ML20217P458
| ML20217P458 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/06/1998 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217P464 | List: |
| References | |
| GNRO-98-00028, GNRO-98-28, NUDOCS 9803100284 | |
| Download: ML20217P458 (52) | |
Text
l h
O Ent:
ritions, Inc.
Por: G oson, MS 39150 Tel 601437-0470 W.K.Hughey v sawy a neysausy March 6,1998 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:
Document Control Desk i
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Proposed Emergency Plan Change - Table 5-1 Change
References:
- 1. GNRO-97/00123 dated December 17,1997 from EOl to NRC, j
i Commitment to Submit an Emergency Plan Change to Reflect Capability of Performing Offsite Dose Assessment Onshift, Related to Emergency Plan Change 28-001-95, GTC-97/00206
- 2. GNRO-97/0008G dated September 5,1997 from EOl to NRC, Additional Information Requested During a Meeting With NRC July 10,1997 Related to Emergency Plan Change 28-001-95 GNRO-98/00028 Gentlemen:
/
The enclosed Emergency Plan changes are hereby submitted for NRC staff review and approval as required by 10CFR 50.54(q) and 50.4. As noted in our September 5,1997 I
i letter, the proposed Emergency Plan changes are necessary to eliminate major sources of l
confusion. The proposed changes also affect Emergency Plan Change 28.001-95 which is currently in the NRC appeal process. As discussed, with the staff during a meeting at NRR p l
on January 23,1998, the proposal also involves other changes to the Emergency Plan which would likely be judged as not requiring NRC approval. Nevertheless, these changes are being included as part of this change request since they are needed to support the other changes included in this package. Some of the key changes in this request include providing the capability to perform onshift dose assessment as a shared function, increasing augmentation times of selected emergency response organization personnel to 120 minutes, increased onshift staffing commitments, sharing of core / thermal hydraulics function with the onshift shift technical advisor, and activation of all emergency response facilities at the Alert level. As previously noted, other changes are included which lllllllll]ll]ll{llllllllll 9803100284 980306
- PDR ADOCK 05000416 F
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March 6,1998 l
GNRO-98/00028 Page 2 of 3 L
l are editorial in nature and are being made to clarify the existing Emergency Plan and to
- ensure consistency with Grand Gulf Technical Specifications.
The proposed changes were evaluated against the criteria of 10CFR50.47,10CFR50, l
Appendix E, and other NRC guidance documents. The increased augmentation times and l.
sharing of functions will not result in any reduction in the capability of the Emergency i
Response Organization to respond to an Emergency. Since the change involves an L
increasing of committed onshift staffing levels and capabilities, the result is a betterment in the protective measures onshift personnel can provide in the event of a radiological emergency. The enclosed proposed changes are adequate in that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency and there is a betterment to the level of public health and safety we can provide. This change has been reviewed and approved by the onsite Plant Safety Review Committee. includes a mark-up of the latest Emergency Plan illustrating the desired l
changes. Attachment 2 provides the justification for each change provided in Attachment 1.
Change criterion codes similar to those used for improved Technical Specifications are included Attachment 2 and are intended to aid the staff during the review process. is a clean copy of Table 5-1 and reflects all proposed Attachment 1 changes.
l is provided at the request of the NRC and describes actual implementation i
plans if the proposed Emergency Plan change is approved. Attachment 5 is a copy of the current Emergency Plan Table 5-1.
l We would be happy to discuss the proposed changesc Please feel free to contact Mr. Kenneth Hughey at (601) 437-6470. We appreciate the cooperation and attention of the staff on this matter.
Yours truly, i
fcP WKH/MJL attachments:
- 1. Mark-Up of Affected Emergency Plan Pages
- 2. Justification for Revision to Emergency Plan Table 5-1
- 3. Proposed Emergency Plan Table 5-1 Mark-Up information incorporated
- 4. How Proposed Emc rgency Plan Table 5-1 Will Be implemented
- 5. Current Emergency Plan Table 5-1 cc:
(See Next Page)
I L
l_ s-March 6,1998 GNRO-98/00028 Page 3 of 3 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 l
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 l
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surrounding the exclusion area which contains residents, the total number and density are
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such that appropriate protective measures could be taken in their behalfin the event of a serious accident. The low population zone for the Grand Gulf Site is the area within a 2-mile radius from the plant.
l l
l 1.28 Media Center - An area designated outside the protected area that provides a location for the media so that communication and information can be disseminated concerning plant conditions and emergency operations.
1.29 Offsite - For accountability purposes it is the area outside the GGNS protected area.
or plume tracking survey purposes it is all areas beyond A15 the SITE BONNDARY.
1.30 Offsite Emergency Coordinator - an individual designated the responsibility for the overall emergency response effort and is the central figure for the emergency organization.
1.31 Onsite - For accountability purposes it is the area within the GGNS A15 n
protected area. For plume tracking survey purposes it is all areas external to the power block out to and including the SITE BOUNDARY.
1.32 Operational - Status of an emergency facility declared by the appropriate facility manager upon determining that the facility is adequately staffed and equipment is setup and available to perform the emergency functions assigned to that facility.
1.33 Operations Support Center (OSC) - Location from which onsite non<ontrol room activities are staged and implemented.
1.34 Pathway - Method by which radiological exposure is received.
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l 1.35 Plan - The Grand Gulf Nuclear Station Emergency Plan.
l l
1.36 Plume Exposure Pathway - The process by which a person receives exposure from direct l
interaction with the products of a radiological release. This includes receiving direct gamma radiation from sources external to the body, both instantaneous and short term due to being in the presence of the products of the release. It also includes direct gamma, beta, and alpha radiation from sources inside the body due to inhalation.
p __
X.XX Plume Tracking Survey - Onsite or offsite surveys performed to support A15 offsite dose assessments which are ultimately used to provide state and local agencies with Protective Action Recommendation.
1.37 Population-at Risk - Those persons for whom protective actions are being or would be taken upon implementation of the plan.
~
1.38 Population Center - A densely populated area with 25,000 or more inhabitants.
1.39 Protective Actions - Those emergency measures taken, either in anticipation of or after a release of radioactive material has occurred, for the purpose of preventing or minimizing radiological exposure to individuals.
1.40 Protective Action Guides (PAGs) - Guidelines for protective action recommendations to state and local agencies based on predetermmed projected radiological dose or dose commitment values to individuals in the general population that warrant protective action in anticipation of or following a release of radioactive material.
1.41 Protected Area - As defined in 10CFR73.2, an area encompassed by physical barriers to which access is controlled for security purposes.
l 1.42 Recovery Action - Those actions taken after the emergency to restore the plant as nearly G
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GG FSAR advice to the control room and communicate with Emergency Operations Facility (EOF)
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personnel regarding plant conditions and actions. Communications are also provided l
with the Control Room, OSC and offsite support agencies.
The TSC area contains approximately 2,250 square feet. The TSC area is large enough to accommodate 25 people, including five NRC personnel, as well as furnishings, data i
displays, plant reference material, and communications equipment. The TSC is located directly above and overlooking the Control Room on the mezzanme level (EL 177') of the control building. The control building which houses the TSC is designed Safety Class
- 3. The control building structure is seismic Category I, and is designed to withstand tomadoes :uxi extreme wind phenomena. The TSC is habitable to the same degree as th i
Control Room for all postulated accident conditions and is served by the Control Room l
ventilation system.
Emergency lighting is powered by the ESF AC buses, with backup emergency lighting provided by battery pack lighting uni *<
l 9 TSC ir r- !rd !c h r*:"-*M 2!
