ML17283A153

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Attachment 1: Summary and Analysis of the GGNS Emergency Plan Changes, Revision 76
ML17283A153
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/03/2017
From:
Entergy Operations
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17283A150 List:
References
GNR0-2017/00062
Download: ML17283A153 (15)
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Text

Attachment 1 to GNR0-2017/00062 Summary and Analysis of the GGNS Emergency Plan Changes J

ATTACHMENT 9.2 10 CFR 50.54(a)(3) SCREENING SHEET1 OF9 Procedure/Document Number: Emergency Plan IRevisoon: 76 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

Emergency Plan Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs, EAL bases, etc. - refer to step 3.0[6]):

Non-Editorial Changes:

1. Page 9-1 Changed section 9.0 title from "Reentry and Recovery" to "Recovery."
2. Page 9-1 Removed section 9.1 "Reentry/Recovery" *
3. Page 9-1 Changed section 9.0, 1st sentence:~ In any Emergency, the immediate action is directed toward limiting the consequences of the incident, in a manner that affords the maximum protection to the plant personnel, and the general public."

To:

"In any declared Emergency, immediate actions are intended to limit consequences and provide maximum protection to plant personnel, the general public, and plant equipment."

4. Page 9-1 Changed section 9.0, 2nd sentence: "Once, the corrective and protective actions have been established an effective control over the situation, the emergency actions shifts into the reentry and the subsequent recovery phases during which all actions are planned and deliberate."

To:

"For a Site Area or General Emergency, once emergency phase corrective and protective actions have been implemented and effective controls established, emergency actions shift to the Recovery phase which includes reentry and recovery operations."

5. Page 9-1 Relocated paragraph 4 under 9.3 "Recovery" to section 9.0 paragraph 4 and changed it from:

"Recovery may be completed by the Emergency Organization before the termination of the emergency.

If recovery has not been accomplished by the termination of the emergency, a recovery organization is activated as described in Section 5.5. Its function is to safely and effectively place the plant back in a safe operating condition. Appropriate GGNS and outside assistance is mobilized to accomplish the objective.*

The Emergency Director is responsible for transmitting the notification that the incident is terminated and reentry/recovery may begin to those agencies connected to the GGNS Operational Hot Line (see Section 7.5.3.a.1)"

To:

"Recovery may be completed by the Emergency Organization before emergency termination. If recovery.

has not been accomplished by the termination of the emergency, a recovery organization is activated as described in Section 5.5. Its objective is to safely and effectively place the plant back in a safe operating condition or an acceptable long term condition. Appropriate GGNS and outside assistance is mobilized to accomplish this objective. The Emergency Director is responsible for transmitting a notification to those agencies connected to the GGNS Operational Hot Line (see Section 7.5.3.a.1) that the incident is terminated and the plant is transitioning to the Recovery phase."

EN-EP-305 REV 4

ATTACHMENT 9.2 10 CFR 50.54(Q)(3) SCREENING SHEET20F9 Procedure/Document Number: Emergency Plan I Revision: 76 Equipment/Facility/Other: Grand Gulf Nuclear Station*

Title:

Emergency Plan Non-Editorial Changes (continued):

6. Page 9-1 Relocated paragraph 7 under 9.3 "Recovery" to section 9.0 paragraph 5 and changed it from:

"Recovery operations are conducted in compliance with nonnal operational radiation exposure levels specified in 10CFR20. When possible, significant releases of radiation during recovery is planned, controlled, evaluated in advance for radiological impact; and appropriate offsite organizations and agencies informed of the scheduled release and estimated impact. Emergency Plan Procedures provide methods of periodically estimating total population exposure."

To:

"Recovery is conducted in compliance with normal occupational dose limits specified in 10CFR20.

Significant releases of radioactive materials during recovery is planned, controlled~ and evaluated in advance for radlologlcal Impact, and appropriate offsite organizations and agencies informed of the scheduled release and estimated impact Emergency Plan Procedures provide methods of periodically estimating total population exposure."

7. Page 9-2 Relocated section 9.3 "Recovery" to the changed section 9.1 wRecovery Operations"
8. Page 9-2 Added the sentence "More detailed information is provided in Emergency Plan procedures." to the end of the first paragraph in section 9.1, Recovery Operations.
9. Page 9-2 Section 9.1, second paragraph: Changed ~ ... recovery programs .. ." to" recovery operations".
10. Page 9-1 Changed section 9.2 "Reentry" to section 9.2 "Reentry Operations."

