ML20141H366

Summary of 970710 Meeting W/Util to Discuss Licensee Emergency Plan Change 28.001-95 & to Determine If Change Reduces Effectiveness of Emergency Plan for Plant,Unit 1. List of Attendees,Agenda & Info Provided by Licensee Encl

ML20141H366
Person / Time
Site:	Grand Gulf
Issue date:	07/17/1997
From:	NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9707230034
Download: ML20141H366 (44)

Text

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i j *W4 I l n g\ UNITED STATES j

! [ NUCLEAR REGULATORY COMMISSION l  ? t WASHINGTON, D.C. 20066-0001

\*****/ July 17,1997 i l

LICENSEE: ENTERGY OPERATIONS, INC.

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FACILITY: Grand Gulf Nuclear Station, Unit 1(

SUBJECT:

HEETING ON EMERGENCY PLAN CHANGE 28.001-95 FOR GRAND GULF NUCLEAR STATION, UNIT 1 i

A meeting was held on Thursday, July 10, 1997, between the Nuclear Regulatory Commission (NRC) staff and the licensee to discuss the licensee's Emergency Plan change 28.001-95 and to determine if the change reduces the effectiveness of the emergency plan for Grand Gulf Nuclear Station, Unit 1 (GGNS). The i notice for the meeting was issued on June 27, 1997.

Attachment 1 is the list of attendees, Attachment 2 is the agenda for the meeting, and Attachment 3 is information provided by the licensee at the meeting. The staff did not hand out any information at the meeting.

Attachment 4 is the Safety Evaluation dated December 11, 1996, issued by the l staff on the plan change in its letter of April 24, 1997.

BACKGROUND:

The licensee requested this meeting to appeal the NRC staff's decision, in the letter of April 24, 1997, that the Plan change did not meet 10 CFR 50.54(q) in that it reduced the effectiveness of the plan and, therefore, could not be implemented without prior staff approval. The plan change, revision 28.001-95, to change the response time of two health physics technicians response time from 30 to 60 minutes for an emergency preparedness (EP) event, was submitted to NRC in the licensee's letter of June 30, 1995.

The of thestaff's decision plan was as to in documented the effect Evaluation a Safety of the plandated change on the11, December effectiveness 1996. }/

This Safety Evaluation was issued to the licensee in the letter of April 24, /j 1997. This letter provided the staff's Safety Evaluation on 50.54(q) and addressed the phone call of April 14, 1997, in yhich the licensee and the f)$

staff discussed the staff's determination as to 50.54(q) and the licensee /

provided. clarification pertaining to shift health physics staffing levels and the then-new (i.e., June 1995) electronic alarming dosimeters to reduce tasks for the health physics staff at the site in the early part of an EP event. In the April 24, 1997, letter, the staff concluded that the new information, provided by the licensee in the April 14th phone conference call, did not change the staff's determination that the plan change reduced the i effectiveness of the plan.

The licensee requested this meeting in its letter of May 22, 1997. In the letter, the licensee also addressed the staff's Safety Evaluation to demonstrate that the plan change should not be considered a reduction in the effectiveness of the plan.

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9707230034 970717 DR ADOCK 050004 6

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In reviewing the documentation on this plan change in preparing for this meeting, the staff concluded that the discussion in the April 14, 1997, on the shift health physics staffing levels, which included a discussion on Table 5-1, " Shift Staffing and Augmentation Capabilities," and the health phnics staffing on-shift, at 30 minutes, and at 60 minutes into' an EP event, 1,'oit ated that the numbers given in the table for the functional areas may not be the actual number of individuals available for those areas because the same individual may be used for several functional areas. Because this indication did affect the staff's decision on the plan change reducing the effectiveness of the plan and was not clearly articulated in the staff's letter of April 24, 1997, the staff had a telephone conference call with the licensee on July 8, 1997, to explain this indication and to request that the licensee discuss the numbers in Table 5-1 for health physics staffing up to 60 minutes into the EP event. The licensee agreed to do this.

The individuals in the Office of Nuclear Reactor Regulation, NRC, to' hear the appeal were Mr. Seymour H. Weiss, Acting Deputy Director of the Division of Reactor Program Management (DRPM) and Mr. Jack W. Ros, Director, Division of Reactor Projects (DRPW). The technical branch that reviewed the licensee's plan change is within DRPM.