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[j TSC may be activated at any time, and shall be activated at an Alert, Site Area Emergency, or General Emergency declaration. Once activated, the TSC shall become operational within approximately 120 nWutes after declaration of
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any of these emerge $ classifications}During emergencies, the TSC will provide A16 for classincation, accident assessment, notincation, and dose assessment j
functions if these functions are unavailable at the EOF or Backup EOF.
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7.3.3 Emergency Operations Facility (EOF) i The EOF (Figures 7-4 and 7-5) provides a location from which evaluation and coordination of all licensee activities related to an emergency is carried out. The facility provides information to offsite groups, assesses the impact of the emergency offsite and l
provides the necessary support to assist the Emergency Organization.
The location for the EOF is in the Energy Services Center approximately 0.6 miles from j
the GGNS site. Figure 7-6 indicates the location of the EOF in relation to the plant.
The EOF has a protection factor of 50 and its own ventilation system. The EOF contains the key technical personnel of the Emergency Organization. Space and communications l
are provided for federal, State, and local representa%s at the EOF. The EOF provides a base of operation for Offsite Monitoring Teams ano is the central point for the receipt l
of field monitoring data.
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L3 The EOF may be activated at any time, and shall be activated at
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Site Area Emergency, and General Emergency declaration. Once i
activated, the EOF shall be operational approximately 120 minutes aRer M7 (um ch-,)
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Communications are provided to the Control Room, TSC, OSC, EIC, ENMC, State and County Emergency Organizations, Federal Agencies, and other support groups, i
l
GGr P5AR 7.5.4 Fest-Accident Sampling Capahdiry Drough the use of inanDed unsrgency sunpiing manipment,.. -
. and analysis can be perimmed ansas to asses the magnaude of the radiciogical henards associsend with an emergency condhion. yamny, a syman is inusDed a chain samples from the fouowing locations:
a.
RER A and B b.
carasiammat Atmosphere c.
Suppmanion Pool De anWas amadan maniendag tsarns beve the apabinty to determine the asemat of the radioingical hamed in the environment. Environmanal air semplars and portable equipman are available for the inupwing======at in the Said wkhin the 10 mile EPZ:
a.
Beta gnema racission noen the plume and/or ground annanninadan b.
todine annen== inn and annuset ofinhaladon and thymid dose by using air amplars whh iodine speclific artridges and parable and Axed analysers. De tedinique to be used to doesnaine =daiadne annammedana in a radasceive plume is described in Bestguncy Plan Procedue 10-S 01-14. His vshnique aBows the doestminadan of radaiamaa anaavan=dann in the fish widi a i
mishuum dsenemble activity of 1 x 10 uCi/cc in the passace of !--- '- 25 noble gases and background radation.
c.
Weser amepling for inter analysis a seen.......,
- t.. due e laiuid reimase pudeways can also be done by osmas monhadng nuns.
De omise enaman mg anma asp =+-i nom GGNS casia of 2===h-s.
Trauponmion is avausbie using designsend OGNS
- vehicles, whh nortral deployment G
movis 30vu
L3 expected to be within approximately 120 minute)s ollowing notification.
t l
Emergency Plan Procedures have been established that relate the various measured parameters to integrated doses. Provisions have been made for estircig integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides.
7.7 Protective Facilities j
Emergency situations may arise, whether it be man-made or natural causes, which require t.
l that protective action be initiated to assure the safety of personnel. Predetermined procedures l
to be initiated in the event of a fire, tornado, or earthquake are contained within the plant l
operating procedures. An important consideration in the protection of the Grand Gulf personnel is for the immediate removal of those personnel not essential for the control of the plant. Security Personnel would be examples of those required to remain onsite. In the event of an emergency situation, the appropriate notification is made. Upon notification, all personnel onsite should either assume their prearranged emergency responsibilities or should follow instructions given over the PA system. This permits accountability of personnel l
before leaving the site or being assigned to an emergency team.
l l
l 7.8 First Aid and Medical Facilities i
First aid equipment and facilities at Grand Gulf are available to handle a wide range of j
emergency situations from minor first aid to transporting a seriously injured individual to an offsite medical facility. Readily available first aid is provided by Health Physics. First aid kits containing items typically needed to care for minor injuries are located in the following areas:
- a. Control Room
- b. Maintenance Shop
\\b
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i l to GNRO-98/00028 1
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4 i
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l ATTACHMENT 2 JUSTIFICATION FOR REVISION l
l TO EMERGENCY PLAN TABLE 5-1 1
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15
Attachment to 2 GNRO-98/00028 l
TYPE PROPOSAL and JUSTIFICATION FOR CHANGE l
EMERGENCY PLAN CHANGE l
CHANGE CATEGORIES The following categories were established to aid in the review of our proposed Emergency Plan changes. The wording for each category is similar to that used during our successful conversion to Improved Technical Specifications. Each change noted in the marked-up copy (Attachment 1) of the Emergency Plan has been designated w' capital letter followed by a number. The capital letter and number designators are ireyed on it
" lowing pages along with an explanation and justification for each proposed change as shown in r.:hment 1.
l Less Restrictive Requirement - L These changes have been determined to be a decrease in effectiveness of the plan as outlined in l
10CFR50.54(q) and therefore require NRC review and approval. These changes requirejustification and technical basis supporting the conclusion that the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50 continue to be met. These changes most likely are similar l
to those that have been previously accepted by the NRC at other plants.
More Restrictive Requirements - M These changes are more restrictive than the existing Emergency Plan requirements and result in additional requirements beyond those currently specified in the Emergency Plan.
Administrative Changes - A These changes are editorial in nature or involve the reorganization, reformatting, or rewording of I
requirements without affecting technical content of the Emergency Plan.
1 Relocated Requirements - R I
l These changes are relocated within the body of the Emergency Plan. No change is being made to the technical content of the words and the existing requirement is preserved.
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I i
I Attachment to 2 GNRO-98/00028 TYPE PROPOSAL l
and JUSTIFICATION FOR CHANGE l
L1 Proposal:
Combine offsite, onsite, and in-plant radiological surveys and relocate as a new emergency task under the Major Functional Area of Radiation Protection. The new emergency task is:
" Surveys (offsite, onsite, and in-plant surveys on as-needed basis only)." This change involves addition of two extra types of surveys that onshift lips will be capable of performing: onsite and offsite surveys. This change also includes addition of words to this new emergency task stating that surveys will only be performed on an as-needed basis.
Governing Regulations:
10CFR50.54(b)(2). Onshift facility licensee responsibilities for emergency response are l
unambiguously defined, adequate staf6ng to provide initial facility accident response in key j
functional areas is maintained at all times, timely augmentation of response capabilities is j
available....
t 10CFR50.54(b)(9)- Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
10CFR50, Appendix E.IV.B - The means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for i
notification and participation oflocal and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to i
protect health and safety. The emergency action levels shall be based on in-plant conditions l
and instrumentation in addition to onsite and offsite monitoring.
l Justification for Change:
This change involves relocation of onsite, offsite, and in-plant radiological surveys to a newly l
created emergency task called " Surveys (offsite, onsite, and in-plant surveys on as needed l
basis only)" under the Major Functional Area of Radiation Protection (newly renamed and l
discussed in change A5). This change also involves addition of two ext. a types of surveys that onshift 11Ps will be capable of performing: offsite and onsite surveys. As discussed in the L4 change, offsite surveys are not expected to be performed by the onshift 11Ps in the Hrst 120 minutes of an event. As discussed in the M4 change, onshi't IIPs will be expected to perform onsite surveys for the first 120 minutes of an event.