1i. General- Procedure 10-S-01-22, Recovery, witl be deleted and superseded by EN-EP-613, "Recovery from Declared Emergencies" at the same time this revision is issued.

Editorial Changes:

12. Pages 1,3,4 List of Effective Pages 1,3,4. Revised to update. revision numbers for pages changed.
13. Page TOC vii 9.0 Change wording from "Reentry and Recovery" to "Recovery". 9.1 Change wording from "Recovery" to "Recovery Operations". 9.2 Change wording from "Reentry" to "Reentry Operations". 9.3 Delete "Recovery". TOC ii, 5.4.8, corrected misspelling of "Offsite".
14. Page 3-1a, section 3.2.h, Change Re-entry and Recovery to Recovery.
15. Page 9-1, section 9.0 first paragraph: Corrected subject/object/verb position to make the sentences clearer and more grammatically correct and less likely to be misinterpreted.
16. Page 9-1,9-2, 9-3, Removed unnecessary use of "the". Removed unnecessary prepositional phrases.

Slmplified tenses.

17. Page 9-1, Section 9.0.b Changed "... release of radiation ... " to * ... release of radioactive materials ... "
18. Page 9-1, section 9.0 Third paragraph: Replaced " ... before the ... " with "prior".
19. Page 9-1, Section 9.0, paragraph 5 Changed " ... release of radiation.;." to "... release of radioactive materials ... "
20. Page 9-2, Section 9.1, second paragraph: Removed "... as required ... ". Replaced "... investigation ... "

with "... assessment..."

EN-EP-305 REV 4

ATTACHMENT 9.2 10 CFR 50.54(0)(3) SCREENING SHEET30F9 Procedure/Document Number: Emergency Plan I Revision: 76 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

Emergency Pfan Editorial Changes (continued}:

21. Page 9-2, Section 9.1, second paragraph: Changed "A systematic investigation is conducted* to determine the equipment that has been damaged and the extent of the damage to plant equipment."

To:

"A systematic assessment is conducted to detennine the extent of damage to plant equipment."

22. Page 9-2, Section 9.1, third paragraph, second sentence - Replaced "Determinations are made as to the repair work required to perform necessary modifications to plant equipment and/or operating procedures.

Repair work and approved modifications are carried out as authorized~ Test programs to confirm fitness for return to services are to be developed and executed."

To:

~Repair work and modifications to plant equipment and/or changes to operating procedures are determined, approved , and performed;. Test programs to confirm fitness for return to services are

. developed and implemented."

23. Page 9-3, Section 9.2, Reentry Operations: Changed terminology to more accurately define conditions. Removed vague and ambiguous adverbs and adjectives.
24. Page A-11f Changed the following reference to section 9.1: Remove reference to "10-S-01-22", and *

"10~S-01-23", and "EN-EP-609, and replaced with "EN;.EP-613". Replace"Reentry/Recovery"with "Recovery";

Changed the following references to section 9.2: Remove reference to "EN-EP-609", and replace with "EN-EP-613u. Replaced "Reentry" with "Recovery Operations".

Remove reference to section 9.3 and all associated references.

25. Page A-14, Replaced reference to procedure "10-S-01-22" and replaced with "EN-EP-613". Replace "Recoveryn with "Reentry Operations".
26. Page A-14, Modified the description of 10-S-01-23, Reentry from:." This procedure provides general guidance for the Reentry phase of on emergency."

To:

"This procedure provides general guidance for Reentry operations.~*

27. Page G-19, Changed the cross.reference sections for NUREG 0654 M.3., and M.4 from GGNS E-Plan section "9.3" to "9.0".

EN-EP-305 REV 4

ATTACHMENT 9.2

  • 10 CfR 50.54(Q)(3) SCREENING SHEET40F9
  • Procedure/Document Number: Emergency Plan*
  • I Revision: 76 ***

EquipmenUFacmtylOther: Grand Gulf Nuclear Station* .

Title:

Emergency Plan **

Part II. Activity Previously Reviewed? DYES [81 NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation Is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

0 Bounding document attached (optional)

Part m. Applicability of Other Regulatory Change Control Processes.