The staff presented the above background in its opening remarks. The licensee stated that it agreed with this background and stated that it instituted compensatory measures when it received the staff's letter of April 24, 1997.

The licensee's slides on the Background and Compensatory Measures are pages 3 and 4 of Attachment 3.

MEETING

SUMMARY

The agenda for the meeting is Attachment 2.

The outline of the licensee's presentation is page 2 of Attachment 3. The licensee explained what they had changed in the plan (pages 5 and 6) and its basis that the change did not reduce the effectiveness of the plan (pages 8 through 11).

The licensee changed the order of its presentation to discuss Table 5-1 of the .

plan which documents the shift staffing and augmentation capabilities of the Emergency Plan for GGNS. The slides are the last 5 pages of Attachment 3 and  ;

includes a pictorial representation of plan change 28.001-95 by arrows and .

Table B-1, " Minimum Staffing Requirements for Nuclear Power Plant 1 Emergencies," which was issued by the staff in NUREG-0654. The licensee stated that a procedure had been written to show which of the number of individuals listed in Table 5-1 did which tasks because Table 5-1 represented tasks that may be done by several individuals. The slide for health physics manning (HP Manning) is for the following tasks: radiation protection (RP),

inplant survey (IP), and onsite monitoring (DM). These tasks are broken down among the 8 individuals which come in at different times following the event. )

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u l The basis for the licensee's contention that the plan change did not reduce the effectiveness of the plan is that it instituted improvements in processes and equipment to reduce the work needed to be done by the 2 HP technicians which arrive at the site 30 minutes after the event. The licensee discussed the old and new processes and equipment for HP technicians in pages 13 through a 30 of Attachment 3.

1

! The staff discussed the numbers listed in Table 5-1 of the plan for GGNS for HP staffing in an event, and the changes in the processes and equipment for the HP technicians presented by the licensee.

i Attachment 4 is the staff's Safety Evaluation dated December 11, 1996, on the plan change which concludes that the change does not meets the criteria of-10 CFR 50.54(q) and should not have been implemented without prior staff i approval.

The staff caucused to consider the presentation and appeal by the licensee,

.j and then reconvened the meeting.  ;

1 The appeal board stated that the licensee had adequately addressed the issues l i raised in the Safety Evaluation dated December 11, 1996; however, the licensee l had not adequately addressed the questions con'cerning Table 5-1 and the l

^ staffing'for EP events at GGNS. Because there is a question of whether the l staffing stated in Table 5-1 is implemented in the plan, there can not be a  :

final decision on whether the plan change resulted in a reduction in the i

, effectiveness of the plan. Therefore, the board decided to postpone its  !

decision until the licensee had provided additional information on how the i licensee has implemented Table 5-1. The staffing stated in Table 5-1 is considered adequate for EP events.

~

The licensee agreed to provide the additional information requested by the

board and stated that it would provide a schedule to submit this information by letter or in another meeting the next week. By telephone conference call

, on July 16, 1997, the licensee stated that it would submit the additional l

! information by August 30, 1997.

i Docket No. 50-416 ,

[ Attachments: As stated cc w/atts: See next page I

The basis for the licensee's contention that the plan change did not reduce the effectiveness of the plan is that it instituted improvements in processes and equipment to reduce the work needed to be done by the 2 HP technicians which arriva at the site 30 minutes after the event. The licensee discussed the old and new processes and equipment for HP technicians in pages 13 through 30 of Attachment 3.

The staff discussed the numbers listed in Table 5-1 of the plan for GGNS for HP staffing in an event, and the changes in the processes and equipment for the HP technicians presented by the licensee.

Attachment 4 is the staff's Safety Evaluation datea December 11, 1996, on the plan change which concludes that the change does not meets the criteria of 10 CFR 50.54(q) and should not have been implemented without prior staff approval.

The staff caucused to consider the presentation and appeal by the licensee, and then reconvened the meeting.

The appeal board stated that the licensee had adequately addressed the issues raised in the Safety Evaluation dated December 11, 1996; however, the licensee >

had not adequately addressed the questions concerning Table 5-1 and the staffing for EP events at GGNS. Because there is a question of whether the staffing stated in Table 5-1 is implemented in the plan, there can not be a final decision on whether the plan change resulted in a reduction in the effectiveness of the plan. Therefore, the board decided to postpone its decision until the licensee had provided additional information on how the licensee has implemented Table 5-1. The staffing stated in Table 5-1 is considered adequate for EP events.

