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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F8911999-10-13013 October 1999 Forwards Copy of FEMA Region IV Final Rept for 990623-24, Grand Gulf Nuclear Station Exercise.Rept Indicates No Deficiencies or Areas Requiring Corrective Action Identified During Exercise ML20216J8891999-10-0404 October 1999 Forwards Details of Existing Procedural Guidance & Planned Administrative Controls.Util Respectfully Requests NRC Review & Approval of Changes by 991020.Date Will Permit to Implement Changes & Realize Full Benefit During Refueling ML20217B0361999-10-0404 October 1999 Refers to Investigation Conducted by NRC OI Re Activities at Grand Gulf Nuclear Station.Investigation Conducted to deter- Mine Whether Security Supervisor Deliberately Falsified Unescorted Access Authorizations.Allegation Unsubstantiated ML20212J8151999-09-29029 September 1999 Forwards Insp Rept 50-416/99-12 on 990725-0904.One Violation Noted & Being Treated as Noncited Violation.Licensee Conduct of Activities at Grand Gulf Facility Characterized by Safety Conscious Operations,Sound Engineering & Maint Practices ML20216J6811999-09-28028 September 1999 Ack Receipt of ,Transmitting Rev 31 to Physical Security Plan for GGNS Under Provisions of 10CFR50.54(p). NRC Approval Not Required,Based on Determination That Changes Do Not Decrease Effectiveness & Limited Review ML20212J7361999-09-28028 September 1999 Forwards Insp Rept 50-416/99-11 on 990830-0903.No Violations Noted.Purpose of Insp to Review Solid Radioactive Waste Management & Radioactive Matl Transportation Programs ML20212J5321999-09-27027 September 1999 Forwards Insp Rept 50-416/99-14 on 990830-0903.No Violations Noted.Inspectors Determined That Radioactive Waste Effluent Releases Properly Controlled,Monitored & Quantified ML20216J7101999-09-26026 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator License Examinations ML20216J8141999-09-26026 September 1999 Forwards Proprietary Renewal Applications for Licensed Operators for Wk Gordon & SA Elliott at Grand Gulf Nuclear Station.Proprietary Info Withheld ML20212F5521999-09-23023 September 1999 Forwards SER Accepting Util Analytical Approach for Ampacity Derating Determinations at Grand Gulf Nuclear Station,Unit 1 & That No Outstanding Ampacity Derating Issues as Identified in GL 92-08 Noted ML20212D9211999-09-16016 September 1999 Informs That NRC Staff Completed Midcycle PPR of GGNS on 990818 & Identified No Areas in Which Licensee Performance Warranted Insp Beyond Core Insp Program.Details of Insp Plan Through March 2000 Encl ML20212A9331999-09-13013 September 1999 Forwards Partially Withheld Insp Rept 50-416/99-15 on 990816-20 (Ref 10CFR73.21).One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20211P7631999-09-10010 September 1999 Discusses Staff Issuance of SECY-99-204, Kaowool & FP-60 Fire Barriers at Plant.Proposed Meeting to Discuss Subj Issues Will Take Place in Oct or Nov 1999 ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20211Q3471999-09-0909 September 1999 Forwards Federal Emergency Mgt Agency Final Rept for 990623 Plant Emergency Preparedness Exercise.No Deficiencies Noted & One Area Requiring Corrective Action Identified ML20211Q3091999-09-0909 September 1999 Forwards Safety Evaluation Accepting BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic BWR, Dtd July 1996 ML20211Q4861999-09-0808 September 1999 Informs That Util Has Discovered Dose Calculation Utilized non-conservative Geometry Factor for Parameter.Calculation Error Being Evaluated in Accordance with Corrective Action Program ML20211Q0091999-09-0808 September 1999 Forwards Request for Addl Info Re Individual Plant Exam of External Events for Grand Gulf Nuclear Station,Unit 1. Response Requested by 000615 ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues ML20211P4171999-09-0707 September 1999 Ack Receipt of ,Which Transmitted Addendum to Rev 30 to Physical Security Plan for Ggns,Per 10CFR50.54(p).NRC Approval