Check if any other regulatmy change processes control the proposed activily.{Refe:r to EN-Ll-100)

APIPllCABILITY CONCllJSION 181 If there are no other controlling change processes; continue the 50.54(q)(3) Screening; .

0 One or more controlling change processes are selected, however, some portion of the activity involves the *.

emergency plan or affects the implementation of1he emergency plan; continue the50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below*.

0 One or more controlling change processes are seleCted and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT re uired. lclenti controllin chan e rocesses below and com lete Part Vt 10CFR50.54 (q)

Part IV. Editorial Ctumge 0YEs* NO S0.54(q)(3)

  • Is this activity an editorial or typographical change such as formatting, paragraph
  • Evaluation is **

numbering, spelling, or. punctuation that does not change intent?* NOT required.

Justification: Enter justi!icntion !llld The following changes are edilorfal changes per EN-AD-101. No Is checked at right continue to next because the remaining changes are non-editorial. part or complete Pnrt VI as

12. Pages 1,3,4 List of Effective Pages 1;3,4. Revised to update revision applicable,.

numbers for pages changed.

13. Page TOC vii 9.0 Change wording from "Reentry and Recovery" to .

"Recovery". 9:1 Change wording from "Recovery" to "Recovery Operations". 9.2 Change wording from ~Reentry" to "Reentry Operations"~

9.3 Delete "Recovery". TOC ii, 5.4.8, corrected misspelling of "Offsite".

14. Page 3-1a, section3.2.h,Change Re-entry and Recovery to Recovery;.
  • 15, Page 9-1 First paragraph: Corrected subject/object/verb position to make the sentences clearer and more grammatically correct and less likely to be misinterpreted. *
16. Page 9-1,9-21 9-3 Removed unnecessary use of "then. Removed unnecessa re ositional hrases. Sim lified tenses; EN-EP,;.305 REV 4

A1TACHMENT9.2 *.. . 10 CFR 50.54(Q)(3) SCREENING SHEeT50F9 Procedum/Docum1rmt Number: Emergency Plan I Revision: 76 Equipment/Facility/Other. Grand .Gulf Nuclear Station.

Title:

Emergency Plan *

  • Part IV. Editorial Change (continued)
17. Page 9-1, Section 9.0.b Changed " ... release of radiation ...
  • to " ... release of radioactive materials ... "

i8. Page 9-1, Third paragraph: Replaced " ... before the ... " with "prior".

19. Page 9-1, Section 9.1, paragraph 5 Changed " ... release of radiation ... " to I*

"... release of radioactive materials.. :

20. Page 9-2, Section 9.1. second paragraph: Removed "... as required ... ".

Replaced ".. .investigation ... " with "... assessment..*

21. Page 9-2, Section 9.1, second paragraph: Changed "A systematic investigation is conducted to determine the equipment that has been damaged and the extent of the damage to plant equipment" To:

"A systematic assessment is conducted to determine the extent of damage to plant equipment" I1

(

22. Page 9-2, Section 9. 1, third paragraph, second sentence - Replaced I "Determinations are made as to the repair work required to perform l
  • necessary modifications to plant equipment and/or operating procedures.

Repair work and approved modifications are carried out as authorized. Test programs to confinn fitness for return to services are to be developed and . I I

executed." I To:

"Repair work and modifications to plant equipment and/or changes to I

operating procedures are determined, approved , and performed. Test  :~

i programs to confirm fitness for return to services are developed and 1

implemented."

j 23.

1 j

Page 9-3, Section 9.2, Reentry Operations: Changed terminology to more accurately define conditions. Removed vague and ambiguous adverbs and adjectives.

II 124. Page A-11, Changed the following reference to section 9.1: Remove 'f.

, reference to "10-S-01-22", and "10-S-01-23", and "EN-EP-609", and I l replace with HEN-EP-613". Replace "Reentry/Recovery* with "Recovery".

l Changed the following references to section 9.2: Remove reference to "EN-EP-609", and replace with "EN-EP-613". Replace "Reentry" with "Recovery Operations".