The licensee agreed to provide the additional information requested by the board and stated that it would provide a schedule to submit this information by letter or in another meeting the next week.

Docket No. 50-416 Attachments: As stated cc w/atts: See next page DISTRIBUTION: E-Mail SCollins/FMiraglia (SJC1/FJM) EFox (EFF)

Hard Cooy JClifford (JWC) EAdensam (EGA1) TGwynn (TPG)

Docket File SWeiss (SHW) CMiller (CLM1) BMurray (BXM)

PUBLIC RZimmerman (RPZ) TEssig (THE) CHawes (CMH2)

PD4-1 r/f JRoe (JWR) DBarss (DMB1) NStinson (NLS)

ACRS JDonohew (JND) FKantor (FXK) GGood (GMG)

OGC (15B18)

Document Name: GG071097.MTS OFC PM/PD( O LA/PD4-1 PERB/DRPM NAME JDorfokvw CHawes OMN TEssig6Adv DATE l/ /97 9//4/97 7 / 11 /97 COPY YES/NO YES/N0 YES/NO 0FFICIAL RECORD COPY

Entergy Operations, Inc. Grand Gulf Nuclear Station cc:

Executive Vice President General Manager, GGNS

& Chief Operating Officer Entergy Operations, Inc.

Entergy Operations, Inc. P. O. Box 756 P. 0.. Box 31995 Port Gibson, MS 39150 l Jackson, MS 39286-1995 I Attorney General Wise, Carter, Child &. Caraway Department of Justice ]i P. O. Box 651 State of Louisiana l Jackson, MS 39205 P. O. Box 94005 l Baton Rouge, LA 70804-9005  ;

Winston & Strawn i 1400 L Street, N.W. - 12th Floor State Health Officer )

Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General i Claiborne County Board of Supervisors State of Mississippi l P. O. Box 339 P. O. Box 22947 Port Gibson, MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc.

611 Ryan Plaza Drive, Suite 1000 P.O. Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident Inspector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs Route 2, Box 399 Entergy Operations, Inc. '

Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 i Manager of Operations i Bechtel Power Corporation P.O. Box 2166 Houston, TX 77252-2166 Mr. Joseph J. Hagan Vice President, Operations GGNS Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150

i . 4

• ATTENDEES AT MEETING OF MARCH 27. 1996 1

NVREG-1465. REVISED SOURCE TERMS S

HAME AFFILIATION W. Hughey E01 - Grand Gulf A. Morgan E0I - Grand Gulf T. Kriesel E01 - Grand Gulf M. Larson E0I - Grand Gulf D. Ellis E01 - Grand Gulf

J. Roe NRC/NRR/DRPW S. Weiss NRC/NRR/DRPM J. Clifford NRC/NRR/PDIV-1 C. Miller NRC/NRR/PERB T. Essig NRC/NRR/PERB J. Donohew NRC/NRR/PDIV-1 G. Good Ft.L Region IV E. Fox hRL/NRR/PERB 3 F. Kantor NRC/NRR/PERB D. Barss NRC/NRR/PERB i

where: E01 = Entergy Operations, Inc.

NRC = Nuclear Regulatory Commission NRR = Office of Nuclear Reactor Regulation DRPM = Division of Reactor Program Management

. DRPW = Division of Reactor Projects III/IV PERB = Emergency Preparedness and Radiation Protection Branch PDIV Project Directorate IV-1 l

ATTACHMENT 1

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APPEAL MEETING FOR EMERGENCY PLAN CHANGE 28.001-95 JULY 10. 1997

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l AGENDA I 1

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Opening Remarks Staff and licensee j Licensee's Presentation Licensee Staff's Presentation Staff Staff Caucus Appeal Decision S. Weiss and J. Roe Discussien Close Meeting l l

ATTACHMENT 2

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l Health Physics 30 Minute i Augmentation Grand Gulf Nuclear Station

, Entergy Operations, Inc.