Is Not Required,Since Util Determined That Changes Do Not Decrease Effectiveness of Plan ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211K6061999-08-31031 August 1999 Informs That Plant Has No Candidates to Take 991006 Generic Fundamentals Exam ML20211K5641999-08-31031 August 1999 Forwards Rev 39 to Grand Gulf Nuclear Station Emergency Plan Non-Safety Related, IAW 10CFR50,App E,Section V. Changes Do Not Decrease Effectiveness of Plan & Continues to Meets Stds of 10CFR50.47(b) & Requirements of App E ML20211J2321999-08-26026 August 1999 Advises That Info Contained in to Support NRC Review of GE Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic BWR, Will Be Withheld from Public Disclosure ML20211J3761999-08-25025 August 1999 Corrected Ltr Informing That Info Provided (on Computer Disk & in Ltr to Ineel ) Marked as Proprietary Will Be Withheld from Public Disclosure Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended.Corrected 990827 ML20211F4881999-08-25025 August 1999 Advises That Info Submitted by 990716 Application & Affidavit Containing Diskette & to Ineel Mareked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20211F7751999-08-24024 August 1999 Forwards Insp Rept 50-416/99-10 on 990809-13.No Violations Noted.Insp Covered Licensed Operator Requalification Program & Observations of Requalification Activities ML20211C4381999-08-20020 August 1999 Forwards Rev 31 to Physical Security Plan for Protection of Grand Gulf Nuclear Station,Iaw 10CFR50.54(p).Util Has Determined That Rev Does Not Decrease Effectiveness of Plan. Encl Withheld,Per 10CFR73.21 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20211B3761999-08-16016 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001, ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20211A9481999-08-12012 August 1999 Informs of Completion of Analysis of Heat Transfer in Cooler During Fan Coast Down & Concludes That Potential Exists for Steam Foundation,Under Conditions Where Dcw Sys Flow Is Lost Prior to Full Isolation Valve Closure ML20210P8411999-08-0909 August 1999 Forwards Insp Rept 50-416/99-09 on 990613-0724.No Violations Noted.Activities at Facility Generally Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Careful Radiological Work Controls ML20210N6401999-08-0303 August 1999 Informs That Eighteeen Identified Penetrations Will Be Restored to Conformance with Licensing Requirements Prior to Restart from RFO10,scheduled for Fall 1999,per GL 96-06. Example of Piping Analysis Being Performed,Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K1951999-07-30030 July 1999 Forwards Insp Rept 50-416/99-03 on 990405-08 & 0510-11.No Violations Identified ML20211K7491999-07-30030 July 1999 Forwards Ltr Rept Documenting Work Completed Under JCN-W6095,analyses Performed at Ineel to Calculate Minimum Time to Fuel Pin Failure in Boiling Water Reactors (BWR) ML20210K6661999-07-29029 July 1999 Forwards Fitness for Duty Program Performance six-month Rept for Period Covering Jan-June 1999,per 10CFR26.71 ML20210F3591999-07-26026 July 1999 Forwards Proprietary Version & Redacted Version of Wyle Test Rept M-J5.08-Q1-45161-0-8.0-1-0,re Pressure Locking & Thermal Binding Test Program.Proprietary Version Withheld ML20210E3251999-07-23023 July 1999 Forwards Insp Rept 50-416/99-07 on 990622-25.No Violations Noted.Emergency Plan & Procedures During Biennial Emergency Preparedness Exercise Was Conducted ML20210D2401999-07-21021 July 1999 Informs of Resignation of Operator WE Griffith,License OP-20806-1,from Entergy Operations,Inc ML20209J0311999-07-16016 July 1999 Forwards Proprietary Info Supporting Review of Generic Alternate Source Term Request.Proprietary Info Withheld Per 10CFR2.790 ML20209G4791999-07-15015 July 1999 Forwards Proposed Emergency Plan Change as Addendum to Changes Previously Submitted Via GNRO-98/00028 & GNRO-99/00007,for NRC Review & Approval ML20210B1031999-07-15015 July 1999 Forwards Insp Rept 50-416/99-08 on 990502-0612.Determined That Three Severity