Remove reference to section 9.3 and all associated references. *

25. Page A-14, Page A-14, Replaced reference to procedure "10-S-01-22" and replace with "EN-EP-613". Replace "Recovery" with "Reentry Operations.
26. Page A-14, Modified the description of 10-S-01-23, Reentry from:" This procedure provides general guidance for the Reentry phase of on emergency."

To:

"This rocedure rovides eneral uidance for Reent o erations."

EN-EP-305 REV 4

. ATTACHMENT 9.2 10 CFR 50.54(Q)(3) SCREENING * ....

  • SHeET60F9 Procedure/Docum~nt Number: Emergency Plan * **** I.Revision: 76 **

Equipment/Facility/Other:* Grand Gulf Nuclear Station**.

Title:

Emergency Plan **

  • 27; PageG~1s.*changed.the*crossreference sections forNUREG.0654 M.3.,.**

and M.4 from*. GGNS E-Plan section "9.3" to "9.0#::

  • v.

Part Emergency Planning Element/Fum::tion Screen (Associated 10 CFR 50.47(b) planning standard function ..

identified in brackets) Does this activity affect any of the following,. including. program elements frcim NU REG~

0654/FEMAREP~t Section II? . . .. 1 .

L Responsibility for emergency r~sponse is assigned. [tl ** O

  • . 2. The response organization* Ms: ttie staff to respond and to* augment staff on a continuing basis (24f7 . ... O. I
  • staffing) in accordance with the emergency plan;[1] : *** * . . .. .. * * * *
3. The process eosures thaton shift emergency response responsibilities are staffed*and assigne<l [21 ***o 4; *The process for timely augmentation of onshift staff is established and maintained. {21 **

0

  • 5. Arrangements for requesting and using off site*assistance have been made;[3]
  • 6;
  • State and local staff can be accommodated at the EOF in accordancewith*the emergency plan. [3] **
  • O. *

. 7, A. standard scheme of emergency c!assification and action levels.is in use. [4]

  • O
  • S; .Procedures for notification of State and local g9vemmental agencies are capable of alerting them. of .. * .. D the: declared emergency within 15 minutes after declaration of an emergency and providing follow~

up notificaticms. [5] * .* * * **

9. Administrative and physical means have been established for alerting and providing prompt *
  • instructions to the public within the plume exposure pathway. [5] ***

o*

1o. The public ANS meets the design requirements of FEMA~REP~10, Guide for Evaluation of.Alert.and U ...

Notifi_catlon SyS.tems*for.Nuclear Pqw~r plants, or complies *with *the licen*see's* FEMA~app~oved *ANS:* :,

design report and sup!Joiiing FEMA approval letter. [5] *

  • I
  • 1 L Systems are established for prompt communication among principal emergency response *
  • u organizations. (6) * * ** ** * * * *
  • 12; Systems are established for prompt communication to emergencyresponse personnel.*(6] D

. 1. 3: *Emergency preparedness information is made available to the public on a periodic. basis within the ::* **u.

plume exposure pathway emergency planning zone (EPZ); [7]

14. Coordinated dissemination of public information during emergencies is emablfshed. [7] *u

,15:. Adequate facilities are maintained* to support emergency response. [6]. O**

16. Adequate equipment Is maintained to support emergency response. [8] u

.17; Methods, systems; and equipmenUor assessment of radioactive releases. are in use. {9) u.

18. A range of public PARs is available for implementation during emergencies. [1 OJ* ..
19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are
  • U ..*
  • available to support the formulation of PARs ahd have been provided to State and local**

governmental authorities. (1 OJ .* *

20. A range of protective actions Is available for plant emergency workers during emergencies, including those for hostile action events.[1 OJ ** ,*
  • EN-EP~305 REV 4 I

v****

ATTACHMENT 9.2 10 CFf? 50.54(Q)(3) SCREENING _

. SHEET.7 OF 9 Procedure/Document Number: Emergency Plan I Revision: 76 Equlpmentlfacmty/Other: Grand Gulf Nuclear Station

Title:

Emergency Phm

21. The resources for controlling radiological exposures for emergency workers are established. [11] u
22. Arrangements are made for medical services for contaminated, injured individuals; [12]
  • D
23. Plans for recovery and reentry are developed. [131 ~
24. A drill and exercise program (including radiological, medical, health physics and other program u areas) is established. [14]
25. Drills; exercises, and training evolutions that provide performance opportunities to develop, lJ maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. (14]
26. Identified weaknesses are corrected. [14] u Training is provided to emergency responders. (15] u
28. Responsibility for emergency plan development and review is established. [16] u
29. Planners responsible for emergency plan development and maintenance are properly trained. [16) D APPLICABILITY CONCUJSION D If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

ii If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation; BASIS FOR CONCLUSION