July 10,1997

[

t Agenda 1

. Introduction All

. Background Kenneth Hughey

. What We Changed Kenneth Hughey

. Basis for Change Kenneth Hughey

. Comparison of Old HP Tom Kriesel Processes to New HP Processes

. Response to NRC Concerns Kenneth Hughey

. Summary Kenneth Hughey

. Comments All ,

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Background

. Change implemented on June 30,1995

. Discussed with NRC that we had implemented using 50.54(q)

. April 24,1997 NRC determined change was a decrease in effectiveness

. May 22,1997 submittal appealing decision and requesting a meeting 3

3 1

Compensatory Measures Upon receipt of NRC letter the following items were addressed:

, HP personnel were assigned to 30 minute oncall status -

short term solution

. Condition Report was written to address and document outcome of issue t

)

What We Changed

. Two Health Physicist's (HP's) changed from 30 to 60 minute augmentation

. No changes to HP functions as required in Table B-1 of ,

NUREG-0654

. No changes to on-shift HP staffing requirements No changes in total numbers of HP staffing 60 minutes after an event Net Effect: Two less HP's only from T-30 to T-60 minutes; 30 minute delay in staff augmentation

What We Changed GG FSAR Table 5-1 Shift Staffing and Augmentation Capabilities -

Capability for Additions Major Position Title On 30 Min 60 Min Functional Area Emergency Tasks or Expertise Location Shift (a) (a)  !

Protective - Access Control Health OSC 2(b) 2 3 j Actions (in- - HP coverage for Physicist  !

plant) Radiation repair, corrective - 4 t Protection actions, search and rescuelfirst-  !

aid, and firefighting

- Personnel monitoring j

- Dosimetry j r

Notes: i (a) Shift augmentation begins at the declaration of an Alert, Site Area Emergency, or General Emergency (b) May be provided by Shift Personnel assigned other duties i

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Regulatory Basis for Change ,

10CFR50.54(q) allows licensees to make changes to the Emergency Plan if:

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. No decrease in effectiveness i

. 10CFR50.47(b) requirements met ,

. Appendix E met ,

Does the change to EP provide for reasonable assurance that

adequate protection can and will be taken in the event of a Radiological Emergency i

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Decrease in Effectiveness

. Little guidance for defining what a decrease in effectiveness means

. Regulatory Review Group in 1993 stated:

- Licensees should not be precluded from making changes as

, long as a minimum was met .

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- Minimum is 10CFR50.47 and Appendix E

. Generic Letter 95-08 stated, " Latitude has always existed in that improvements in one area of the program may offset reductions in other areas."

Decrease in Effectiveness Based on NEl White Paper

. . Does the change result in loss of reasonable assurance

that ade~quate protection can and will be taken in the event of a radiological emergency?

. Does the change result in the loss of ability to meet any of the standards or applicable requirements described in i 10CFR50.47(b) and (d)?

. Does this change delete or contrac;;ct any other regulatory  ;

requirement?

i

t Basis for Change i

. HP work processes automated Issuance of EADs ,

Signing in on RWP's

- Verifying worker's dose margin, training qualification

- Verifying worker's dose received

. HP staff augmentation now consistent with majority of ,

ERO responders i

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Basis for Change

. Plant Design Major Engineered Safety Function (ESF) rooms have Area Radiation Monitors

. Improved understanding of Accident Progression

- New calculations, using GGNS, has shown significantly longer release times than that assumed as basis for NUREG-0654

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. Up to three needed for 2ch worker t

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. Required rezeroing prior to issuance

. Normally rezeroed after each entry i

Provided NO ALARMS to worker

. Worker had to stop and read I

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Access Control Paper Based

. Each worker had to be controlled with a piece of paper

. Required dedicated HP to track paperwork and workers i

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\a Radiation Work Permits

. Dose margins were not tied to any worker dosimeter alarms because workers did not have alarming dosimeters

. Workers had to manually sign in on RWP log sheet i

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i  :. l Dose Margins and Training Checks

. Dose margins verified by reviewing computer printout

. Status of training verified by reviewing training blue card or computer printout t

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Workers Were Dependent on HPs 1

. Dosimetry

. Dose, dose margin, and training check

. HP continuous coverage required for each team - no alarming dosimeters i.

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Electronic Alarming Dosimeters

. Worker self-issue

. Gives readout of dose to the worker / easier / quicker to read

. Alarms if setpoints are reached

. Total dose and doserate protection for worker

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Radiation Work Permits Automated

. EADs setpoints for each entry tied to dose margin t

. Workers sign in by use of SSN - HP is not needed i

Dose Margins and Training Checks i

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. Dose margins verified by computer at each login

. Training status automatically verified at each login

. Dose management is all automated

. Workers are locked out of RWP computer if margin is exceeded

. .'i Workers Not Dependent on HP's e

. Dosimetry - self issue i

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. Dose, dose margin, and training check - automated  !