Level IV Violations Occurred & Being Treated as Noncited Violations ML20210H3211999-07-14014 July 1999 Forwards Proprietary Info Supporting Review of 970506 Submittal of BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic Bwr. Proprietary Info Withheld Per 10CFR2.790 ML20209D7511999-07-0909 July 1999 Responds to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. as Result of NRC Review of Util Responses,Info Revised in Rvid & Rvid Version 2 Will Be Released ML20209D7671999-07-0101 July 1999 Submits Response to Violations Noted in Insp Rept 50-416/99-02 on 990222-26 & 0308-12.Corrective Actions: Contractor Performance Has Been re-evaluated in Regards to UFSAR Reviews ML20196K4901999-07-0101 July 1999 Discusses Relief Requests PRR-E12-01,PRR-E21-01,PRR-E22-01, PRR-P75-01,PRR-P81-01,VRR-B21-01,VRR-B21-02,VRR-E38-01 & VRR-E51-01 Submitted by EOI on 971126 & 990218.SE Accepting Alternatives Proposed by Util Encl ML20196J5711999-06-30030 June 1999 Advises That Versions of Submitted Info in 990506 Application & Affidavit, Re Proposed Amend to Revise Ts,Marked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20216J8891999-10-0404 October 1999 Forwards Details of Existing Procedural Guidance & Planned Administrative Controls.Util Respectfully Requests NRC Review & Approval of Changes by 991020.Date Will Permit to Implement Changes & Realize Full Benefit During Refueling ML20216J7101999-09-26026 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator License Examinations ML20216J8141999-09-26026 September 1999 Forwards Proprietary Renewal Applications for Licensed Operators for Wk Gordon & SA Elliott at Grand Gulf Nuclear Station.Proprietary Info Withheld ML20211Q4861999-09-0808 September 1999 Informs That Util Has Discovered Dose Calculation Utilized non-conservative Geometry Factor for Parameter.Calculation Error Being Evaluated in Accordance with Corrective Action Program ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211K6061999-08-31031 August 1999 Informs That Plant Has No Candidates to Take 991006 Generic Fundamentals Exam ML20211K5641999-08-31031 August 1999 Forwards Rev 39 to Grand Gulf Nuclear Station Emergency Plan Non-Safety Related, IAW 10CFR50,App E,Section V. Changes Do Not Decrease Effectiveness of Plan & Continues to Meets Stds of 10CFR50.47(b) & Requirements of App E ML20211C4381999-08-20020 August 1999 Forwards Rev 31 to Physical Security Plan for Protection of Grand Gulf Nuclear Station,Iaw 10CFR50.54(p).Util Has Determined That Rev Does Not Decrease Effectiveness of Plan. Encl Withheld,Per 10CFR73.21 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20211B3761999-08-16016 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001, ML20211A9481999-08-12012 August 1999 Informs of Completion of Analysis of Heat Transfer in Cooler During Fan Coast Down & Concludes That Potential Exists for Steam Foundation,Under Conditions Where Dcw Sys Flow Is Lost Prior to Full Isolation Valve Closure ML20210N6401999-08-0303 August 1999 Informs That Eighteeen Identified Penetrations Will Be Restored to Conformance with Licensing Requirements Prior to Restart from RFO10,scheduled for Fall 1999,per GL 96-06. Example of Piping Analysis Being Performed,Encl ML20211K7491999-07-30030 July 1999 Forwards Ltr Rept Documenting Work Completed Under JCN-W6095,analyses Performed at Ineel to Calculate Minimum Time to Fuel Pin Failure in Boiling Water Reactors (BWR) ML20210K6661999-07-29029 July 1999 Forwards Fitness for Duty Program Performance six-month Rept for Period Covering Jan-June 1999,per 10CFR26.71 ML20210F3591999-07-26026 July 1999 Forwards Proprietary Version & Redacted Version of Wyle Test Rept M-J5.08-Q1-45161-0-8.0-1-0,re Pressure Locking & Thermal Binding Test Program.Proprietary Version Withheld ML20210D2401999-07-21021 July 1999 Informs of Resignation of Operator WE Griffith,License OP-20806-1,from Entergy Operations,Inc ML20209J0311999-07-16016 July 1999 Forwards Proprietary Info Supporting Review of Generic