  • The following items do not require a 50.54(q) evaluation and the basis is provided:
3. Page 9-1 Changed section 9.0, 1st sentence:
  • In an}! Emergenc!l, the immediate action is directed toward limiting the conseguences of the incident, in a manner that affords the maximum* grotection to the i;ilant 12ersonnel; and the general QUblic."

To:

"In any declared Emergency, immediate actioas are intended to limit conseguences and provide maximum protection to plant personnel. the general public. and plant equipment."

The sentence was simplified grammatically and plant equipment was added to the end of the sentence..

Protecting plant equipment is important since certain system can be used to mitigate consequences of*

the event, either by minimizing a release or minimizing further damage to fission product barriers.

Inclusion of plant equipment does not affect any of the planning standards in 10CFR50.47 (b), the requirements in 10 CFR 50 Appendix E, or the program elements in NUREG 0654. No further evaluation is required for this change.

5; Page 9-1 Relocated *Qaragragh 4 under 9.3 "Recoveot to section 9.0 12aragragh 4 and changed it from:

"Recovery ma:t be comQleted bl! the Emergenc~ Organization before the termination of the emergencl!.

If recovery has not been accomi;ilished b~ the termination of the em erg enc~. a recovery organization is activated as described in Section 5.5. Its function is to safel}! and effectivel)l glace the (;llant back in a safe ogerating condition. Aeerogriate GGNS and outside assistance is mobilized to accomglish the objective. The Emergengy Director is resgonsible for transmitting the notification that the incident is.

  • terminated and reent!)/recovery mall begin to those agencies connected to the GGNS OQerational Hot Line (see Section 7.5.3.a.1 )" /

To:

"RecoveOl ma~ be com[;!leted b~ the Emergengy Organization before emergenc:l termination. If recovery has not been accomQlished b'.ll the termination of the emergenc~, a recove!)! organization is activated as described in Section 5.5. Its objective is to safe!)'. and effective!)! Qlace the giant back in a safe 012erating condition or an accegtable long term condition. A12i;iro12riate GGNS and outside assistance is mobilized to accomolish this obiective. The Emeraencv Director is resoonsible for

ATTACHMENT9.2 10 CFR 50.54(0)(3) SCREENING Procedure!Oocument Number.: Emergency Plan I Revision: 76 Equipment/Faciiity/Other: Grand Gulf NucCear Statio11 TitBe: Emergency Plan transmitting a notification to those agencies connected to the GGNS Operational Hot Line (see Section 7.5.3.a.1) that the incident is terminated and the plant is transitioning to the Recovery phase." 7.5~3.a.1) that the incident is terminated and the plant is transitioning to the RecovelY phase..:

The sentence was simplified grammatically, and "... or acceptable long term condition." was added to the end of the 3n1 sentence. The prior sentence assumed that the plant could be place back into a safe operating condition. This may not be achievable and an alternative would be to place the plant into an acceptable long term condition, Inclusion of the alternative statement does not affect any of the planning standards in 10CFR50.47 (b), the requirements in 10 CFR 50 Appendix E, or the program elements in NUREG 0654. No further evaluation is required for this change. *

6. Page 9-1 Relocated paragraph 7 under 9.3 "Recovery" to section 9.012aragraph 5 and changed itfrom:

"Recovery operations are conducted in compliance with normal operational radiation exposure levels. . .

specified in 10CFR20. When possible. significant releases of radiation during rec:ove[!{ is planned.

controlled. evaluated in advance for radiological impact. and appropriate offsite organizations and agencies informed of the scheduled release and estimated impact Emergency Plan Procedures provide methods of periodically estimating total population exposure."

To:

~coveiy Is conducted in compliance with normal occupational dose limits specified in 10CFR20..

Significant releases of radioactive materials during recovery is planned, controlled. and evaluated in advance ..

for radiological impact. and appropriate offsite organizations and agencies informed of the scheduled release and estimated impact Emergency Plan Procedures provide methods of periodically estimating total population exposure.".

