ML20209G479

Forwards Proposed Emergency Plan Change as Addendum to Changes Previously Submitted Via GNRO-98/00028 & GNRO-99/00007,for NRC Review & Approval

ML20209G479
Person / Time
Site:	Grand Gulf
Issue date:	07/15/1999
From:	Hughey W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20209G483	List: ML20209G479
References
GNRO-99-00058, GNRO-99-58, NUDOCS 9907190174
Download: ML20209G479 (7)

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

-/

9907190174 990715 PDR F

ADOCK 05000416 PDR .

4 ^7 ') ) l <

_J L=

~ ,

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.

• Capately. as h"aaad in EPPoS-3,11/W95 FINAL EMERGENCY PREPAREDNESS PoSmoN (EPPoS) oN oNSHIFT DOSE ASSESSMENT.

• 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;  ;

i, .

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.

i

- 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.

I

~~

n. , , .

u .

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.

)

p

't .

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

Li