HA4, EAL #2 (Formatting only)

There is no site-specific value used for high winds in the Grand Gulf EAL. The highest recorded wind speed of record in the Grand Gulf area is 69 mph. This value is below the hurricane minimum sustained wind speed of 74 mph. According to the Hurricane Research Division of the Atlantic Oceanographic and Meteorological Laboratory, damage due to wind speeds of 74 to 95 mph is expected to be limited primarily to shrubbery, tree, foliage, and unanchored homes. No real damage to other structures. The UFSAR only discusses the Design Bases Tornado and does not discuss hurricane force winds therefore only reference to tornado was retained in the EAL.

Deviations:

None H - 22

Grand Gulf Nuclear Station El .

Vehicle crash within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the following plant structures or equipment therein or control indication of degraded performance of those systems:

Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other (Site-Specific) Structures.

Applicability: All Grand Gulf: HA4, EAL #3 Vehicle crash into a vital area structure resulting in visual damage to vital area Applicability: 1, 2, 3, 4, 5,D Differences:

NEI HA1, EAL #3 is implemented by Grand Gulf HA4, EAL #3 (Formatting only)

Deviations:

None H - 23

Grand Gulf Nuclear Station Turbine failure-generated missiles result in any VISIBLE DAMAGE to or penetration of any of the following plant areas: (site-specific) list.

Applicability: All Grand Gulf: HA4, EAL #5 Main turbine failure-generated missiles resulting in visual damage to vital area Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HAI, EAL #4 is implemented by Grand Gulf HA4, EAL #5 (Formatting only)

Deviations:

None H 24

Grand Gulf Nuclear Station El .

m Uncontrolled flooding in (site-specific) areas of the plant that results in degraded safety system performance as indicated in the control room or that creates industrial safety hazards (e.g., electric shock) that precludes access necessary to operate or monitor safety equipment.

Applicability: All Grand Gulf: NIA Applicability: N/A Differences:

Grand Gulf does not have any areas that can flood and affect safety related equipment.

Deviations:

None H - 25

Grand Gulf Nuclear Station AL #

(Site-Specific) occurrences within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to plant structures containing equipment necessary for safe shutdown, or has caused damage as evidenced by control room indication of degraded performance of those systems.

Applicability: All Grand Gulf: HA4, EAL #4 Explosion within the Protected Area causing visual damage to vital area Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA1, EAL #6 is implemented by Grand Gulf HA4, EAL #4 (Formatting only)

Explosion is included in this EAL to provide consistency with NEI HUI , Example EAL #4. See discussion on NEI HA2 for additional information.

Deviations:

None H - 26

Grand Gulf Nuclear Station El FIRE or EXPLOSION Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown.

Applicability: All Grand Gulf: HA5 FIRE affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Applicability: 1, 2, 3, 4, 5,D Differences:

NEI HA2 is implemented by Grand Gulf HA5 (Formatting only)

Explosion was included in Grand Gulf HA4, EAL ##4to provide consistency with NEI HUI, Example EAL #4.

Deviations:

None H - 27

Grand Gulf Nuclear Station EAL #I FIRE or EXPLOSION in any of the following (site-specific) areas:

(Site-specific) list AND Affected system parameter indications show degraded performance or plant personnel report VISIBLE DAMAGE to permanent structures or equipment within the specified area.

Applicability: All Grand Gulf: HA5, EAL #I Fire causing visual damage to plant safety equipment required to establish and maintain safe shutdown Applicability: I, 2, 3, 4, 5, D Differences:

NEI HA2, EAL #is I implemented by Grand Gulf HA5, EAL #(Formatting I only)

Explosion was included in Grand Gulf HA4, EAL #4 to provide consistency with NEI HUI, Example EAL #4.

Deviations:

None H - 28

Grand Gulf Nuclear Station El Release of Toxic or Flammable Gases Within or Contiguous to a VITAL AREA Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or Establish or Maintain Safe Shutdown.

Applicability: All Grand Gulf: HA6 Release of toxic or flammable gases within or contiguous to a Vital Area which jeopardizes operation of safety systems required to establish or maintain safe shutdown.