  • Changed wording in the first sentence to correct its meaning." ... normal operational radiation exposure levels .. ." are radiation levels encountered in the plant during normal operations. These are not specified in 10 CFR 20. Replaced with *... normal occupational dose limits ... ", which are included in 10 CFR 20~

Changed wording In the second sentence from "*.. release of radiation ... " to "... release of radioactive material". Radiation is always being released from the atom or nucleus; Neither of these changes affect any of the planning standards in 10CFR50.47 (b), the requirements in 10 CFR 50 Appendix E, orthe program elements in NU.REG 0654 .. No further evaluation is required for this change. *

  • 11.Gem:ffal- Procedure 10-S-01-22, Recoverv. will be deleted and superseded bv EN-EP-013; "Recovery from Declared Emergencies" at the same time this revision Is Issued.

This change is listed as part ofeditorial changes in section A-14 and A-16. Supersedence ofthe older procedure by the newer one requires a 50.54(q) review be performed on the new procedure. The review is performed separately and not in this document.

EN-EP-305 REV 4

~-,.,.~-----,,,,,,,.-*~.,,.,.,..._ ,.,,,.,,..g,,~~7l.~:%it' i'.:<Wll'* '. I!'

ft.TTACHMENT9.2 10 CFR 50.54(CJ)(3) SC!llEENING

~SHEETS OF,9 w " "" . "**-****

edtm.111Joe\Om11mt Number. Emergency Plain . *. I RevlsltJn: 76 EquipmentlfacUU:y/Other: Grand Gulf Nuclear Stamm

Title:

Emergency Pian

  • SAS!S fOR CONCLUSION Non*edltorial changes requiring a 50.54(q) evaluation.

The following changes in part or collectively affect the emergency planning standard i 3 listed in Part Vof *

!his form:

1. Page 9~1 Changed section 9.0 title from "Reentrv and Recovery" lo "Recovery."
2. Page 9°1 Removed section ~.1 -Reentry/Recovery"
4. Page !M Qhangecl sec.;tlon 9.0. 2nd sentence: uonce the correc:Uve and proteqtiw actions have tpgu\'!n esl:ablishjd an effective control over the situatkm, the emergency actions §hlfts into the reentry and the subseguent recovefl: ghiSH during whi£h all actions are planned and deliberate."

To:

'.'E.or a Site Area or General Emergency, oncem §!mergeney phase correctlvs;i and i:m:;itep!lve actions have taen implemented and effective controls esrab!ished, emergency ectigns shift to the Recovery phase .

which lm::ludes reent!'.Y and recgvery operations,"

7. P2ge 9*2 Relocated section 9.3 "Recover/' to the changer.! section 9.1 "Recovery Ogerat!ons" El. f?age 9-2 Added tlie sentem;;a "More detailed l11formatlon !s provided in Emergern::y Plan procedures." to the end of the first Qaragraph in section 9.1, Reco11e1Y Operations;
9. Page 9-2 Segt!on*9.1. second paragraph: Changed K *** rncoyerv programs,,." to" recovery opera!lons",

10.Page 9-3 Relocated section 9.3 "Reentry" to section H9.2 and ren!j!med lhe ~me "Reentry Og§raticms."

The changes remove "Reentry" as a separate phase that is performed prior to recovery and makes it subordinate to the "Recovery phase*. Under the "Recovery phase", "Recovery Operations~ and "Reenlry Operaticms* are perfomiecl.

  • A 10CFR50.54 (q) evaluation will bErperformed to determine whether ornotthe effec&iveness ofthe *
  • emergency phm is reduced and prior NRC approval is required.

Part VI. Signab.llres:

Preparer Name (Print} Dale:

Paul Sudnak tli.1117 .

Reviewer Name {Print) .Dale:

David Townsend Nuclear EP Project Manager 62./z.1 /;?

Approver Name (Prlnl) Approver Signature Date:

Jeff Seiter Manager, Emer9ency Planning or deslgnee 6/i1//7 EN-EP-305 REV 4

  • ATTACHMENT 9.3. 1o CFR 50.54(a)(3) EvA1..uAr10N .