Inclusion of these emergency tasks with the other tasks for the newly renamed Major Functional Area of Radiation Protection is editorial in nature. The proposed grouping of all emergency tasks under the newly renamed Major Functional Area of Radiation Protection are as follows:
e Access Control llP coverage for repair, corrective actions, search and e
t 17
r; Attachment to 2 GNRO-98/00028 TYPE PROPOSAL l
and l
JUSTIFICATION FOR CHANGE rescue /first-aid, and firefighting Personnel monitoring Dosimetry e
l Surveys (offsite, onsite, and in-plant surveys on e
as-needed basis only) l Of the above listing of emergency tasks, there are only three emergency tasks that require significant involvement by onshift 11P personnel. The tasks are IIP coverage, in-plant surveys, and onsite surveys. Further examination of these three tasks indicates that if P coverage and in-plant surveys can be combined since in-plant surveys will only be performed when lip coverage is required (see discussion in L6 change). Minimal involvement is needed by the onshift if Ps for the other emergency tasks of personnel monitoring, dosimetry, access j
control, and offsite surveys. A discussion of thejob tasks requiring minimal involvement by 11P is provided:
Access Control Worker access control is essentially automated since lip work processes have been computerized. Specifically this includes an RWP (radiation work permit) i access control computer system and the Electronic Alarming Dosimeter (EAD) computer system. The RWP access control and EAD computer systems work together to provide a fully integrated system allowing workers to sign-in on their emergency RWP and to self-issue EADs. Both systems have been on-line and used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used by workers. During the log-in process, workers acknowledge their EAD alarm setpoints and that they have read and understand their RWP. In the past, these processes were llP labor intensive tasks and dedicated 11Ps were required to check dose margins, training qualifications, and to ensure workers had read and understood their RWP. Access control is maintained since the worker must obtain an EAD and enter an RWP number into the access control computer system prior to being allowed access into the Controlled Access Area (CAA).
Personnel Monitoring i
Personnel are required to perform a self-frisk whenever they exit any CAA. No llP involvement is necessary during frisking since workers are trained to perform this task without lip supervision. While wearing EADs, workers monitor their i
dose received and in the event that their EAD alarms they are trained to leave the area and immediately contact llP.
18
Attschment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CH ANGE Dosimetry There are two primary types of dosimetry in use at Grand Gulf: TLDs (thermoluminescent dosimeters) and EADs. The TLDs are attached to Security Badges and are self-issued by emergency workers as they pass through Security Island. Security issues TLDs to non-plant workers on an as-needed basis.
Workers self-issue their own EAD whenever they sign-in on their RWP. During worker self-issuance of the EAD, radiation dose and dose alarm setpoints are assigned to the EAJ. The EAD assigned radiation dose and dose rate alarms are automatically assigned from the emergency RWP and are such that workers are precluded from exceeding radiation dose limits while allowing workers to carry out anticipated emergency actions. Worker self-issuance of EADs has eliminated the need for liealth Physicists to physically issue dosimetry. The EAD computer system also verities worker training and dose margins for each entry. In the past, dosimetry issuance was a manual process requiring a number of dedicated liealth Physicists to zero and issue dosimeters (at least three pocket ion chambers per worker), verify worker training, and verify and track radiation dose margins.
Self-Issuance of TLDs and EADs by all onshift emergency workers allows 11Ps to l
focus on more critical emergency tasks such as onsite survey 2 or lip coverage.
Offsite Surveys Offsite monitoring surveys are not needed for the first 120 minutes of an event since onsite surveys are adequate for plume tracking and offsite dose assessment purposes. As discussed with the staffin previous correspondence and meetings, onshift lips are currently required to be able to perform in-plant and onsite radiological surveys in addition to the shared Protective Action (in-plant)
Radiation Protection emergency tasks. Non-performance of offsite surveys by onshift personnel for the first 120 minutes of an event is discussed in further detail in the L4 change.
For the remaining two primary 11P emergency tasks of11P coverage and onsite Surveys the following discussion provides the level ofinvolvement for onshift lips.
11P Coverage
.1P coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter a room to perform ajob. The decision to provide lip coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMS).
l During the initial stages of an accident, all areas of the plant would not be affected by releases of radioactive materials, therefore 11P coverage would not be required for all areas. If11P coverage is deemed necessary, multiple emergency teams can be covered by the onshift ilPs. IfIIP ceverage is not provided, worker protection is ensured since all emergency workers are required to wear EADs I
19
Attachment to 2 GNRO-98/00028 TYPE PROPOSAL f
and JUSTIFICATION FOR CHANGE (which will alarm at preset dose and dose rate setpoints) and due to the installed l
ARMS (which alarm at preset dose rates) located throughout the plant. Using l
ARMS, EADs, and llP coverage when needed is ALARA (as low as is reasonable l
achievable) and complies.vith 10CFR20.1101(b).
l Areas important to safety, for which IIP coverage could be required, are l
instrumented with ARMS. The ARM system is provided to ensure compliance with the personnel radiation protection guidelines of 10CFR20,10CFR50, l
10CFR70, and Regulatory Guides 8.2,8.8 and 8.12 (
Reference:
Grand Gulf Updated Final Safety Analysis Report, Section 12.3.4.1). During an emergency l
condition, these ARM readings are used by onshift lip personnel. Using data l
from these ARM readings, llP can brief emergency workers on expected dose l
rates for areas requiring entry. The ARMS also alarm locally and provide an l
audible and visual warning to workers if dose rate setpoints are exceeded.
Workers are trained to exit areas if an ARM goes into alarm status.11P and Operations personnel monitor these ARMS on a routine basis and during an l
emergency. ARM alarms also enunciate in the control room and provide a continuous indication to shift personnel of any ii. creases of radiation levels in the l
plant during an emergency.
1 A single HP may provide coverage for multiple teams. It is possible, and p!anned, with current Table 5-1 staffing levels, that IIPs would be required to l
provide llP coverage for multiple teams. For multiple team IIP coverage, the IIP l
would escort the emergency workers to the work location, survey the affected l
area, brief the workers, and then remain in radio contact while thejob was in l
progress. The l'P would then be available for other critical emergency tasks as l
listed in Table 5-1.
The requirements of 10CFR20.1101(b) mandate the use of procedures and engineering controls based upon sound radiation protection principles to achieve occupational dose and doses to the public that are ALARA. Using EADs and ARMS is an example of the use of engineering and procedural controls for l
keeping, dose ALARA. Using ARMS is an engineering control that is used instead of sendingjob coverage llPs with every team to verify radiological conditions for rooms which are already being monitored continuously. Workers l-entering the CAA are procedurally required to wear EADs. The EAD provides l
the worker with a continuous status of dose received, work area dose rates, and will alarm at a preset dose or dose rate alarms. Worker use of EADs facilitates l
not sending IIPs into the plant with all teams to provide llP coverage while j
preserving the ALARA concept.
l Onsite Surveys The M4 change discusses the new commitment to provide onsite surveys onshift.
Onsite (plume tracking) surveys can casily be performed by an onshift ilP 20 I
x Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and-JUSTIFICATION FOR CHANGE performing a survey in the affected downwind sectors from the plant and out to the site boundary. This can be accomplished by having the onshift HP conduct a survey within the protected area (fenced in area) or from roads surrounding the plant. The roads are located in close proximity to the plant and do include some offsite areas (areas outside the site boundary). Onsite surveys would take approximately 10-15 minutes to accomplish, and any radioactivity detected above background could be communicated to the proposed onshift offsite dose assessment calculation person (see M3 change) via radio. Radiological surveys in close proximity to the plant are representative of conditions in the plume since Grand Gulfis a ground level release plant as described in the Updated Final Safety Analysis Report (UFSAR). This survey would provide the earliest I
indication of a release. It is important to note that the HP performing this emergency task would be in communication via radio at all times with other ERO personnel. This task would also not be rpected to be a full timejob. Once the onsite survey was complete, the HP could then assist in providing HP coverage as j
determined by the Emergency Director.