Applicability: I, 2, 3, 4, 5,D Differences:

NEI HA3 is implemented by Grand Gulf HA6 (Formatting only)

Deviations:

None H 29

Grand Gulf Nuclear Station Report or detection of toxic gases within or contiguous to a VITAL AREA in concentrations that may result in an atmosphere IMMEDIATELY DANGEROUS TO LIFE AND HEALTH (IDLH)

Applicability: All Grand Gulf: HA6, EAL #I Determination of toxic, oxygen displacing or flammable gasses in a vital area, that must be manned for safe operation of the plant, immediately dangerous to life and health or > lower flammability limit.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA3, EAL #is I implemented by Grand Gulf HA6, EAL #I (Formatting only)

Combined NEI HA3, Example EALs #& I#2 into a single EAL in the Grand Gulf implementation Deviations:

None H - 30

Grand Gulf Nuclear Station A3, Example EAL Report or detection of gases in concentration greater than the LOWER FLAMMABILITY LIMIT within or contiguous to a VITAL AREA pplicability: All Grand Gulf: HA6, EAL #I Determination of toxic, oxygen displacing or flammable gasses in a vital area, that must be manned for safe operation of the plant, immediately dangerous to life and health or > lower flammability limit.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA3, EAL #2 is implemented by Grand Gulf HA6, EAL #(Formatting I only)

Combined NEI HA3, Example EALs #& I#2 into a single EAL in the Grand Gulf implementation Deviations:

None H 31

Grand Gulf Nuclear Station El Confirmed Security Event in a Plant PROTECTED AREA.

Applicability: All Grand Gulf: HA1 Confirmed security event in plant Protected Area Applicability: 1, 2, 3, 4, 5,D Differences:

NEI HA4 is implemented by Grand Gulf HA1 (Formatting only)

Deviations:

None H - 32

Grand Gulf Nuclear Station El I:

INTRUSION into the plant PROTECTED AREA by a HOSTILE FORCE Applicability: All Grand Gulf: NAI, EAL # I Site Security Code Orange (Armed adversary attempting to or has crossed the Protected Area fence)

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA4, EAL #I is implemented by Grand Gulf HAI, EAL #(Formatting I only)

Site Security code system developed for rapid information transfer in fast moving security events.

Deviations:

None H - 33

Grand Gulf Nuclear Station El AL #2 Other security events as determined from (site-specific) Safeguards Contingency Plan and reported by the (site-specific) security shift supervision Applicability: All Grand Gulf: NIA Applicability: N/A Differences:

Grand Gulf EAL #encompasses I all security events as determined from the Safeguards Contingency Plan.

Deviations:

None H .. 34

Grand Gulf Nuclear Station 5

Control Room Evacuation Has Been Initiated.

Applicability: All Grand Gulf: HA3 Control room evacuation has been initiated.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA5 is implemented by Grand Gulf HA3 (Formatting only)

Deviations:

None H - 35

Grand Gulf Nuclear Station AL #I Entry into (site-specific) procedure for control room evacuation Applicability: All Grand Gulf: HA3, EAL #I Control Room evacuation has been directed per 05-I-02-11-1, Shutdown from the Remote Shutdown Panel.

Applicability: 1, 2, 3,4, 5, D Differences:

NEI HA5, EAL #I is implemented by Grand Gulf HA3, EAL # I (Formatting only)

Deuiations:

None H - 36

Grand Gulf Nuclear Station El 1:

Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of an Alert.

pplicability: All Grand Gulf: HA2 Conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA6 is implemented by Grand Gulf HA2 (Formatting only)

Deviations:

None H - 37

Grand Gulf Nuclear Station Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels .

A pplicabiIity : All Grand Gulf: HA2, EAL #I Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA6, EAL #I is implemented by Grand Gulf HA2, EAL #(Formatting I only)

Deviations:

None H - 38

Grand Gulf Nuclear Station Confirmed Security Event in a Plant VITAL AREA Applicability: All Grand Gulf: H S I Confirmed security event in a plant Vital Area Applicability: 1, 2,3,4, 5, D Differences:

None Deviations:

None H - 39

Grand Gulf Nuclear Station El EAL #1 INTRUSION into the plant VITAL AREA by a HOSTILE FORCE Applicability: All Grand Gulf: HSI, EAL #I Site Security Code Red (Armed adversary has entered any power block building or vital area)

Applicability: 1, 2, 3, 4, 5, D Differences:

Site Security code system developed for rapid information transfer in fast moving security events.