Alternate Source Term Request.Proprietary Info Withheld Per 10CFR2.790 ML20209G4791999-07-15015 July 1999 Forwards Proposed Emergency Plan Change as Addendum to Changes Previously Submitted Via GNRO-98/00028 & GNRO-99/00007,for NRC Review & Approval ML20210H3211999-07-14014 July 1999 Forwards Proprietary Info Supporting Review of 970506 Submittal of BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic Bwr. Proprietary Info Withheld Per 10CFR2.790 ML20209D7671999-07-0101 July 1999 Submits Response to Violations Noted in Insp Rept 50-416/99-02 on 990222-26 & 0308-12.Corrective Actions: Contractor Performance Has Been re-evaluated in Regards to UFSAR Reviews ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20195J6351999-06-16016 June 1999 Forwards Addendum to Rev 30 of GGNS Physical Security Plan IAW 10CFR50.54(p).Addendum Is Submitted to Announce Relocation/Reconfiguration of Plant Central & Secondary Alarm Station Facilities.Rev Withheld,Per 10CFR73.21 ML20195G0281999-06-0909 June 1999 Submits Summary on Resolution of GL 96-06 Re Eighteen Penetrations Previously Identified as Being Potentially Susceptible to Overpressurization ML20207F5041999-06-0202 June 1999 Forwards Updated Medical Rept IAW License Condition 3 for DA Killingsworth License OP-20942-1.Without Encls ML20206P2981999-05-13013 May 1999 Forwards Responses to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, Cancelling 990402 Submittal ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 ML20206J0941999-05-0404 May 1999 Forwards Proprietary & Redacted ME-98-001-00,both Entitled, Pressure Locking & Thermal Binding Test Program on Two Gate Valves with Limitorque Actuators. Rept ME-98-002-00 Re Flexible Wedge Gate Valves,Encl.Proprietary Rept Withheld ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested ML20206D8171999-04-29029 April 1999 Informs NRC of Results of Plant Improvement Considerations Identified in GGNS Ipe,As Requested in NRC . Licensee Found Efforts Have Minimized Extent of Radiological Release in Unlikely Event That Severe Accident Occurred ML20206D7281999-04-28028 April 1999 Forwards South Mississippi Electric Power Association 1998 Annual Rept, Per 10CFR50.71(b).Licensee Will Submit 1998 Annual Repts for System Energy Resources,Inc,Entergy Mississippi,Inc & EOI as Part of Entergy Corp Annual Rept ML20206C9551999-04-22022 April 1999 Forwards 1999 Biennial Emergency Preparedness Exercise Scenario. Without Encl ML20205M1311999-04-0202 April 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Info Was Discussed During Conference Call with NRC on 990126.Wyle Position Paper Encl.Subj Paper Withheld ML20205H5861999-04-0101 April 1999 Requests Relief from ASME B&PV Code,Section XI for Period of Time That Temporary non-code Repair Was in Effect,Per 10CFR50.55a(g)(5)(iii) ML20205F1781999-03-31031 March 1999 Forwards Consolidated Entergy Submittal to Document Primary & Excess Property Damage Insurance Coverage for Nuclear Sites of Entergy Operations,Inc,Per 10CFR50.54(w)(3) ML20196K7101999-03-26026 March 1999 Submits Reporting & Recordkeeping for Decommissioning Planning,Per 10CFR50.75(f)(1) ML20205A6511999-03-25025 March 1999 Responds to NRC Re Violations Noted in Insp Rept 50-416/99-01 on 990201-05.Corrective Actions:Program Will Be Implemented to Ensure Accessible Areas with Radiation Levels Greater than 1000 Mrem/H ML20204E7391999-03-15015 March 1999 Forwards Objectives for June 1999 Emergency Preparedness Exercise for Plant.Without Encl ML20207H9291999-03-0404 March 1999 Submits Update to Original Certification of Grand Gulf Nuclear Station Simulation Facility IAW Requirements of 10CFR55.45(b)(5) ML20207E3081999-03-0303 March 1999 Informs That GGNS Severe Accident Mgt Implementation Was Completed on 981223.Effort Was Worthwhile & Station Ability to Respond & Mitigate Events That May Lead to Core Melt Has Been Enhanced ML20207E3221999-03-0303 March 1999 Notifies of Change in Status of Mj Ellis,License SOP-43846. Conditional License Requested