]
As-Needed Basis Surveys The Ll change also includes addition of a statement to the newly created emergency task of l
" Surveys" to state that surveys will be performed on as-needed basis only. This statement clarifies that surveys are only performed when needed and are not performed on a continuous basis. Requiring surveys when all plant instrumentation'is operable would not be an effective I
use of HP onshift resources. Plant instrumentation can be used for offsite dose assessment calculations or to determine HP coverage needs. As stated in 10CFR20.1501, surveys should l
only be performed to ensure compliance with regulations and are reasonable. Performance of l
surveys when there is need satisfies this requirement and complies with the ALARA l
considerations of 10CFR20.1101. Addition of this statement provides a clear understanding that surveys are only performed as needed.
==
Conclusion:==
Providing the capability to perform all survey tasks onshift is consistent with the NRC l
position given in 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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e Attachment to 2 GNRO-98/00028 i
TYPE PROPOSAL and l
JUSTIFICATION FOR CH ANGE Precedent
References:
South Texas Froj ct has grouped onsite/offsite surveys into one title. In-plant surveys are not listed in their Table C-1. Two RP technicians perform these two tasks onshin.
L2 Proposal:
A new footnote (g) is being added to allow going below minimum onshin staffing levels listed in Table 5-1 due to unexpected absences for up to 120 minutes Governing Regulations:
10CFR50.47(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...
Justification for Change i
There is no discussion in the Emergency Plan addressing onshift ERO members being absent due to an unexpected condition. This proposed change addresses unusual conditions such as injuries, sickness, or other circumstances in which an employee may have to leave the site unexpectedly and thus cause non-compliance with Table 5-1 onshin staffing levels. The proposed allowance is consistent with ti:e current NRC approved Grand Gulf Technical Specifications (Section 5.2.2.c allows being below minimum staffing as long as immediate 2
actions are taken to fill the position within two hom). Unexpected vacancies will be filled by the immediate call-in of qualified personnel. This change will not be used as a way to circumvent the staffing levels of Table 5-1. This change has been conservatively classified as a less restrictive requirement.
j Precedent
References:
South Texas Project has this allowance.
L3 Proposal:
Change 30 and 60 minute augmentation times for selected positions to 120 minutes.
Governing Regulations:
10CFR50.47(b)(2)- On-shin 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....
22
l Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and l
JUSTIFICATION FOR CHANGE Justification for Change:
Adequate numbers of qualiGed personnel are maintained onshift and available to perform emergency duties in the unlikely event of an accident. The onshift staffing levels will ensure that the capability to assess and classify an accident, perform radiological assessment, communicate with offsite agencies, protect in-plant personnel, take corrective action and protect the health and safety of the public is maintained at all times. The onshift stafHng l
levels in the proposed Table 5-1 provide the capability to perform necessary emergency tasks during the Grst 120 minutes of an event and are consistent with the guidance of NUREG-0654.
I Augmentation of the emergency organization with additional staff at 120 minutes is acceptable since adequate resources are available onshift to respond to and manage emergencies in the short term. The capability to add staffing resources in specific areas of expertise at 120 minutes ensures the capability to manage emergency response in the long term.
The planning basis for NUREG-0654 notes that the overall objective of emergency response plans is to provide dose savings from a spectrum of accidents, and that no single specific j
l accident sequence should be isolated for plan development since accidents may have different j
consequences. Recognizing this guidance, and in the absence of any speciDe accident l
sequences speci6ed for emergency planning purposes, an analysis of the proposed emergency l
response organization stafHng plan was performed using the assumptions from a spectrum of design basis accidents described in the Grand Gulf UFSAR which are considered as envelope
{
situations for response to other less challenging events. The analysis provides an illustration of onshift capability and an evaluation of the plant response capability, therefore providing a framework for consideration of what resources are actually required to respond to a serious plant event.
l The evaluation was performed using the following process to provide a systematic and consistent analytical method:
The analysis uses as initiating conditions, those GGNS Emergency Plan Table 4-2 Design Basis Accidents associated with a Site Area Emergency and General Emergency.
l The UFSAR analysis is used as a description of the event, including any speciGed actions
)
l required of the station staff.
l The minimum station staffis presented along with expected actions, based on Emergency Plan requirements.
Expected actions are evaluated against unacceptable results criteria for determination of acceptability.
Unacceptable results criteria are the standards of performance against which the proposed station stafHng was evaluated. The criteria consist of the following unacceptable results:
Exposure to radiation inconsistent with applicable EPA guidance for emergency workers.
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i Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and l
JUSTIFICATION FOR CHANGE Failure to notif" plant personnel, state and local officials and the NRC in a timely manner, e
Failure to assess and classify the event, assess radiological consequences, and make e
Protective Action Recommendations in a timely manner.
Failure to mitigate the event through operator action and corrective measures in a timely e
manner.
j l
The response of the proposed minimum station staff to design basis accident conditions i
classified as a Site Area Emergency or General Emergency were evaluated. The accidents evaluated were steam sys:em pipe break outside containment, LOCA within the reactor coolant system pressure boundary, feedwater line break outside containment, main condenser offgas system treatment system failure and fuel handling accident outside primary containment. Expected actions for each emergency position or task was evaluated for the first 120 minutes of the accident using the unacceptable results criteria.
I The evaluation of the typical responses to events and anticipated staffing of required tasks indicates that the proposed on-shift staffing levels are adequate to perform all necessary 2
emergency tasks for the first 120 minutes of an event.
[
Even though the Grand Gulf Emergency Plan has been developed to protect public health and l
safety in the event of any type of accident, it should be recognized that the likelihood of an event leading to core damage and a large early release of radioactive material is extremely remote.
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 IE-4/ year for core damage frequency and is also below the goal of I E-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 any appreciable impact on public health and safety within this time frame.
Based on the GGNS PRA analysis, containment failure, if at all, occurs at the earliest at eleven or more hours after the initiating event. Containment bypass scenarios which could potentially result in releases before this time frame have a frequency ofless than 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 i
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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Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE 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.
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 3
public health risk from the operation of the station.
==
Conclusion:==
This change is acceptable based on the discussions above. Changes which increase onshift staffing and provide the capability to perform all critical emergency response tasks onshift 1
support this change. There is no impact on public and safety as result of this proposed change.
Precedent
References:
The following plants have been allowed some type of deviation in response time: Palo Verde, South Texas Project, Davis Besse, Duke Power.
L4 Proposal:
Delay.gmentation of two 30 and two 60 minute Offsite Radiological Survey responders until 120 minutes.
Governing Regulations:
l 10CFR50.47(b)(?)- On-shift facility licensee resnonsibilities for emergency response are unambiguously defined, adequate staffing to provis initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available...
10CFR50.54(b)(9)- Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
Justification for Change:
Augmentation of 30 and 60 minute ofisite radiological survey responders at 120 minutes is acceptable based on the onshift capability to perform onsite (plume tracking) surveys and the fact that there may not be a need to perform plume tracking 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 used for offsite dose assessment calculation purposes.