Deviations:

None H-40

Grand Gulf Nuclear Station 1, le Other security events as determined from (site-specific) Safeguards Contingency Plan and reported by the (site-specific) security shift supervision A pplicabiI ity : All Grand Gulf: N/A Applicability: NIA Differences:

Grand Gulf EAL #I encompasses all security events as determined from the Safeguards Contingency Plan.

Deviations:

None H - 41

Grand Gulf Nuclear Station Control Room Evacuation Has Been Initiated and Plant Control Cannot Be Established.

pplicabiIity : All Grand Gulf: HS3 Control Room evacuation has been initiated and plant control cannot be established.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA2 is implemented by Grand Gulf HA3 (Formatting only)

Deviations:

None H 42

Grand Gulf Nuclear Station le I Control room evacuation has been initiated.

AND Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.

Applicability: All Grand Gulf: HS3, EAL #I Control Room evacuation has been directed per 05-I-02-11-1, Shutdown from the Remote Shutdown Panel and control of the plant cannot be established in c 15 minutes.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA2, EAL #is I implemented by Grand Gulf HA3, EAL #(Formatting I only)

Deviations:

None H - 43

Grand Gulf Nuclear Station Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of Site Area Emergency.

pplicability: All Grand Gulf: HS2 Conditions exist which in the judgment of the Emergency Director warrant declaration of Site Area Emergency.

Applicability: 1, 2, 3,4,5, D Differences:

NEI HA3 is implemented by Grand Gulf HA2 (Formatting only)

Deviations:

None H 44

Grand Gulf Nuclear Station El EAL #I Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Applicability: All Grand Gulf: HS2, EAL #I Conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Applicability: 1, 2, 3, 4, 5, D Differences:

NEI HA3, EAL #is I implemented by Grand Gulf HA2, EAL #I (Formatting only)

Deviations:

None H - 45

Grand Gulf Nuclear Station 1

Security Event Resulting in Loss Of Physical Control of the Facility.

Applicability: All Grand Gulf: HG1 Security event resulting in loss of physical control of the facility.

Applicability: 1, 2,3, 4, 5,D Differences:

None Deviations:

None H - 46

Grand Gulf Nuclear Station A HOSTILE FORCE has taken control of plant equipment such that plant personnel are unable to operate equipment required to maintain safety functions.

Ap plicabiIity : All Grand Gulf: H G I , EAL #I Loss of physical control of the Control Room due to a security event or Loss of physical control of the Remote Shutdown Panel due to a security event or Loss of physical control of adequate core cooling or reactivity control capability Applicability: 1, 2, 3, 4, 5,D Differences:

None Deviations:

None H

47

Grand Gulf Nuclear Station 2

Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of General Emergency.

pplicability: All Grand Gulf: HG2 Other conditions existing which in the judgment of the Emergency Director warrant declaration of General Emergency.

Applicability: 1, 2, 3, 4, 5,D Differences:

None Deviations:

None H - 48

Grand Gulf Nuclear Station I: le #I Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Applicability: All Grand Gulf: HG2, EAL #I Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Applicability: I, 2, 3, 4, 5, D Differences:

None Deviations:

None H - 49

Grand Gulf Nuclear Station System Malfunction This section contains the correlation between NEI 99-01 and Grand Gulf ICs and EALs in the System Malfunction Recognition Category. It includes a statement of the NEI IC or EAL, a statement of the corresponding Grand Gulf IC or EAL, and sufficient discussion to describe any difference or to justify any deviation.

The Cold Shutdown/ Refueling System Malfunctions were combined with the System Malfunction recognition category to address human factors issues and make the System Malfunction recognition category consistent with the remaining recognition categories.

s-I

Grand Gulf Nuclear Station El Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: S U I Loss of all offsite power to ESF busses for > 15 Minutes Applicability: 1, 2, 3, 4,5 Differences:

Applicability includes modes 4 and 5 because Grand Gulf SU! Also implements NEI CU3.

Deviations:

None s-2

Grand Gulf Nuclear Station El Loss of power to (site-specific) transformers for greater than 15 minutes.

AND At least (site-specific) emergency generators are supplying power to emergency busses.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SUI, EAL #I Loss of power from ESF-11 and ESF-21 and ESF-12 transformers for > I 5 minutes Applicability: 1, 2, 3, 4, 5 Differences:

Applicability includes modes 4 and 5 because Grand Gulf SU! Also implements NEI CU3.