to Accommodate Medical Condition.Revised NRC Form 396 with Supporting Medical Evidence Attached.Without Encls ML20207A8161999-02-24024 February 1999 Forwards 1998 Annual Operating Rept for Ggns,Unit 1. Listed Attachments Are Encl ML20207A9901999-02-24024 February 1999 Informs That Util Has No Candidates from GGNS to Nominate for Participation in Planned Gfes,Scheduled for 990407 ML20203A1551999-02-0101 February 1999 Forwards Grand Gulf Nuclear Station Fitness for Duty Program Performance six-month Rept for Reporting Period 980701-981231 ML20202G0791999-01-26026 January 1999 Informs That He Mcknight Has Been Permanently Reassigned from Position Requiring License to Perform Assigned Duties. License Is No Longer Needed,Effective 981231 ML20199K4151999-01-20020 January 1999 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 ML20199K6771999-01-14014 January 1999 Provides Notification of Planned ERDS Software Change Scheduled to Take Place on 990215 ML20199D8811999-01-11011 January 1999 Submits Response to SE JOG Program on Periodic Verification of motor-operated Valves,In Response to GL 96-05 ML20199D9521999-01-0808 January 1999 Informs That CE Cresap,License SOP-4220-4,has Been Permanently Reassigned from Position Requiring License & No Longer Has Need for License,Per 10CFR50.74 ML20199A6081999-01-0606 January 1999 Submits List of Plant Info Brochures Disseminated Annually to Public & List of Updated State &/Or Local Emergency Plan Info,Per NRC Administrative Ltr 94-07, Distribution of Site-Specific & State Emergency Planning Info ML20202B7531998-12-21021 December 1998 Submits Ltr Confirming Discussion with J Tapia,Documenting Extension for Response to NOV 50-416/98-13.Util Response Will Be Submitted by 990212 1999-09-08
[Table view] |
Text
( ,( / i c
g O Enttrgy oper tions,Inc.
kf PO. Box 756 Port Gbson. MS 39150 1
Toi 601437-6470
- w. K. Hughey J Safey & Req 4atory July 15,1999
! U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 !
Proposed Emergency Plan Change - Table 5-1 Change, Addendum to l GNRO-98/00028 Augmentation Time at NRC Request
Reference:
GNRO-98/00028 dated March 6,1998 from EOl to NRC, Proposed Emergency Plan Change - Table 5-1 GNRO-99/00007 dated January 20,1999 from EOl to NRC, Proposed Emergency Plan Change - Table 5-1 Change, Addendum to GNRO-98/00028 Augmentation Time GNRO-99/00058 Gentlemen:
The enclosed proposed Emergency Plan change is an addendum to the changes previously submitted via GNRO-98/00028 and GNRO-99/00007 and is hereby submitted for NRC staff review and approval as required by 10CFR50.54(q) and 50.4. During a June 29,1999 phone discussion with the staff concerning our previous submittalit was agreed that specified changes to the proposed Table 5-1, (provided in GNRO-99/00007),
were appropriate to assist the staff in completing their review of our proposed Emergency Plan changes.
We believe it appropriate to reiterate for the Staff's benefit GGNS's general philosophy on the proposed Emergency Plan changes. Without question, all proposed changes must be evaluated against the criteria of 10CFR50.47,10CFR50, Appendix E and other NRC guidance documents.
In part;cular for our proposed Emergency Plan change submitted on March 6,1998, we felt it was first important to ensure 10CFR50.47(b)(2) requirements, specifically " adequate
( staffing to provide initial facility accident response in key functional areas is maintained at I all times... " were met. Our process to ensure compliance with 10CFR50.47(b)(2) involved identification of key functional tasks that we felt onshift ERO personnel
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c GNRO-99/00058 Page 2 of 7
, should be able to perform at all times and for periods up to 90 minutes and longer if circumstances warrant' without augmentation. The key functional tasks are:
H e. Classification of an event.
. Offsite agency notification.
1 Dose assessment and issuance of PAR's (protective action recommendations).
. Mitigation of the event.