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Attachment to 2 GNRO-98/00028 l
TYPE PROPOSAL and l
JUSTIFICATION FOR CHANGE l
l Onsite Surveys are Acceptable for First 120 Minutes i
Offsite surveys are not needed for the first 120 minutes of an accident because onsite surveys can be used for ofTsite dose assessment calculations and subsequent protective action recommendations. Onsitel and offsite radiological surveys both have the same purpose; to track and measure the radioactive plume. Both surveys involve performance of radiation surveys and air sampling outside of the plant in affected downwind sectors. Even though the Emergency Plan describes the two surveys, either is sufficient for offsite dose assessment calculations. Other offsite radiological survey tasks such as soil, water, and vegetation sampling or environmental TLD retrieval can be performed when additional augmentation personnel arrive at 120 minutes. These particular samples (soil, water, and vegetation samples or environmental TLDs) are not used as input parameters for offsite dose assessment calculations. These types of radiological survey tasks would be considered in the recovery phase, following an offsite release of radioactive material, and are not needed for the immediate protection of public and safety. Therefore, there is no expectation for onshift personnel to perform these activities in the first 120 minutes of an event. Since onsite surveys i
are adequate for offsite dose assessment calculation purposes, offsite surveys can be delayed I
for 120 minutes. The M4 change discusses the new commitment to provide onsite surveys onshift.
t in-plant Post Accident Effluent Radiation Monitors are Preferred l
Since all expected release pathways are monitored release points onsite (plume tracking) surveys most likely will not be performed during the early phases of an accident. The preferred input for offsite dose assessment calculations is installed post accident effluent l
radiation monitor readings. During the initial time frame (first 15 minutes out to and including the 120 minutes) of an accident, in-plant post accident effluent radiation instrumentation would be used in lieu of onsite survey radiological monitoring data since l
radiological release instrument data is easily obtained. The offsite dose assessment l
calculation software is interfaced with the installed post accident effluent radiation monitors allowing instant transfer of radiation monitoring data into the offsite dose calculation l
software. Using in-plant post accident effluent radiation monitors is an acceptable alternative to field monitoring (onsite surveys) as described in Table 4-1 of our Emergency Plan. The allowance to use in-plant post accident effluent radiation monitors versus field monitoring is also supported by the GGNS Emergency Plan and NUREG-0654, Table B-1 since field monitoring teams are currently not required to be onsite for the first 30 minutes of an l
accident. Use ofin-plant post accident effluent radiation monitors further supports augmentation of offsite radiological surveys until 120 minutes.
' The Grand Gulf site is surrounded by offsite state roads, some of which are located within the site boundary. Onsite (plume tracking) surveys could include a mix of onsite and offsite locations.
Performance of onsite surveys necessitates transversing offsite areas (areas outside the site boundary) in order to get to other onsite survey locations within the site boundary.
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Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and 1
JUSTIFICATION FOR CHANGE
)
==
Conclusion:==
Public health and s.fety is preserved since onsite (plume tracking) survey monitoring or in-plant post accidem ef0uent radiation monitors provide the information necessary for onshift personnel to periorm rapid and accurate offsite dose assessments. The personnel reporting at the new augmentation time of 120 minutes will relieve the onshift lips of all radiological monitoring duties related to plume tracking surveys. The additional survey personnel will allow Geld monitoring beyond the site boundary if needed and the other detailed survey tasks.
Precedent
References:
I Crystal River - No requirement for offsite surveys for Orst two hours of an event at which time the State performs this task. Onsite monitoring survey task (plume tracking) stafHng at 30 and 60 minutes appears to support non-performance ofoffsite surveys for Grst 120 minutes.
Duke Power - Offsite survey task is staffed at 75 minutes. Onsite survey task is not staffed until 45 minutes.
J L5 Proposal:
Stafi the Core / Thermal liydraulics task at 120 minutes instead of current 30 minutes. The M5 change discusses the new commitment for the STA (Shift Technical Advisor) to provide the Core / Thermal llydraulics (CTil) capability onshin.
Governing Regulations:
i 10CFR50.47(b)(2)- On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key l
functional areas is maintained at all times, timely augmentation of response capabilities is available...
Justification for Change:
l The M5 change discusses the new commitment for the STA (Shift Technical Advisor) to provide the CTil capability onshift and supports this change. As discussed in the M5 change, the STA is already required to perform this task onshift as outlined in the GGNS Technical l
Specifications and UFSAR. The STA can adequately handle all technical support and CTil i
tasks for the first 120 minutes of an event. The proposed 120 minute CT11 responder will l
relieve the onshift STA of all CTil responsibilities upon arrival at the site. The L3 change provides justification for the proposed 120 minute augmentation time for other tasks and is consistent with this change.
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Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE
==
Conclusion:==
This change is supported by the M5 change which involves a new commitment to provide the CTIl capability onshift. The analysis supporting the L3 change also supports the conclusion for this change in that the onshift STA can adequately cover the CTil and technical support tasks for the first 120 minutes of an event. With the onshift capability commitment and based on our evaluation that the STA can provide both the CTil and technical support tasks for the first 120 minutes, the extended time for dedicated CTli responders is acceptable.
Precedent
References:
Davis Besse - No onshift requirement for this task. Allowed to staff at 60 minutes.
q Duke Power (Oconee)- Onshift STA performs this duty for first 75 minutes.
South Texas Project - No onshift requirement. Allowed 75 minute staffing for nuclear engineer.
Palo Verde - Allowed 120 minute staffing for Reactor Analyst.
1 L6 Proposal:
1 Augment the In-plant survey task at 120 minutes versus current 30 and 60 minute times.
Governing Regulations:
10CFR50.47(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..
Justification for Change:
Currently the task ofin-plant surveys is an onshift task which is augmented by one additional person at 30 minutes and one more person at 60 minutes. Ilowever, as discussed in the L1 j
change, in-plant surveys are a part ofIIP coverage. Augmentation of this task at 120 minutes isjustified for the following reasons:
In-plant Surveys Performed on As-Needed Basis In-plant surveys are performed on an as-needed basis and whenever the two onshift ilPs provide IIP coverage. iip coverage in-plant surveys will only be performed if radiological conditions cannot be determined by using in-plant instrumentation or if the job to be performed necessitates a survey.
l 28
I j
Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE In-Plant Areas are instrumented with Area Radiation Monitors In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency thereby reducing the need to send IIPs into the plant to obtain radiological data. In-plant safety-related areas that may require entry during an emergency are monitored with area radiation monitors (ARMS). The Area Radiation Monitoring system is provided to ensure compliance with the personnel radiation protection guidelines of 10CFR20,10CFR50,10CFR70, and NRC Regulatory Guides 8.2,8.8 and 8.12 (
Reference:
Updated Final Safety Analysis Report Section 12.3.4.1). NRC Regulatory Guide 8.8 (Rev. 3,1978), "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable" states:
" Central or ' built-in' monitoring systems that give information on the dose rate and q
concentration of airborne radioactive material in selected station areas can reduce the exposure of station personnel who would be required to enter areas to obtain the data if such systems were not provided. These systems also can provide timely information regarding changes in the dose rate or concentrations of airborne radioactive in the areas."
Sending 11Ps into plant areas with existing radiation monitoring systems would not be an effective use of11P resources. The radiological monitoring systems ensure that both IIP and ERO menibers are kept informed of current and changing radiological conditions. Using these systems is more efficient than requiring an 11P to enter the plant to perform surveys. IIP in-plant surveys would provide an indication of current radiological conditions but could become inaccurate very quickly as plant conditions changed. In-plant radiological instrumentation provides a continuous radiological status of the rooms monitored along with providing local and control room alarms. Performing in-plant surveys in rooms that are instrumented with radiological monitoring systems is contrary to NRC staff guidance in Regulatory Guide 8.8. Installed radiological monitoring systems avoid the need to send IIP personnel into the plant to collect radiological data. Avoiding unnecessary surveys by using in-plant ARMS satisfies the requirements of 10CFR20.1101(b) since occupational radiation exposure is kept ALARA.