Deviations:

None s-3

Grand Gulf Nuclear Station El 1: 2 Inability to Reach Required Shutdown Within Technical Specification Limits.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: S U l l Inability to reach required shutdown within technical specification time limits Applicability: 1, 2, 3 Differences:

NEI SU2 is implemented by Grand Gulf SU11 (Formatting only)

Deviations:

None S-4

Grand Gulf Nuclear Station Plant is not brought to required operating mode within (site-specific) Technical Specifications LCO Action Statement Time.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: S U I I , EAL #I Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time Applicability: 1, 2, 3 Differences:

NEI SU2, EAL # I is implemented by Grand Gulf SU11, EAL # I (Formatting only)

Deviations:

None s-5

Grand Gulf Nuclear Station El UNPLANNED Loss of Most or All Safety System Annunciation or Indication in The Control Room for Greater Than 15 Minutes Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SU8 Unplanned loss of most or all safety system annunciation or indication in the control room for >5Iminutes Applicability: 1, 2, 3 Differences:

NEI SU3 is implemented by Grand Gulf SU8 (Formatting only)

Deviations:

None S-6

Grand Gulf Nuclear Station El UNPLANNED loss of most or all (site-specific) annunciators or indicators associated with safety systems for greater than 15 minutes.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SU8, EAL #I Unplanned loss of most or all safety system annunciators or indication on 1H I 3-P680, 1H I 3-P601 and 1H I 3-P870 for > I 5 minutes Applicability: 1, 2, 3 Differences:

NEI SU3, EAL # I is implemented by Grand Gulf SU8, EAL # I (Formatting only)

Deviations:

None s-7

Grand Gulf Nuclear Station El I:s Fuel Clad Degradation.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SUIO Fuel Clad Degradation.

Applicability: I, 2, 3, 4, 5 Differences:

NEI SU4 is implemented by Grand Gulf SUlO (Formatting only)

Applicability modes 4 and 5 included because Grand Gulf SU9 also implements NEI CU5.

Deviations:

None S-8

Grand Gulf Nuclear Station El 1: s (Site-specific) radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SUIO, EAL #I Offgas isolation due to valid Offgas Post Treatment monitor signal.

(1H I 3-P601-19A-C8)

Applicability: 1, 2, 3, 4, 5 Differences:

NEI SU4, EAL # I is implemented by Grand Gulf SUIO, EAL # I (Formatting only)

Applicability modes 4 and 5 included because Grand Gulf SUIO also implements NEI CU5.

Deviations:

None s-9

Grand Gulf Nuclear Station (Site-specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.

App~icability:Power Operations, Startup, Hot Shutdown Grand Gulf: SUIO, EAL #2 Coolant sample activity >4.0 vCi/gm 1-131 dose equivalent.

Applicability: 1, 2, 3, 4, 5 Differences:

NEI SU4, EAL #2 is implemented by Grand Gulf SUIO, EAL #2 (Formatting only)

Applicability modes 4 and 5 included because Grand gulf SUlO also implements NEI CU5 Deviations:

None s-lo

Grand Gulf Nuclear Station RCS Leakage Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SU3 Loss of RPV inventory Applicability: 1, 2, 3 Differences:

NEI SU5 is implemented by Grand Gulf SU3 (Formatting only)

Deviations:

None s-11

Grand Gulf Nuclear Station Unidentified or pressure boundary leakage greater than 10 gpm Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SU3, EAL #I Unidentified or pressure boundary leakage > I 0 gpm Applicability: 1, 2, 3 Differences:

NEI SU5, EAL # I is implemented by Grand Gulf SU3, EAL #(Formatting I only)

Deviations:

None s-12

Grand Gulf Nuclear Station 1: #

Identified leakage greater than 25 gpm Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SU3, EAL #2 Identified leakage >35 gpm Applicability: 1, 2,3 Differences:

NEI SU5, ELA #2 is implemented by Grand Gulf SU3, EAL #2 (Formatting only)

Deviations:

None S-13

Grand Gulf Nuclear Station I: 6 UNPLANNED Loss of All Onsite or Offsite Communications Capabilities Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SU9 Unplanned loss of all onsite or offsite communications capabilities Applicability: 1, 2, 3, 4,5 Differences:

NEI SU6 is implemented by Grand Gulf SU9 (Formatting only)

Applicability mode 4 and 5 included because Grand Gulf SU9 also implements NEI CU6.

