ML20138B568

Safety Evaluation Re Emergency Plan Change 28.001-95 to Entergy Operations,Inc,Grand Gulf Nuclear Station

ML20138B568
Person / Time
Site:	Grand Gulf
Issue date:	12/11/1996
From:	NRC (Affiliation Not Assigned)
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Shared Package
ML20138B564	List: ML20138B568
References
NUDOCS 9704290201
Download: ML20138B568 (6)

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NUCLEAR RE2ULATORY COMMISSION WASHINGTON, D.C. enmat anni SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMERGENCY PLAN CHANGE 28.001-95 ,

i ENTERGY OPERATIONS. INC.

GRAND GULF NUCLEAR STATION DOCKET NO. 50-416

1. BACKGROUND By letter dated June 30, 1995, Entergy Operations, Incorporated (the licensee) submitted Change Number 28.001-95 to the Grand Gulf Nuclear Station Emergency Plan. The change was submitted in accordance with the requirements of 10 CFR 50.54(q) on the basis that the licensee's evaluation concluded that the change does not decrease the effectiveness of the plan and the revised plan continues to meet the standards of Section 50.47(b) and the requirements of Appendix E. 1 Conference calls between Entergy Operations, Inc. and the Nuclear Regulatory Commission (NRC) occurred on June 12, 1996, and July 25, 1996, to discuss issues concerning this implemented change. The licensee submitted additional i information by letter dated August 9, 1996, to respond to questions raised by the staff. This safety evaluation (SE) is based on the Emergency Plan Change 28.001-95 submittal, the letter of August 9,1996, and the contents of the currently approved site emergency plan.

II. APPLICABLE REGULATIONS AND GUIDANCE 10 CFR 50.47(b)(2) ,

On-shift facility licensee responsibilities for emergency response are l unambiguously defined, adequate staffing to provide initial facility l accident response in key functional areas is maintained at all times, I timely augmentation of response capabilities is available and the (

interfaces among various onsite response activities and offsite support

. and response activities are specified.

10 CFR Part 50. Anoendix E. IV. Content of Emeroency Plans The applicant's emergency plans shall contain, but not necessarily be l limited to, information needed to demonstrate compliance with the i elements set forth below, i.e., organization for coping with radiation l l

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ENCLOSURE 9704290201 970424 PDR ADOCK 05000416 P PDR

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i emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, and recovery. In addition, the ,

emergency response plans submitted by an applicant for a nuclear power  !

i reactor operating licensa shall contain information needed to demonstrate i compliance with the standards described in 10 CFR 50.47(b), and they will l be evaluated against those standards.

l 10 CFR Part 50. Annendix E. IV. A. Ornanization

! The organization for coping with radiological emergencies shall be 2

descrind, including definition of authorities, responsibilities, and

' duties of individuals assigned to the licensee's emergency organization i and the means for notification of such individuals in the event of an j emergency.

l Reaulatory Guide 1.101 "Emeroency Plannina and Prenaredness for Nuclear Pont i

Reactors". C. Reaulatory Position i The cr'iteria and recommendations contained in Revision 1 of NUREG-0654/ FEMA-REP-1 are considered by the NRC staff to be acceptable methods l for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.

NUREG-0654/ FEMA-REP-1. Rev. 1. Criterion B. Onsite Emeraency Oraanization

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity.' For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, " Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency.

This espability shall be as indicated in Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980, letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1g82. (See Table B-1).

7. Each licensee shall specify the corporate man'agement, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled " Minimum Staffing Requirements for Nuclear Power Emergencies," (Table B-1) and in the following areas:

a. logistics support for saergency personnel, ...; .,

b. technical support for planning and reentry / recovery operations; l

c. management level interface with governmental authorities; and

d. release of information to news media during an emergency (coordination with governmental authorities).

NUREG-0737 Sunnlement No.1 " Clarification of TMI Action Plan Renuirements" Table 2, " Minimum Staffing Requirements for NRC Licensees for Nuclear i Power Plant Emergencies" (Note: Table 2 of NUREG-0737 is the same  !

information contained in Table B-1 of NUREG-0654. The requirements of l Supplement 1 of NUREG-0737 were issued to the industry by Generic Letter 82-33, which states that the staffing levels contained in Table 2 are only goals, and not strict requirements).

III. EVALUATION Before the licensee implemented Emergency Plan Change 28.001-95, Grand Gulf I i

Nuclear Station's (GGNS) staffing levels were in accordance with the minimum '

staffing guldance set forth in Table B-1 of NUREG-0654, " Minimum Staffing Requirements For NRC Licensees For Nuclear Power Plant Emergencies". However, after the licensee implemented Emergency Plan Change 28.001-95 by letter dated

.Nne 30, 1995, the GGNS staffing levels deviated from the minimum staffing guidance of NUREG-0654, Table B-1 for nuclear power plant emergencies. The emergency plan change upon which this SE is based increased the augmentation rqsponse time of the two health physics (HP) technicians responsible for rediation protection duties from 30 minutes following declaration of an Alert, Site Area Emergency, and General Emergency to 60 minutes. This change eliminated the 20 minute auga ntation commitment of the HP technicians and shifted these individuals to 60 minute responders. The onshift requirements are not affected.