Table 5-1 emergency tasks were identified which support performance of the above listed L ' key functional tasks during the proposed non-augmented time of 90 minutes. After identification of the required emergency tasks, we then identified tasks that would be staffed onshift and those tasks which were shift capable2 positions. This necessitated increasing (overstaffing) our NRC committed onshift staffing by 50% to ensure onshift l ; personnel were capable of performing ths key functional tasks during the first 90 minutes L 'of an emergency.;The 50% increase was based on our committed increase of onshift
! staffing from 10 personnel to 15. [This conclusion is based on the fact NUREG-0654 Table B-1 requires 10 dedicated on-shift individuals as compared to the 15 dedicated on-shift individuals proposed.]
increases in specific onshift staffing or capability (GNRO-98/00028, Attachment 2, M1 through M7) included sp9cific increases in Table 5-1 commitments which were proposed
- to offset any decrease in emergency capability associated with the 90 minute augmentation, included:
. .. Increasing the onshift communicator staffing from one to two.
e' Providing radwaste operator capabinty as an onshift requirement.
L e Increasing onshift l&C staffing from zero to one.
l e< Deleting footnote denoting mechanical and electrical maintenance as a shared :
- function thus increasing onshift staffing in these areas by one each.
.- Increas'ng onsite survey staffing from zero to one.
. Providing the capability to perform onshift dose assessment (EPPOS-3).
. Combining core / thermal hydraulics function with the onshift shift technical advisora ,
. - Activation of all facilities at an ALERT.
= Another form of overstaffing, as discussed with the NRC staff during the telephone call on June 29,1999, includes calling out personnelin an emergency prior to reaching a defined emergency classification. As agreed, additional wording to clarify the allowance for calling in of additional resources to the site to assist onshift personnel in case of a real or
- potential hazard, as deemed necessary by the Emergency Director, is being included. We agree with this concept, and believe the suggested wording further enhances the acceptability of our proposed plan changes since the ERO could be onsite providing augmentation before an emergency classification and facility activation threshold level had M While staff augmentation is expected within the required time, circumstances such as severe weather condibons may further deley augmentshon (e.g., situation simber to the hurricane at Turkey Point). Thus, the GGNS philosophy of ensuring capately at all times.
- Currently required tpy GGNS Technical Spectrication 5.2.2.g and UFSAR 13.12.3.8.
GNRO-99/00058
. Page 3 of 7 been reached-.We believe this provides an additional layer of defense and fully supports .
the increase in augmentation time since overstaffing would occur prior to reaching any
. threshold based level.
i Additionally, onshift' personnel are more effective initially than having to call in personnel from offsite in responding to an event. The "more effective because they are already
- here" idea has previously been endorsed by the NRCY Since we are committing to overstaff onshift personnel, we feel that our overall response is more effective, which offsets the delayed augmentation as a result of the proposed augmentation time of 90 l- : minutes.
To validate the ability to perform the mafarity of the tasks identified in Table 5-1 without staff augmentation, EP evaluated drills are performed on the Operations Staff using the plant s;mulator. These drills, which last approximately 90 minutes (excluding the post-drill l critique), are performed during the Operations re-qualification period. An average of 20 l such drills per year were conducted in the past two years. During these drills, the Operations Staff is taken from a normal operating condition to an accident condition usually culminating in a General Emergency Classification. During this time, the Operations Staff performs all the functions they would normally be required to perform in an emergency condition prior to the TSC or EOF becoming operational. Additionally, the staff augmentation provided the Operations Staff includes only those minimum-staffing personnel expected to be available during a backshift period. Conduct of such j standardized drills demonstrates the ability to adequately perform such key functional tasks as event classification, dose assessment, offsite communications / notifications, accident mitigation, and team prioritization and tracking.
An additional validation of GGNS's ability to perform the tasks identified in Table 5-1 can be found in NRC Inspection Report 50-416/98-16. During the inspection, the inspectors conducted walkthroughs with two operating crews using a dynamic simulation on the plant-specific control room simulator. Also, walkthroughs were conducted to evaluate the licensee's ability to:
- ' Evaluate plant conditions.