SHEET1 OF4 Procech.m~IDocument Number: Emergency Plan I Rev!slon:16 Equipmeni/f'acmcy/Other: Grand Gulf Nuclear Station

Title:

Grand Gulf Nuclear Station Emergency Plan Part I. Description of Proposed Change: .

The numbering used below corresponds lo the descriptions listed In attachment 9.2, 10 CFR50;54(q){2) Screening.

1. Page 9-1 Changed section 9,0 title from "Reentry and Recoveryi* to "Recovery."
2. Page 9-1' Removed section 9.1 "Reentry/Recovery~

4, Page 9-1 Changed section 9.0, 2nd sentence: ~once the corrective and protective actions have been established an effective control over the situation, the emergency actions shifts into the reentry and the subsequent recovery phases during which all actions are planned and deliberate."

To:

UFor a Site Area or General Emergency, once emergency phase corrective and protective actions have.

been implemented and effective controls establishedi emergency actions shift to the Recovery phase**

which includes reentry and recovery operations."

7. Page 9-2 Relocated section 9.3 "Recovery to the changed section 9. 1 "Recovery Operations" 8, Page.9-2Added the sentence uMore detailed infonnation is provided in Emergency Plan procedures." to the end of the first paragraph in section 9.1, Recovery Operations.
9. Page 9-2 Section 9, 1, second paragraph: Changed "... recovery programs.;." to " recovery operationsn~

10.Page 9-3 Relocated section 9.3 "Reentry" to section. 9.2 and renamed the title "Reentry Operations:

The changes remove "Reentry" as a separate phase that is performed prior to recovery and makes it subordinate to the "Recovery phase". Under the "Recovery phase~. uRecovery Operations" and "Reentry*

Operations" are performed.

Part II. Description ;;md Review of licensing BHis Affected by the Proposed Change:

Perfonned electronic search of the GGNS Emergency Plan section 9.0, Reentry and Recovery, 9.1 Reentry/Recovery, 9:2, Reentry, Appendix G; page G-4, NUREG-0654 Cross Reference B. 7, Appendix G, page G-19, NU REG 0654 Cross Reference M, M~ 1, M.2, M.3,

  • Revision 1 of the Emergency Plan was reviewed for the original approved text used to describe Reentry and Recovery. With the exception of the following revision changes, all other changes were editorial or error corrections.
  • Rev 75, section 9.0: This revision removed Site or General Emergency from the first sentence and resulted .

in immediate actions applying to all emergencies. The first sentence is a generic statement, and does not contain any commitments or implement any regulations.

Rev 61, section 9.3: This revision changed the name from the Emergency Director/Off-site Emergency Coordinator to the Emergency Director. This was a simple name change, did not change responsibilities and obligations, and consolidated Fleet wide naming convention.

Rev 61, section 9.3: This revision added the 3rc1 paragraph: "The Emergency Director discusses existing offsite condWons with appropriate State officials prior to terminating a Site Area Emergency or General Emergency classification." This change was evaluated and determined that there were no effects on the GGNS Emergency Plan.

  • Revision 1 of the Plan approved by the NRC, established the licensing basis for the GGNS Emergency Plan, It, along with the changes in revision 61 and 75, and the changes in revision 76 were considered in their entirety.

EN-EP-305 REV 4

ATTACHMENT 9;3 10 CFR S0.54(Q)(3) EVALUATION ..

SHEET20F4 Procedure/Document Number: Emergency Pian I Revision:76 Equlpment/Facmty/Other: Grand Guff Nuclear Station .

Title:

Grand Gulf Nuclear Statlc:m Emergency Plan

  • Part m. Describe How the Proposed Change Complies with Relevant Emergency Preparedmass .
  • Regulation(s) am:I Previous .Commitment(s) Made to the NRC:

10CFR 50:47 (b)(13l General plans forrecovery and reentry are developed; Site CoroR!iance: Through implementation of this revision; the commitment to comply with the planning

. standards provided in 10 CFR 50.47: (b)(13) remains; and the requirement for Reentry and Recovery plans remains in the GGNS Emergency Plan; 10 CFR 50 Appendix E. IV. H. Recovery Criteria to be used to determine when, following an accident; ...

reentry of the facility would be appropriate orwhen operation could be resumed shall be described; Site Compliance: Through implementation of this *revision; the commitment to comply with the.**

regulations provided in 10 CFR 50 Appendix E; IV. H; Recovery remains; and Reentry and Recovery criteria are established and remain in the GGNS Emergency Plan.