l The licensee based its justification on three arguments:

i i 1. Electronic Alaming Dosimeters (EADs)

2. Radiation Work Pemits (RWP)

O. Area Radiation Monitors (ARMS)

Paragraph 8 of the submittal stated in part:

l "The use of electronic alaming dosimeters (EAD) coupled with Radiation

' Work Permits (RWP) has eliminated the need to have additional personnel to control access and issue dosimetry for personnel onshift and 30 minute

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responders. The EAD radiation dose and dose rate alams associated with

! the RWP are such that workers are precluded from exceeding radiation 1

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dose limits, but at the same time allow workers to carry out emergency actions. Workers self-issue EADs, eliminating the need for Health Physicists to physically issue dosimetry... Access control is maintained since the worker must enter a Radiation Work Pemit (RWP) number to be allowed access into the Radiologically Controlled Area (RCA).

...The EAD provides the. worker with integrated total dose and dose rate, and alams when either of these two have been exceeded... The use of EADs has reduced the need for Health Physics coverage for evolutions related to perfoming emergency or corrective actions to place the plant in a safe condition.

...Each of the major ESF rooms has Area Radiation Monitors (ARMS) with indication in the control room. These ARMS provide ALARM and DOSERATE functions. These functions provide an indication of radiological conditions and aid radiological personnel in making decisions related to personnel protection...Since this equipment is required and readily available for use, the need for HP coverage is minimal between time 0 and 60 minutes post event declaration".

In accordance with NUREG-0654, Table B-1, the major tasks for a technician responsible for radiation protection includes access control HP coverage for j plant entries, personnel monitoring, and dosimetry issuance, f: These four major tasks include the following activities:

l o Access Control - Establish boundaries; contamination control;

} evaluation of radiological air borne conditions; determine when

respirator protection is needed; determine the type of respirator

and the proper cartridge for radiological protection.

o HP coverage - Evaluate plant radiological conditions and issue RWPs for changing radiological conditions; evaluate radiation levels to j:

detemine if entry of a RCA is permissible; determine stay times for l

entry of a RCA; provide radiation protection coverage for teams

engaged in repair, corrective actions, search and rescue, first aid, and firefighting activities.

i o Personnel monitoring - Decontaminate of personnel contaminated with l radioactive particles or gases; deliver the proper medical attention l

to injured contaminated personnel; frisking personnel out of a controlled area.

o Dosimetry issuance - provide proper dosimeters for plant personnel.

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Staff Analysis During normal operating conditions, Electronic Alarming Dosimeters (EADs) coupled with Radiation Work Permits (RWP) are adequate for worker self-issuance. Since workers must enter an RWP number to be allowed access into the RCA, the EADs are sufficient for maintaining access control. Further, because of the computer system (Dositec) to which the EADs are connected, the workers' training qualifications and dose margins for each entry of the RCA is '

kept up-to-date and would preclude a worker from entering the RCA should training be inadequate or dose margins exceeded. Therefore, the dependence on the HP technician to perfom these two duties is reduced by the use of the EADs in conjunction with the RWP. However, for the duties of HP coverage and l personnel monitoring under emergency conditions, the use of the EADs does not 1

adequately provide for worker safety as does the HP technician, as explained i below.

During the early phases of an accident, radiation levels are usually not a 3

e major concern if the fuel clad barrier is still intact. However, as an accident progresses and the fuel clad barrier is breached, or where the j inventory of radioactive material in the RCS is released directly to the l

environment, radiation levels within the plant or the immediate area onsite i

may be a concern. Additionally, for emergencies that do not follow a core damage sequence, such as damage to spent fuel assemblies during handling or l accidents involving releases from onsite storage tanks, the release of i

radioactive material could conceivably be the initiating event. In these j

cases, HP technician escort for personnel entering high radiological areas i

will be necessary. l l Under such accident conditions, self-monitoring with EADs would likely not  !

1 l provide sufficient protection of worker health and safety. Rapidly changing l

direct radiation levels, coupled with a significant potential for releases o?

l airborne radioactive materials, mandate HP technician accompaniment of tear.s l conducting in-plant entries. An EAD would not adequately monitor the

radiological environment of the worker under these conditions. Further, the use of EADs for self-monitoring would necessitate set points for worker i

protection which would likely result in numerous aborted in-plant entries, thus rendering the licensee's response to the emergency less effective.

j Additionally, the on-shift HP technician positions for radiation protection

are'not dedicated positions, i.e., they may be filled by shift personnel assigned other duties. This can further reduce the quality of radiation j protection coverage for in-plant team entries.

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IV. CONCLUSIONS .

For the above stated reasons, the staff concludes that Emergency Plan Change 28.001-95 implemented by Entergy Operations, Inc. at the Grand Gulf Nuclear Plant decreases the effectiveness of the plan. The staff does not approve the change.

Principal Contributor: Narvaez Stinson Date: December 11. 1996 1

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