In-plant Surveys are Considered ilP Coverage Surveys In-plant surveys are performed whenever lip coverage is performed. Separate lips are not sent into the plant to perform in-plant surveys prior to sending emergency teams inio the plant to perform jobs. In-plant surveys are not considered as a separate and distinct task from that j
ofIIP coverage as listed in Table 5-1 of the Emergency Plan. If the radiological status of a l
room is unknown, and emergency workers must enter a room to perform ajob, ajob coverage l
lip would be dispatched to the location. An in-plant survey would then be performed as a part of the normal 11P coverage duties.
29
g Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE
==
Conclusion:==
l l
10CFR20.1101(b) mandates the use of procedures, engineering controls, and sound radiation protection principles to achieve occupational doses that are ALARA. Performing in-plant surveys on as-needed basis in combination with HP coverage and use ofin-plant radiation l
monitoring instrumentation supports this change. The 30 and 60 minute HP augmentation l
time extension to the proposed 120 minute time is appropriate since it is the time when the
)
l majority of the ERO staff will be onsite. This change is acceptable since adequate accident l
response in key functional areas is maintained onshift.
1 Precedent
References:
I South Texas Project - Does not list in-plant surveys in their Emergency Plan Table C-l.
I Davis Besse - Does not list in-plant surveys in their Emergency Plan Table 5-1. One RP technician required onshift.
i Duke (Oconee)- No onshift in-plant survey task is required as listed in Figure B-8.
L7 Proposal:
Footnote (d) is reworded to allow the ability to use personnel trained to perform specific radiation protection emergency tasks instead of current prescriptive words. This footnote will be applied to the total staffing number for radiation protection personnel reporting in the 120 minute interval. This change is deemed less restrictive since the allowance will now be applied to.more emergency tasks.
1 Governing Regulations:
10CFR50.47(b)(15)- Radiological emergency response training is provided to those who may be called en to assist in an emergency.
Justification for Change:
J This change allows emergency task trained personnel to Gil the proposed 17.0 minute augmentation radiation protection emergency response positions. This change is necessary to allow 120 minute augmenting ERO staff personnel to perform specific 11ealth Physics emergency tasks (for exacuple, onsite, in-plant, and offsite surveys) as long as the individual has been trained to perform ilie specific task. Worker control and prescription of radiological protective requirements will only be performed by fully qualified 11ealth Physicists. Table 5-I currently allows personnel other that 11ealth Physicists to perform the emergency task of Offsite Monitoring. This change is a continuation of that allowance. Onshift radiation protection personnel are unaffected by this change and will continue to be qualified to perform all emergency tasks listed in Table 5-1 for the Radiation Protection function.
30 l
r Attichment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE 1
l
==
Conclusion:==
l This change is acceptable based on compliance with the training requirements of 10CFR50.47. It is also acceptable since onshift radiation protection personnel will continue to be quali6ed to perform all emergency tasks outlined for the major functional area of Radiation Protection in the Table 5-1.
L8 Proposal:
Staff a dedicated Offsite Dose Assessment person at 120 minutes versus current 30 minute allowance.
Governing Regulations:
10CFR50.47(b)(2)- On-shift facility licensee responsibilities for emergency response are unambiguously denned, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is j
available....
Justification for Change:
l As outlined in the M3 change, the capability to perform offsite dose assessment calculations will be provided onshift. Augmentation at 120 minutes is acceptable since ofTsite dose assessment calculations are easily performed by onshift personnel for the first 120 minutes of an accident. 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 i
on demand and as necessary to provide protective action recommendations. The proposed 120 minute responder will relieve the onshift offsite dose assessment person of all dose assessment duties.
==
Conclusion:==
This change is acceptable based on onshift capability and technological improvements.
Providing the offsite dose assessment calculation task at all times, as outlined in the M3 change, is a betterment than the currently allowed 30 minute staffing time. The case of performance of calculations supports the 120 minute responder staffing time since offsite dose calculations can easily be performed by onshift personnel for the first 120 minutes of an acciderh.
31
l l
l Attachment to 2 GNRO-98/00028 y
TYPE PROPOSAL and JUSTIFICATION FOR CHANGE M1 Proposal:
Increase onshift communicator stamng number from one to two and eliminate the 30 minute responder.
Justification for Change:
This change is acceptable since it increases the onshin minimum number from one to two.
The net result is a betterment of onshift emergency preparedness. The current requirement is one communicator onshift. Increasing communicator stamng levels is necessary to support the proposed augmented stamng time of 120 minutes.
M2 Proposal:
Assign a Repair and Corrective Action Radwaste Operator (RWO) as an onshift position.
Footnote (b) is added to allow personnel assigned other duties to perform this task.
Justification for Change:
This change increases the commitment for the Repair and Corrective Action Radwaste Operator by requiring this capability onshift. The current Table 5-1 requirement is to staff this position at 60 minutes. Assigning the Radwaste Operator as an onshift capable position will result in an overall increase in emergency preparedness and is similar to having the offsite dose assessment capability onshift as discussed in EPPOS-3. Footnote (b) allows the onshift RWO to perform other duties such as communicator or allows other repair and corrective action personnel to fill the RWO position as directed by the Emergency Director.
At 120 minutes the onshift Radwaste Operator becomes dedicated specifically to repair and corrective actions. This change is acceptable since it results in an improvement of overall shift emergency preparedness capabilities. It also supports the proposed augmented stamng time of 120 minutes.
M3 Proposal:
Reassign the 30 minute Offsite Dose Assessment task as an onshift capability position.
Footnote (b) is applied to this newly created onshift position to allow onshift personnel assigned other duties to perform this task. As discussed in the L8 change, the onshift offsite dose assessment calculation person responsible for performance of this task will be relieved of this task at 120 minutes.
i f
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32
I l
Attachment to 2 GNRO-98/00028 i
TYPE PROPOSAL and JUSTIFICATION FOR CHANGE Justification for Change:
This change is an increase in commitment beyond what is currently specined in the GGNS Emergency Plan and is speci6ed by the NRC (EPPOS-3, " Emergency Preparedness Position (EPPOS) On Requirement For Onshift Dose Assessment Capability"). In EPPOS-3, the NRC requested that licensees provide the capability to perform the offsite dose assessment task onshin. Footnote (b) is added to provide an allowance for onshift personnel assigned other duties (EPPOS-3 lists STA, lip, chemist, operators, etc.) to perform the offsite dose assessment emergency task. This footnote is necessary to ensure personnel are not precluded from performance of other critical emergency tasks as directed by the Emergency Director.
EPPOS-3 supports the Footnote (b) allowance since the NRC has stated:
"There may be events where the on-shift personnel responsible for performing i
dose assessments are needed to perform actions critical to mitigating the event and are therefore unavailable to immediately perform a dose assessment. This situation is acceptable because licensees are expected to inform the public of the event classification and initial recommended protective actions based upon plant conditions. However, licensees need to have the capability to perform dose assessments on shift and should perform the dose assessments as soon as practicable when conditions warrant that an assessment be performed."
If onshift personnel responsible for offsite dose assessment calculations are needed to perform actions critical to mitigating the event, classifications and initial protective action recommendations (PARS) will be based on plant conditions. Dedicated onshift personnel are not necessary for this task since offsite dose assessment calculation software and computerization allows performance of these calculations in minutes and on demand as needed to support protective action recommendations. This change is acceptable since it results in improved onshift offsite dose assessment capabilities and meets the intent of EPPOS-3. It also supports the proposed augmented staf6ng time of 120 minutes.
