ML20199K415

Forwards Proposed Addendum to Emergency Plan Changes Previously Submitted Via GNRO-98/00028 for NRC Review & Approval as Required by 10CFR50.54(q) & 50.4

ML20199K415
Person / Time
Site:	Grand Gulf
Issue date:	01/20/1999
From:	Hughey W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199K418	List: ML20199K415
References
GNRO-99-00007, GNRO-99-7, NUDOCS 9901260414
Download: ML20199K415 (3)

Text

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N RO. Box 756 Port Gbson, MS 39150 TG 601437-0470 W.K.Hughey Drectv Nmys Safety & hydatory January 20,1999 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:

Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Proposed Emergency Plan Change - Table 5-1 Change, Addendum to GNRO-98/00028 Augmentation Time

Reference:

GNRO-98/00028 dated March 6,1998 from EOl to NRC, Proposed Emergency Plan Change - Table 5-1 GNRO-99/00007 Gentlemen:

The enclosed proposed Emergency Plan change is an addendum to the changes previously submitted via GNRO-98/00028 and is hereby submitted for NRC staff review and approval as required by 10mR50.54(q) and 50.4. During informal discussions with the staff conceming our previous submittal, it was noted that justifying the time from event initiation to complete staff augmentation was not necessarily the only element that the staff used to support increased augmentation times. It was apparent from these discussions with the staff that the basis for approving increased augmentation times was also the demographics of the plant and plant personnel.

Review of other plant submittals and NRC safety evaluations for submittals similar to GNRO-98/00028 did indicate that the NRC has allowed increases in augmentation times based on demographics (remote siting) and proximity of onshift Emergency Response

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Organization (ERO) personnel to the plant. In our previous submittal (GNRO-98/00028) we felt that any increase in augmentation time should involve betterment in the protective 1

measures onshift personnel can provide in case of a radiological emergency. Therefore, g

as discussed in GNRO-98/00028, we committed to increase onshift staffing requirements gD and capabilities thus increasing protective measures that can and will be taken in the

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event of a radiological emergency.

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V GNRO-99/00007 Page 2 of 3 Our priorjustification for the proposed 120 minute augmentation time was based on the ability to perform all key functions in Table 5-1 of our Emergency Plan without staff augmentation for any design basis accident associated with a Site Area Emergency or General Emergency (see GNRO-98/00028 Attachment 2 item L3). The 120 minutes was also chosen as a maximum staff augmentation time since it was a number the staff had previously approved for other sites. Given our new understanding of the Staff's desire to factor in plant demographics, we have reevaluated our augmentation time. Consequently, we have determined that 90 minutes is a more realistic value for augmentation of onshift ERO pe,sonnel although we remain convinced that 120 minutes is technically justifiable.

The basis for the 90 minute staff augmentation is provided in Attachment 2. This new proposed augmentation time does not invalidate the justification provided in GRNO-98/00028 but ratherjust adds additional conservatism by completing staff augmentation earlier than previously evaluated. I would like to stress that the 90 minute augmentation time is not meant to give an allowance for delaying ERO response. The expectation is that ERO personnel respond immediately and report to their assigned facility as soon as possible whenever the Emergency Plan is activated. During normal working hours, it is expected that all ERO positions would be filled before the 90 minute requirement.

The proposed changes wero evaluated against the criteria of 10CFR50.47,10CFR50, Appendix E, and other NRC guidance documents. The revised augmentation time of 90 minutes does not result in any reduction in the capability of the Emergency Response Organization to respond to an Emergency. Increasing the required onshift staffing levels and capabilities results in a betterment in the protective measures onshift personnel can provide in the event of a radiological emergency and therefore offsets any perceived reductions provided by a 90 minute augmentation time. Increasing the augmentation time to 90 minutes addresses 10CFR50.47(b)(2) requirements for timely augmentation.

Providing increased onshift staffing / capability to perform Table 5-1 key functions for initial facility accident response also ensures compliance with 10CCFR50.47(b)(2). This change has been reviewed and appm /ed by the onsite Plant Safety Review Committee. includes a mark-up of the proposed Table 5-1 (Attachment 3 in GNRO-98/00028)in the Emergency Plan illustrating the desired changes. Attachment 2 provides the justification for each change provided in Attachment 1. Attachment 3 is a clean copy of Table 5-1 and reflects all proposed Attachment 1 changes.

8 Palo Verde and Davis Besse

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GNRO-99/00007 Page 3 of 3 For questions or comments, please feel free to contact Mr. Kenneth Hughey at (601) 437-6470. We appreciate the cooperation and attention of the staff on this matter and look forward to working with the staff on this change since this change is critical to engoing organizationalimprovements planned.

Yours truly, i

1 hk WKH/MJL attachments:

1. Mark-Up of Revised Proposed Emergency Plan Pages

2. Justification for Revision to Emergency Plan Table 5-1

3. Proposed Emergency Plan Table 5-1 Revised Information incorporated cc:

Ms. J. L. Dixon-Herrity, GGNS Senior Resident Mr. N. S. Reynolds Mr. L J. Smith (Wise Carter)

Mr. H. L. Thomas Mr. E. W. Merschoff (w/2)

Regional Administrator U.S. Nuclear Regulatory Commission Region IV

.611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 i

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Att: chm:nt 1 to GNRO-99/00007 ATTACHMENT 1 r

MARK-UP OF REVISED PROPOSED EMERGENCY PLAN PAGES t

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