Deviations:

None S-14

Grand Gulf Nuclear Station I E Loss of all (site-specific list) onsite communications capability affecting the ability to perform routine operations Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SU9, EAL #I Loss of all onsite communications equipment (See Table S l )

Table S1 Onsite Communications Equipment Plant Radio System Plant Paging System Sound Powered Phones In-plant telephones Applicability: 1, 2, 3, 4, 5 Differences:

NEI SU6, EAL #I is implemented by Grand Gulf SU9, EAL #I (Formatting only)

Applicability mode 4 and 5 included because Grand Gulf SU9 also implements NEI CU6.

Deviations:

None S-15

Grand Gulf Nuclear Station Loss of all (site-specific list) offsite communications capability Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SU8, EAL #2 Loss of all offsite communications equipment (See Table S2)

Table S2 Offsite Communications Equipment All telephone lines (commercial and microwave)

Satellite phone OHL NRC phones (ENS, HPN, MCL, RSCL, PMCL)

Cellular phones UHF radios Applicability: 1, 2, 3, 4, 5 Differences:

NEI SU6, EAL #2 is implemented by Grand Gulf SU8, EAL #2 (Formatting only)

Applicability mode 4 and 5 included because Grand Gulf SU3 also implements NEI CU6.

Deviations:

None S-16

Grand Gulf Nuclear Station m

Inadvertent Criticality Applicability: Hot Shutdown Grand Gulf: SlJ7 Inadvertent criticality Applicability: 3, 4, 5 Differences:

NEI SU8 is implemented by Grand Gulf SU7 (Formatting only)

Applicability mode 4 and 5 included because Grand Gulf SU7 also implements NEI CU8.

Deviations:

None s-17

Grand Gulf Nuclear Station El I: EAL #I An UNPLANNED extended positive period observed on nuclear instrumentation.

Applicability: Hot Shutdown Grand Gulf: SU7, EAL #I An unplanned sustained positive period observed on nuclear instrumentation.

Applicability: 3, 4, 5 Differences:

NEI SU8, EAL # I is implemented by Grand Gulf SU7, ELA # I (Formatting only)

Applicability mode 4 and 5 included because Grand Gulf SU7 also implements NEI CU8.

Replaced extended with sustained because it better describes the critical period characteristics.

Deviations:

None S-18

Grand Gulf Nuclear Station An UNPLANNED sustained positive startup rate observed on nuclear instrumentation Applicability: Hot Shutdown Grand Gulf: NIA Applicability: N/A Differences:

Startup rate indication is not used in the BWR design.

Deviations:

None s-19

Grand Gulf Nuclear Station Failure of Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was Successful.

Applicability: Power Operation, Startup Grand Gulf: SA3 Failure of reactor protection system instrumentation to complete or initiate an automatic reactor scram once a reactor protection system setpoint has been exceeded and manual scram was successful.

Applicability: 1, 2 Differences:

NEI SA2 is implemented by Grand Gulf SA3 (Formatting only)

Deviations:

None s - 20

Grand Gulf Nuclear Station El AL #

Indication(s) exist that indicate that reactor protection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred.

Applicability: Power Operations, Startup Grand Gulf: SA3, EAL #I Automatic scram failed to rapidly insert sufficient control rods to bring the reactor subcritical, and a manual scram was successful Applicability: 1, 2 Differences:

NEI SA2, EAL # I is implemented by Grand Gulf SA3, EAL # I (Formatting only)

Added to rapidly insert sufficient control rods to bring the reactor subcritical to quantify the successful scram criteria. The NEI bases states that if sufficient control rods are inserted to bring the reactor subcritical on a scram, the scram is considered successful.

Deviations:

None s-21

Grand Gulf Nuclear Station UNPLANNED Loss of Most or All Safety System Annunciation or Indication in Control Room With Either (1) a SIGNIFICANT TRANSIENT in Progress, or (2)

Compensatory Non-Alarming Indicators are Unavailable.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SA6 Unplanned loss of most or all safety system annunciation or indication in control room with either a significant transient in progress, or compensatory non-alarming indicators are unavailable Applicability: 1, 2, 3 Differences:

NEI SA4 is implemented by Grand Gulf SA6 (Formatting only)

Deviations:

None s - 22

Grand Gulf Nuclear Station AL #

UNPLANNED loss of most or all (site-specific) annunciators or indicators associated with safety systems for greater than 15 minutes.