. HPs do not have to escort all teams since EADs are used t

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4 Other items

. RWP computer system provides for gathering of historical dose information .

. Historical dose information can be used for future jobs / entries i

. Dose limits now automated - RWP computer will notify worker if dose limit is reach'ed t

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EADs Do Not Provide for Adequate Worker 1 Protection as Compared to HP Coverage

. EADs have improved workers' awareness of ALARA i

. EADs enhance HP coverage and worker protection i

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. Automated functions allow for greater HP coverage as compared to manual intensive process

. Not ALARA to require continuous HP coverage with every ,

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HP Escort Needed for Entry to Areas With 1 Damaged Spent Fuel Assemblies

. Fuel handling mainly done during refueling outages - HP manning 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day exceeds NUREG-0654 Table B-1

. HP coverage is required anytime fuel is being handled

. Radiological concern occurs very early in fuel handling accident well before staff augmentation e

27

5 Rapidly Changing Direct Radiation Levels and Significant Releases of Airborne Levels Mandates HP Escort

! . EADs are designed for rapidly changing conditions

enhancing worker protection and awareness of changing conditions

. Conservative HP practice has teams dispatched with SCBAs along with adequate HP coverage if radiological conditions are unknown

. ARM's in use provide for another layer of pro'zection against rapidly changing conditions by providing alaims for workers

. HP escort of all teams is not ALARA

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Low Set Points on EADs Result in Numerous -

Aborted Attempts

. EAD setpoints can be easily changed on a per entry basis and set as as high as needed to accomplish tasks for given/ expected radiological conditions

. Team is more effective because they are warned when radiological conditions have changed  :

. For teams that alarm EADs, new teams can be dispatched very easily since teams are in radio contact with OSC at all times 1

Non Dedicated Onshift HP's Reduces Quality .

of Coverage

. Onshift HP's are dedicated ANSI Qualified HP's

. NUREG-0654 Table B-1 allows non dedicated HP's

. No change proposed to this section of Table B-1 b

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Summary

. Automated process allows more HP resources to be focused on providing HP coverage thus reducing need for early staff augmentation

. Reasonable assurance that adequate protection can and will be taken i

. Revised Emergency Plan meets all requirements of 10CFR50.47(b) and (d) .

. Appropriate use of 10CFR50.54(q) 31

,. '*t UNITED STATES

' ' ' l, j NUCLEAR RECULATORY COMMISSION CASHIN!. ton, D.C. 33e06-0001

. ms SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMERGENCY PLAN CHANGE 28.001-95 ENTERGY OPERATIONS. INC.

GRMD GULF NUCLEAR STATION DOCKET NO. 50-416 I. 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 t,o meet the standards of Section 50.47(b) and the requirements of Appendix E.

Conference calls between Entergy Operations, Inc. and the Nuclear Regulatory Comission (NRC) occurred on June 12, 1996, and July 25, 1996, to discuss issues concerning this implemented change. The licensee submitted additional 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 unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, 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 limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiation ATTACHMENT 4

9: , ,- .

-emergencies, assessment actions, activation of emargency organization, notificatio, procedures, emergency facilities and equipment, training, saintaining emergency preparedness, and recovery. In addition, the emergency response plans submitted by an applicant for a nuclear power reactor operating license shall contain information needad to demonstrate compliance with the standards described in 10 CFR 50.47(b), and they will

-be evaluated against those standards.

10 CFR Part 50. Annendir E. IV. A. Oraanization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

iteaulatory Guide 1.101 'Emeroency Plannino and Preparedness for Nuclear Power Peactors". C. Reaulatory Position The cr'iteria and recomendations contained in Revision 1 of NUREG-0654/ FEMA-REP-1 are considered by the NRC staff to be acceptable methods 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 Emeroency Oraanization

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons ta 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 l Table B-1 entitled, ' Minimum Staffing Requirements for Nuclear Power 4

. Plant Emergencies." The minimum on-shift staffing levels shall be as '

indicated <n Table B-1. The licensee must be able to augment on-shift ,

capabilities within a short period after declaration of an emergency.

This capability shall be as indicated in Table B-1. The implementation schedule for licensed operators, tuxiliary 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, 1982. (See Table B-1).