M4 Proposal:
Increase onshift Onsite Radiological Survey (out of plant) staffing from zero to one by relocating the 30 minute responder to the onshift column in Table 5-1.
Justification for Change:
As stated in the December 9,1997 letter to the NRC, one onshift ifP currently provides twenty-four hour coverage for this task. This change is a reflection of this practice, however, it is viewed as increasing in commitment. Currently, there is no onshift onsite radiological survey requirement. As described in the Ll change, this task will be listed under the newly renamed Major Functional Area of Radiation Protection with the newly created emergency l_
task of surveys. The Ll change providesjustificatioa to combine this task with the newly created Radiation Protection emergency task of " Surveys." This change is acceptable since it f
33
T Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE improves the shift capability for onsite surveys and results in a betterment in onshift emergency preparedness. It also supports the proposed augmented stamng time of 120 minutes.
l MS Proposal:
Add the words "and Core / Thermal liydraulics" to the Emergency Task " Technical Support" in Table 5-1 to allow the onshift STA to provide the Core / Thermal 11ydraulics (CTil) capability onshift.
Justification for Change:
J Neither Table 5-1 of the Emergency Plan and NRC guidance in NUREG-0654 required the capability to perform the emergency task of CTil onshift. liowever, the onshin STA is assigned and committed to the task of CTil as outlined in the Technical Specifications (TS)
I and the Updated Final Safety Analysis Report. Activation of the Emergency Plan does not exempt the onshift STA from providing this task. This change provides an increase in committed onshift capability as outlined in Table 5-1 by reflecting NRC approved words in the TS. The existing wording in Table 5-1 of the Emergency Plan could imply that the onshin j
STA is precluded from providing any CTli guidance to the Emergency Director. This interpretation would be contrary to the TS. This change avoids confusion of the stamng time and requirements for the CTli task. This change is acceptable since it increases Emergency Plan effectiveness by committing to expanded Table 5-1 onshift capabilities.
It should be noted that the L5 change will require that a dedicated CT11 person respond at 120 minutes and relieve the STA of all CT11 duties. This change supports the proposed augmented stamng time of 120 minutes. The L5 change providesjustification for the proposed 120 minute augmentation time for this task and also supports this change.
M6 Proposal:
Delete footr.ote (b) from the Mechanical and Electrical Maintenance onshift staffing number.
Assign 30 minute I&C Maintenance responder as an onshift position.
Justification for Change:
Deleting footnote (b) from the Mechanical and Electrical Maintenance onshift staffing numbers results in dedicated onshin positions. Reassigning the 30 minute I&C Maintenance responder to the onshin column is considered an increase in effectiveness. These changes are acceptable since they result in an improvement of onshift capabilities by requiring dedicated staffing of these key functional areas and increasing I&C maintenance onshift stamng. These changes support the proposed augmented staffing time of 120 minutes.
34
j Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE M7 Proposal:
l
. Add a requirement to activate the Emergency Operations Facility (EOF) at an A!ert in Section 7.3.3, paragraph 3 of the Emergency Plan.
I Justification for Change:
1 Activation of the EOF at an Alert is consistent with other emergency facility activation. This change is a betterment of Emergency Preparedness since prior to this change the EOF only
)
l had to be activated at the General and Site Area Emergency. The TSC and OSC are currently activated at an Alert, General Emergency, and Site Area Emcrgency. This change is acceptable since it improves the response to an emergency due to the proposed earlier activation level of the EOF than what was previously allowed. Activation of the EOF at an Alert ensures that emergency personnel are readily available to respond to a change in plant i
conditions and to provide support as required that is consistent with OSC and TSC activation times. This change supports the proposed augmented staffing time of 120 minutes.
l l
l l
l l
l 35
F f
Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE Al Proposal:
Eliminate footnote (b) from Shift Superintendent.
Justification for Change:
The R4 change allows this change since the reorganization of Table 5-1 information eliminates the need to list the footnote (b) with the Shift Superintendent.
l A2 Proposal:
Change Position Title or Expertise for Notification / Communication function from current
(
words " Operator / Plant Systems Engineer / Engineering Techniciad' to " Communicator."
l Justification for Change:
l The current words are too prescriptive and do not reflect either a required title or expertise for this task. It could be interpreted to limit filling this position to only those personnel who have l
the titles currently listed in Table 5-1. The current wording is not used in NUREG-0654, Table B-1. This change better describes the minimum qualification to perform the ftmetion of l
l communicator without imposing any restrictions on who can fill the function. Individuals assigned this function will be trained to perform the function.
A3 Proposal:
Change Position Title or Expertise for Offsite Dose Assessment task from the current words l
" Health Physics Supervisor" to the new words of" Radiological Assessment."
Justification for Change:
The current words are too prescriptive and clearly reflect a title. This could limit filling this pasition to only those personnel who have the titles currently listed in Table 5-1. Literal l
interpretation with the current wording could imply that only Health Physics Supervisors l
should perform the offsite dose assessment task. This change reflects a required area of I
expertise and allows personnel with backgrounds in areas such as HP, chemistry, engineering, or operations to perform this emergency task (
Reference:
EPPOS-3). Individuals assigned this emergency task will be trained to perform this task.
I 36 I
l
D Att:chment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CIIANGE l
A4 Proposal:
Delcte the words, "Other as Designated (d)", from position title or expertise t'or offsite radiological surveys.
Justification for Change:
These words are being deleted from the Position Title of Expertise for this task due to the L7 change. The L7 change addresses expanded application of footnote (d).
A5 Proposal:
Rename Major Functional Area " Protective Actions (in-plant) Radiation Protectiod'as
" Radiation Protection."
Justification for Change:
This change is editorial in nature and facilitates grouping of all Radiation Protection emergency tasks (see Ll change) under one Major Functional Area. The total number of dedicated on-shift personnel capable of performing these tasks has not decreased. This change also helps eliminate confusion by avoiding the use of the sharing function footnote (b)
(see A6 change). This change allows consolidation of all Radiation Protection emergency tasks under this newly renamed Major Functional Area.
A6 Proposal:
Delete footnote (b) from orishift staffing number for the newly renamed Major Functional area of Radiation Protection.
Justification for Change:
Reorganization of Table 5-1 no longer requires this function to be shown as a footnote (b).
The Ll change supports removal of this footnote.
A7 Proposal:
Rename Emergency Task " EOF Director" as " EOF Direction and Control."
Justification for Change:
Current words are not an emergency task description (they are m, re a position identifier).
I l
37 l
l
l f
Attachment to 2 GNRO-98/00028
)
TYPE PROPOSAL and JUSTIFICATION FOR CHANGE The change is necessary to ensure descriptions of emergency tasks listed in Table 5-1 are consistent.
A8 Proposal:
Add a footnote (h) to newly renamed emergency task of" Emergency Direction and Control" to state that the Shift Superintendent (SRO) is relieved of this task at 120 minutes and upon relief the Shift Superir tendent (SRO) resumes plant operational duties.
Justification for Change:
The current Table 5-1 words imply that two persons would be assigned this task once all facilities are staffed. The relief allowance is discussed in NUREG-0654 and is also described in Section 5 of our Emergency Plan. During the initial stages of an accident, the Shift Superintendent (SRO) is responsible for Emergency Direction and Control (ED&C). The On-Call Manager assumes this duty aner the TSC is operational, which then allows the Shift Superintendent (SRO) to perform other operational emergency duties. Addition of the footnote (h) to the newly renamed emergency task of" Emergency Direction and Control" (see R1 change) clarifies that the Shin Superintendent is relieved of the ED&C task by the augmenting personnel. It also ensures that there is an understanding that the Shift Superintendent (SRO) resumes plant operational duties once relieved of ED&C duties.