  • Previous NRC commitments* licensing Research System*(LRS)\13.0a was used to search fOr potential****
  • NRC commitment changes as a result of the GGNS Emergency Plan change: There were no identified conflicts with the plan changes and the current NRC commitments. All current NRC commitments that relate to Reentry and Recovery continue to be maintained and fulfilled with this plan change.

ATIACHMENT 9.3 10 CfR50.54(Q)(3) EVALUATION SHEET30F4 ProcedurelOocument Number: Emergency Plan* *I Revision:76 . * '

Equipmentlfacility/Other: Grand Gulf Nuclear Station

Title:

Grand Gulf Nuclear Station Emergency Phm Part iV. Description of Emergency Plan Planning Stillndards, Functions and Program Elements Affected by the Proposed Change: * *

  • Plans for recovery and reentry are developed, Sections IV.H. of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergenc31Plan functions:

The change incorporates both Reentry Operaticms and Recovery Operations under the Recovery phase.

  • During Recovery Operations, plans are established to identify equipment to be .repaired,. replaced, or*

returned to service.. Priorities are assigned to equipment and systems yielding the highest value to meet*.

Recovery objectives, Personnel are assigned to the Recovery organization based on planned Recovery

  • efforts, priorities; and objectives; .

For initial Reentry Operations, area hazards are assessed and evaluated. These assessments, including radiation s1.11veys, are perfomied in areas associated with critical systems and equipment which have been identified in the Recovery plan as necessary to support Recovery Operations.

  • The current revision of the GGNS Emergency Plan separates the Reentry phase fi-om the Recovery phase and describes the Recovery phase as being entered subsequent to the Reentry phase. In reality; initial Recovery plans would include Reentry into areas with equipment and systems needed for further stabilizing the plant and establishing additional levels of control. Based on reentry surveys and assessments, Recovery .

plans may be modified based on significant hazards or impediments in areas identified as critical for

  • Recovery. A reiterative process is likely based on results of ongoing plant hazards assessments and Recovery planning; .

A flexible and reiterative process cannot be implemented if elements of the process are predefined, distinct,

. and sequential.

For this reason, it is logical and prudent to perform both reentry and recovery planning and certain aspects

  • of Reentry and Recovery operations at the same time. This allows modifying plans based on ongoing assessments of plant conditions.

Aside from the benefit of incorporating both Recovery and Reentry Operations into the Recovery phase; the elements of both Reentry and Recovery ofthe prior revision rem.ain in this revision; **

  • Since Reentry Operations and Recovery Operations elements essentially remain the same with no adverse impact on either Reentry or Recovery, the change and clarification to section 9.0 is not considered a reduction in effectiveness.

The proposed changes to the GGNS emergency plan continue to meet the planning standards outlined in* 1O

. CFR 50.47(b)(14).The effectiveness of the emergency plan is not reduced. The emergency plan changes .

  • can be incorporated without prior NRC approval.

Part VI. Eva!uatlcm Conclusion Answ1H' the following qMe~tlons about the pl'oposed change*. :

Does the proposed change comply.with 10 CFR50.47(b)and 10 CFR 50 Appendix E? >

  • 121vcsONo,
t Does the proposed change maintain the effectiveness of the.emergency plan (i;e., no

. 181YES 0 *No reduction in effectiveness)?

J. Does the pn::iposed t::hange constitute an emergency action level scheme change? ..

  • f&I NO If questions 1 or 2 are answered NO; or question 3 answered YES, rejecUhe proposed change, modify the **

proposed change and perform a new evaluation or obtain prior NRC approval under provisions oMO CFR 5Ct90; If questions 1 and 2 are answered YES, and question 3.answered NO, Implement applicable change process{es), Refer.to step 5;8(8);

Preparer Name {Print) ** 01'.lle;.

Paul Sudnak. *** 1:. l 11 Reviewer Name (Prinl}

David TOwnsend Nuclear EP Project Manager

  • Approver Name (Print) Approver Signature . Date:

Attachment 2 to GNR0-2017/00062 Grand Gulf Nuclear Station Emergency Plan, Revision 76

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