AND Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR

b. Compensatory non-alarming indications are unavailable.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SA6, EAL #I Unplanned loss of most or all safety system annunciators or indication on 1H13-P680 or 1Hl3-P601 or 1H13-P870 for > I 5 minutes AND Either:

a. A significant transient is in progress.

or

b. Compensatory non-alarming indications are unavailable.

Applicability: 1, 2, 3 Differences:

NEI SA4, EAL # I is implemented by Grand Gulf SA6, EAL #I (Formatting only)

Deviations:

None S - 23

Grand Gulf Nuclear Station El AC power capability to essential busses reduced to a single power source for greater than 15 minutes such that any additional single failure would result in station blackout.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: S A I AC power capability to Div I & II ESF busses reduced to a single power source for

>I 5 minutes such that any additional single failure would result in loss of AC power to both Div I & II ESF busses.

Applicability: 1, 2, 3 Differences:

NEI SA4 is implemented by Grand Gulf SAI (Formatting only)

Deviations:

None S - 24

Grand Gulf Nuclear Station E I:SA5, AC power capability to site-specific essential busses reduced to a single power source for greater than 15 minutes AN Any additional single failure will result in station blackout.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: S A I , EAL #I AC power to 15AA and 16AB busses reduced to only one of the following sources for >I 5

minutes

a. ESFl1 or ESF21 or ESF12 transformers OR

b. DGI 1 or DG12 diesel generators Applicability: 1, 2, 3 Differences:

NEI SA4, EAL # I is implemented by Grand Gulf SA1, EAL # I (Formatting only)

Deviations:

None S - 25

Grand Gulf Nuclear Station E I:S S I Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Busses Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SSI Loss of all offsite and onsite AC power to Div I & II ESF busses Applicability: 1, 2, 3 Differences:

None Deviations:

None S - 26

Grand Gulf Nuclear Station AL ti Loss of power to (site-specific) transformers AND Failure of (site-specific) emergency generators to supply power to emergency busses AND Failure to restore power to at least one emergency bus within (site-specific) minutes from the time of loss of both offsite and onsite AC power Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: S S I , EAL #I Loss of power to 15AA and 16AB busses AND Failure to restore power to either 15AA or 16AB bus within 15 minutes from the time of loss of both offsite and onsite AC power Applicability: 1, 2, 3 Differences:

None Deviations:

None s - 27

Grand Gulf Nuclear Station Failure of Reactor Protection System Instrumentationto Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was NOT Successful.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SS3 Failure of reactor protection system instrumentation to complete or initiate an automatic reactor scram once a reactor protection system setpoint has been exceeded and manual scram was not successful.

Applicability: 1, 2, 3 Differences:

NEI SS2 is implemented by Grand Gulf SS3 (Formatting only)

Deviations:

None S - 28

Grand Gulf Nuclear Station le 1 Indication(s) exist that automatic and manual scram were not successful.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulk SS3,EAL #I Automatic scram and a manual scram failed to rapidly insert sufficient control rods to bring the reactor subcritical Applicability: 1, 2, 3 Differences:

NEI SS2, EAL #I is implemented by Grand Gulf SS3, EAL #(Formatting I only)

Added to rapidly insert sufficient control rods to bring the reactor subcritical to quantify the successful scram criteria. The NEl bases states that if sufficient control rods are inserted to bring the reactor subcritical on a scram, the scram is considered successful.

Deviations:

None S 29

Grand Gulf Nuclear Station Loss of All Vital DC Power Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SS2 Loss of all vital DC power Applicability: 1, 2, 3 Differences:

NEI SS3 is implemented by Grand Gulf SS2 (Formatting only)

Deviations:

None S - 30

Grand Gulf Nuclear Station I:ss3, EAL #I Loss of All Vital DC Power based on (site-specific) bus voltage indications for greater than 15 minutes.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SS2, EAL #I 11DA and 11DB 1105 VDC for > I 5 minutes Applicability: 1, 2, 3 Differences:

NEI SS3, EAL #is Iimplemented by Grand Gulf SS2, EAL #(Formatting I only)

Deviations:

None S-31

Grand Gulf Nuclear Station I: ss Complete Loss of Heat Removal Capability.

Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SS5 Complete loss of heat removal capability.

Applicability: 1, 2, 3 Differences:

NEI SS4 is implemented by Grand Gulf SS5 (Formatting only)

Deviations:

None S - 32

Grand Gulf Nuclear Station Heat Capacity Temperature Limit Curve exceeded (BWR).