1 Classify the emergency using the latest procedures.
. Recommend appropriate protective actions (onsite and offsite).
e: Make timely notifications to offsite agencies.
. Perform and evaluate dose calculations.
These drills are normally observed every two years by Region IV in conjunction with their scheduled 82701 Inspection module.
J Also, to support staff approval of the change, we felt it was necessary to discuss the reasons why onshift personnel would not be overwhelmed by too many tasks and not enough people. The justification, as provided in GNRO-98/00028, provides the detail necessary to come to the conclusion that onshift personnel will not be overwhelmed for 90
)
'
- Reference; NRc safety evaluaten for revision to South Texas Project Emergency Plan dated May 20,1993.
l l
j
p ; ..
' GNRO-99/00058 L Page 4 of 7 l-t minutes (with the new onshift staffing number of 15) of an event. Justification for each function is as follows:.
Emergency, Task / Position Justification as stated in GNRO-98/00028 ID#
. Offsite Dose Offsite dose assessment calculations are easily L8 Assessment performed by onshift personnel. One trained individual can rapidly perform dose calculations with a user-friendly computerized dose calculation work station available at several locations in the plant and selected emergency facilities. Onshift offsite dose assessment calculations can be performed on demand and as necessary to provide protective action recommendations.
l e Offsite radiological Delayed augmentation of offsite radiological survey L4 Surveys responders is acceptable based on the onshift capability to perform onsite surveys and the fact that there may not even be a need to perform surveys due to installed post accident effluent radiation monitors. Onsite surveys or installed post accident effluent radiation monitors provide rapid indication of a release of radioactive materials and
. either can be t! sed for offsite dose assessment calculation purposes. The Grand Gulf site is surrounded by state roads, some of which are located within the site boundary. Onsite (plume l = tracking) surveys could include a mix of onsite and :
, offsite locations. Performance of onsite surveys
. necessitates transversing offsite areas (areas l
, outside the site boundary) in order to get to other i onsite survey locations within the site boundary. j e In-Plant Surveys . 10CFR20.1101(b) requires the use of procedures, L6 engineering controls, and sound radiation protection principles to achieve occupational doses l that are ALARA. Performing in-plant surveys on i as-needed basis in combination with HP coverage l l
and use of in-plant radiation monitoring 4
instrumentation supports this change.
- Core / Thermal The STA is already required to perform this task LS
. Hydraulics onshift as outlined in the GGNS Technical l Specifications and UFSAR. ;
i l
l; ;
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GNRO-99/00058 Page 5 of 7:
e ' Electrical Maintenance ~ Requiring this function onshift at all times allows M6
. delay of the 30-minute responder.
l e Protective Action Health Providing the capability to perform all survey tasks L1 Physicist onshift is consistent with the NRC position given in L3 EPPOS-3, Final Emergency Preparedness Position (EPPOS) for the Onshift Dose Assessment task.
- Technological improvements in radiological access ,
control, dosimetry, and worker personnel -
monitoring have all resulted in an increase in the ]
)
effectiveness of onshift HP resources. Onshift HP '
resources are now focused on the two most important radiation protection emergency tasks: HP coverage and onsite surveys. Providing the capability to perform all types of surveys onshift necessary to support worker radiation protection and offsite dose assessment requirements provides reasonable and adequate protection for public health and safety.
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- The EP planning guidance documents developed in the late 70's and early 80's (used to
' develop the GGNS Emergency Plan) were not developed using the insights or benefit of probabilistic risk assessment (PRA), Although the Grand Gulf Emergency Plan was
' developed to protect public health and safety in the event of any type of accident, it is recognized that the likelihood of an event leading to core damage and a large early release of radioactive materialis extremely remote. As discussed in L3 section of the March 8* letter, the NUREG/CR 4550 probabilistic risk assessment (PRA) and the updated GGNS PRA both estimate core damage frequency for GGNS to be approximately SE-6/ year. This is well below the Commission's subsidiary safety goal of 1E-4/ year for' l core damage frequency and is also below the goal of 1E-5/ year for large release. Only a fraction of this total would result in core damage in two hours or less. In addition, only a - ,
very small fraction of the core damage frequency total results in radioactive releases with i any appreciable impact on public health and safety within this time frame.