7. Each licensee shall specify the corporate san'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:

..- - -.- -. -e- . .- - - - . - - . - . - - - - ~

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3-

a. logistics support for emergency personnel, ...; *'

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

c. management level interface with governmental authorities; and

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

IRIMC-0737 Sunnlement No.1

• Clarification of TMI Action Plan Renuirements' Table 2, ' Minimum staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies" (Note: Table 2 of NUREG-0737 is the same infomation contained in Table B-1 of NUREG-0654. The requirements of

- 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-g5, Grand Gulf Nuclear Station's (GGNS) staffing levels were in accordance with the minimum staffing guldance set forth in Table B-1 of NUREG-0654, "Ninimum Staffing Requirements For NRC Licensees For Nuclear Power Plant Emergencies". However, after the licensee implemented Emergency Plan Change 28.001-95 by letter dated June 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 Lpon which this SE is based increased the augmentation response time of the two health physics (HP) technicians responsible for radiation protection duties from 30 minutes following declaration cf an Alert, ,

Site Area Emergency, and General Emergency to 60 minutes. This change eliminated the 30 minute augmentation comitment of the HP technicians and shifted these individuals to 60 minute responders. The onshift requirements are not affected.

The licensee based its justification on three arguments:

1. Electronic Alaming Dosimeters (EADs)

2. Radiation Work Pamits (RWP)

3. Area Radiation Monitors (ARMS)

Paragraph 8 of the submittal stated in part:

"The use of electronic alarming 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 responders. The EAD radiation dose and dose rate alarms associated with the RWP are such that workers are precluded from exceeding radiation

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l dose limits, but at the same time allow workers to carry out emergency actions. Workers self-issue EADs, eliminatina the need for Health Physicists to physically issue dosimetry... Acc.n :9ntrol is maintained since the worker must enter a Radiation Work Permit (RWP number to be allowed access into the Radiologically Controlled Area (kCA).

...The EAD provides the worker with integrated total dose and dose rate, and alarms when either of these two have been exceeded... The use of EADs has reduced the need for Health Physics coverage for evolutions f related to performing emergency or corrective actions to place the plant i 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 D0SERATE 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 plant entries, personnel monitoring, and dosimetry. issuance.

These four major tasks include the following activities:

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 chang'ng radiological conditions; evaluate radiation levels to determine if entry of a RCA is persissible; determine stay times for entry of a RCA; provide radiation protection coverage for teams engaged in repair, corrective actions, search and rescue, first aid, and firefighting activities, o Personnel monitoring - Decontaminate of personnel contaminated with 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 couplednormal operatingWork with Radiation conditions, permitsElectronic (RWP) areAlaming Dosimeters adequate for worker(lf-EADs) se 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 margin's 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 perform these two duties is reduced by the use of the EADs in conjunction with the RWP. However, for the duties of HP coverage and personnel monitoring under emergency conditions, the use of the EADs does not adequately provide for worker safety as does the HP technician,' as explained below.

During the early phases of an accident, radiation levels are usually not a 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 inventory of radioactive material in the RCS is released directly to the environment, radiation levels within the plant or the issnediate area onsite 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 accidents involving releases from onsite storage tanks, the release of

i radioactive material could conceivably be the initiating event. In these i cases, HP technician escort for personnel entering high radiological areas ,

! will be necessary.  !

Under such accident conditions, self-monitoring with EADs would likely not

! provide sufficient protection of worker health and safety. Rapidly changing direct radiation levels, coupled with a significant potential for releases of i airborne radioactive materials, mandate HP technician accompaniment of teams conducting in-plant entries. An EAD would not adequately monitor the

, radiological environment of the worker under these conditions. Further, the l 1 use of EADs for self-monitoring would necessitate set points for worker l

} protection which would likely result in numerous aborted in-plant entries, 1 thus rendering the licensee's response to the emergency less effective.

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! Additionally, the on-shift HP technician positions for radiation protection 1 are not dedicated positions, i.e., they may be filled by shift personnel i essigned other duties. This can'further reduce the quality of radiation i 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 l 28.001-95 implemented by Entergy Operations, Inc. at the Grand Gulf Nuclear i

Plant decreases the effectiveness of the plan. The staff does not approve the change.

l Principal Contributor: Narvaez Stinson Date: December 11, 1996 l

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