Applicability: Power Operations, Startup, Hot Shutdown Grand GulC: SS5, EAL #I Inability to maintain Suppression Pool temperature in the HCTL Safe Zone requiring Emergency Depressurization per EP-3 Applicability: 1, 2, 3 Differences:

NEI SS4, EAL #is I implemented by Grand Gulf SS5, EAL #(Formatting I only)

Deviations:

None s - 33

Grand Gulf Nuclear Station El 1:

Inability to Monitor a SIGNIFICANT TWNSIENT in Progress Applicability: Power Operation, Startup, Hot Shutdown Grand Gulf: SS6 Inability to monitor a significant transient in progress Applicability: 1, 2, 3 Differences:

None Deviations:

None s - 34

Grand Gulf Nuclear Station 199-01: SS6, #I

a. Loss of most or all (site-specific) annunciators associated with safety systems.

AND

b. Compensatory non-alarming indications are unavailable.

AND

c. Indications needed to monitor (site-specific) safety functions are unavailable.

AND

d. SIGNIFICANT TRANSIENT in progress.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SS6, EAL #I

a. Unplanned loss of most or all safety system annunciators or indication on 1H I 3-P680,1 H I3-P601 and IH I3-P870 for > 5I minutes AND

b. Indications needed to monitor criticality or core heat removal or fission product barrier status are unavailable AND

c. Significant transient in progress AND

d. Compensatory non-alarming indications are unavailable Applicability: 1, 2, 3 Differences:

None Deviations:

None s - 35

Grand Gulf Nuclear Station El Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power to Essential Busses App~icabi~ity: Power Operation, Startup, Hot Shutdown Grand Gulf: SGI Prolonged Loss (>4hrs) of all offsite and onsite AC power to Div I & II ESF busses.

Applicability: I,2,3 Differences:

Grand Gulf has a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Station Blackout coping analysis.

Deviations:

None S - 36

Grand Gulf Nuclear Station Loss of power to (site-specific) transformers AND Failure of (site-specific) emergency diesel generators to supply power to emergency busses AND Either of the following: (a or b)

a. Restoration of at least one emergency bus within (site-specific) hours is not likely OR

b. (Site-Specific) Indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SGI, EAL #I Loss of AC power to 15AA and 16AB busses, AND Either:

a. Restoration of AC power to either 15AA or 16AB within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely or

b. Conditions are imminent that a Loss of two fission product barriers and loss or potential loss of third ( F G I ) is expected to occur prior to restoration of AC power to either 15AA or 16AB.

Applicability: 1, 2, 3 Differences:

None Deviations:

None s - 37

Grand Gulf Nuclear Station El Failure of the Reactor Protection System to Complete an Automatic Scram and Manual Scram was NOT Successful and There is Indication of an Extreme Challenge to the Ability to Cool the Core.

Applicability: Power Operation, Startup Grand GulC: SG2 Failure of the reactor protection system to complete an automatic scram and manual scram was not successful and there is indication of an extreme challenge to the ability to cool the core Applicability: 1, 2, Differences:

None Deviations:

None S - 38

Grand Gulf Nuclear Station El I: L ##I Indications exist that automatic and manual scram were not successful.

AND Either of the following: (a or b)

a. Indication(s) exists that the core cooling is extremely challenged.

OR

b. lndication(s) exists that heat removal is extremely challenged.

Applicability: Power Operations, Startup, Hot Shutdown Grand Gulf: SG2, EAL #I Automatic scram and manual failed to rapidly insert sufficient control rods to bring the reactor subcritical AND Either:

a. RPV parameters cannot be maintained within EP-2A limits or

b. RPV pressure and suppression pool temperature cannot be maintained in the HCTL Safe Zone Applicability: 1, 2, 3 Differences:

NEI SG2, EAL #I is implemented by Grand Gulf SG2, EAL #(Formatting I only)

Added to rapidly insert sufficient control rods to bring the reactor subcritical to quantify the successful scram criteria. The NEI bases states that if sufficient control rods are inserted to bring the reactor subcritical on a scram, the scram is considered successful.

Deviations:

None s - 39

GNRO-2003/00067, Proposed Upgraded Emergency Action Levels (Eals) Using NEI 99-01 Revision 4 Methodology-LDC 2003-093

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GNRO-2003/00067, Proposed Upgraded Emergency Action Levels (Eals) Using NEI 99-01 Revision 4 Methodology-LDC 2003-093

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