A9 Proposal:
Rename the current Position Title or Expertise for the Major Functional Area of Rescue /First Aid from the current words " Shift Personnel (i.e., Computer Support, Maintenance)" to the new words of" Rescue and First Aid." Assign a reporting lxation (OSC) for this function.
Justincation for Change:
The current words are too prescriptive and could limit filling this position to only those personnel who have the titics currently listed in Table 5-1. NUREG-0654 does not describe expertise requirements for this Major Functional Area. This change reflects the minimum qualifications necessary to perform the function without imposing any restrictions on who can fill the function. Individuals assigned this function will be adequately trained to perform this function. Assigning this function to the OSC is a reflection of current practice and this change is necessary to add clarity to the Emergency Plan.
c j
4 l
f 1
38
1 P
c Att:chment to 2 GNRO-98/00028 TYPE
- PROPOSA1, and JUSTIFICATION FOR CHANGE A10 Proposal:
Add words "Provided by Claiborne County / Port Gibson" to the Capability for Additions for the Major Functional Area of Rescue /First aid.
Justification for Change:
Words are currently listed in current Table 5-1. The R3 change necessitated this addition.
All Proposal:
Rename Position Title or Expertise change for "OEC" to " Senior Manager."
Justification for Change:
This change clarifies the level of expertise needed for this position which has always been a senior manager and is consitent with NUREG-0654.
A12 Proposal:
Add allowance for engineers to reside in either the OSC or TSC.
Justification for Change:
This change allows flexibility from current prescriptive words. NUREG-0654 is silent on reporting locations for thue engineers.
A13 Proposal:
Add footnote (f) to the ne wly created emergency task (see M5 change) of " Technical Support and Core / Thermal liydraulics" which will state " Core / Thermal Hydraulics is part of normal STA duties as listed in the Updated Final Safety Analysis Report and Technical Specifications" Justification for Change:
This change involves the addition information that is already provided in the TS and UFSAR.
No new requirements are added. Adding information ensures that personnel are aware that the STA must perform the core / thermal hydraulics task as part of their normal onshift duties.
This change supports the change to recognize that the STA can perform this task as described in the M5 change.
39 j
g Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and l
JUSTIFICATION FOR CHANGE A14 Proposal:
This change renames the emergency task words of" Electrical" and " Mechanical" to
" Technical Support." His change also involves deletion of the words " Plant Systems" from
" Engineer" and addition of the words " Electrical" and " Mechanical" to the " Engineer" word.
Justification for Change:
This change is editorial in nature and states exactly what tasks the Plant System Engineering provides. The current wording (plant systems) is a repeat of wording that is already described for this Major Functional Area, but which was assigned to the STA and was proposed f,r relocation (see R5 change). This change is consistent with the wording described in NUREG-0654. Table B-1. This change provides a better description of the emergency task and required expertise than current words.
AIS Proposal:
Add new definitions to Section 1.0 of the Emergency Plan for clarification purposes.
Justification for Change:
During preparation of the Ll change to Table 5-1, it was determined that it would be prudent to either revise or add new definitions to Section 1.0 of the Emergency Plan to ensure a clear understanding of key terms related to surveys. The new definitions are italicized as follows:
Offsite - For accountability purposes it is the area outside the GGNS protected area. For e
plume tracking surveypurposes it is allareas beyvnd the SITE BOUNDARY Onsite - For accountability purposes it is the area within the GGNS protected area. For e
plume tracking surveypurposes it is allareas external to thepower block out to and including the SITEBOUNDARY.
Plume Tracking Survey - Onsite or ofsite surveys performed to support ofsite dose msessments which are ultimately usedtoprovide state andlocal agencies with Protective Action Recommendations.
These definitions do not impose any new requirements or commitments and arejustified since they provide clarification to the Emergency Plan A16 Proposal:
This change provides clarifying information of specific functions that the TSC performs in the event of the unavailability of the EOF or Backup EOF.
40
p Attichment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE Justification for Change:
This change is necessary because the TSC has limitations on space, HVAC capacity, and location within the restricted area that render it unsuitable for the support of additional State, Local, Licensee, and Federal personnel beyond for which it is currently designed to support.
This information provides clari6 cation and does not impose any new requirements or commitments.
A17 Proposal:
Add allowance for Notification / Communication function to be performed in the EOF.
Justification for Change:
With the EOF being activated at the alert (see M7 change), this function will be directly transferred from the control room to the EOF. The TSC will still retain this capability.
AIS Proposal:
Add allowance for offsite dose assessment to be performed in the CR or EOF.
Justification for Change:
Allows performance of these functions in any of these facilities.
i 1
41
1 j
Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE R1 Proposal:
Relocate Major Functional Area of"Em:rgency Direction and Control" to the Emergency Tasks area for the Major Functional Area ofPlant Operations and Assessment of Operational Aspects.
Justification for Change:
This change allows combining of the two Shift Superintendent functions since the Plant Operations and Assessment and Operational Aspects Shift Superintendent and Emergency Direction and Control Shift Superintendent are one in the same. This change also allows elimination of footnote (b) currently assigned to the staffing number for the Emergency Direction and Control Shift Superintendent number as discussed in Al change.
R2 Proposal:
Relocates the "On-call Manager (Emergency Director)" by listing it under the Shift Superintendent in Table 5-1. This change also involves deletion of the "(Emergency Director)" from the "On-call Menager" title words.
Justification for Change:
The Rl change provides a discussion related to this change and facilitates relocation of the On-call Manager (Emergency Director). The R1 change also allows the deletion of
"(Emergency Diiector)" words which if kept would be a repeat of the words included in the relocated words discussed in the R1 change.
R3 Proposal:
Relocates Major Functional Area of Firelighting as an Emergency Task under the Major Functional Area of Plant Operations and Assessment of Operational Aspects.
Justification for Change:
This change involves grouping of this function with the Major Functional area for which it is associated; Plant Operations. This change is desired for clarity purposes and reflects current practice.
42
O Attachment to 2 GNRO-98/00028 TYPE PROPOSAL and JUSTIFICATION FOR CHANGE R4 Proposal:
Relocates the Emergency Direction and Control " Shift Superintendent" to the Major Functional Area of Plant Operations and Assessment of Operational Aspects.
Justification for Change:
Change facilitates removal of footnote (b)(see Al change) from the Shin Superintendent and climinates duplication of entries assigned to the Shift Superintendent in Table 5-1. The R1 change allows this change since both of these Shin Superintendents are one in the same. This change is also supported by change A8, which clarifies that the Shift Superintendent is relieved of this function once the TSC is operational.
R5 Proposal:
Relocate emergency tasks " Technical Support" and "Coreffhermal Hydraulics" to the Major Functional Area of Plant Operations and Assessment of Operational Aspects emergency tasks section.
Justification for Change:
This change preserves the task by grouping it with the Major Functional area for which it is associated; Plant Operations. This change is desired for clarity purposes and reflects current practice.
1 R6 Proposal:
Relocates the "firefighting communications" task from Major Functional area of Security to i
the newly created Emergency Task of Firefighting (see R3 change).
Justification for Change:
These emergency tasks are assigned to operations personnel who are responsible for all firefighting activities. Security does not provide any firefighting communication support.
This change preserves the emergency tasks by grouping the wording with the appropriate emergency task.
43
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