Based on the G' GNS PRA analysis, containment failure, if at all, occurs at the earliest I eleven or more hours after the initiating event. Containment bypass scenarios which !
could potentially result in releases before this time frame have a frequency of less than l
, 1E-7 and are below the screening criteria suggested by Appendix 2 of NRC Generic Letter 88-20.: While vessel breach, in a small fraction of the core damage scenarios, may occur as early as an hour and a half after the initiator, containment failure is required for there to be an impact on public health and safety. During the time following an initiator and prior to core damage, operator actions are plant centered and are being directed by Emergency Procedures. These procedures are focused on establishing core cooling (thereby, arresting or preventing core damage) and preventing containment failure.
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GNRO-99/00058
.Page 6 of 7.-
i it should be noted that the time frames discussed above, while based on best estimate methods and tools, are still somewhat conservative in that the methods still must assume that multiple' equipment failures occur at the same time for many cases. This results in some over estimation of core damage frequency and conservatively short estimates on the timing of many accident progression events. The overall result is conservative.
1 The GGNS PRA results (from best estimate severe accident studies) provide further justification that the proposed changes in the Emergency Plan would not have a bearing on the public health risk from the operation of the station.
The PRA discussion, as provided in the March 6,1998 letter was provided as an aid to the staff since it allows the staff to evaluate the proposed change on the basis of risk and supports the staff's risk-informed approach. Although not the sole basis for the requested change, the PRA discussion can be used by the staff in the safety decision process and
'should facilitate a more efficient use of staff resources.
We would like to continue 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 or when directed at the discretion of the Emergency Director. During normal working hours, it is expected that all ERO positions would be filled before the 90-minute requirement. Nevertheless, our evaluations have demonstrated that
, . adequate protection of public health and safety can be assured for delays in staff l augmentation up to and longer than 90 minutes if circumstances warrant, j The proposed changes were evaluated against the criteria of 10CFR50.47,10CFR50,
' Appendix E, and other NRC guidance documents. The NRC requested changes support the proposed augmentation time of 90 minutes. increasing the required onshift staffing levels and capabilities results in a betterment in the protective measures onshift personnel l can provide in the event of a radiological emergency which offsets any perceived l
. reductions provided by a 90 minute augmentation time. Increasing the augmentation time i
. to 90 minutes addresses 10CFR50.47(b)(2) requirements for timely augmentation. i L Providing increased onshift staffing / capability to perform Table 5-1 key functions for initial l facility accident response also ensures compliance with 10CCFR50.47(b)(2). This change has been reviewed and approved by the onsite Plant Safety Review Committee. ;
, Attachment 1 includes a mark-up of the proposed Table 5-1 (Attachment 3 in GNRO-l 98/00028) in the Emergency Plan illustrating the desired changes. Attachment 2 provides j 4
. the justification for each change provided in Attachment 1. Attachment 3 is a clean copy p of Table 5-1 and reflects all proposed Attachment 1 changes.
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i GNRO-99/00058 Page 7 of 7, For questions or comments, please feel free to contact NS&RA at (601) 437-6481. We appreciate the cooperation and attention of the staff on this matter and look forward to
.Lworking with the staff on this change since this change is critical to ongoing organizational improvements planned.
L Yours trul ,
. [0/-
WKH/MJL attachments: 11. 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 l Incorporated l cc: Ms. J. L. Dixon-Herrity, GGNS Senior Resident Mr. N. S. Reynolds Mr. L. J. Smith (Wise Carter)
Mr. H. L; Thomas l
Mr. E. W. Merschoff (w/2)
~ Regional Administrator
- U.S. Nuclear Regulatory Commission l Region IV L
611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011 Mr. S. P. Sekerak, NRR/DLPM/PD IV-1 (w/2)
- U.S. Nuclear Regulatory Commission .
One White Flint North, Mail Stop 13D18
- 11555 Rockville Pike Rockville, MD 20852-2378 Mr. J. N. Donohew, NRR/DRPW/PDIV-1 (w/1)
U.S. Nuclear Regulatory Commission
~ One White Flint North, Mail Stop 13H3 l 11555 Rockville Pike H t Rockville, MD 20852-2378 1
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