ML22011A298

ANS Evaluation Report

ML22011A298
Person / Time
Site:	Grand Gulf
Issue date:	01/11/2022
From:	Hardy J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22011A297	List: ML22011A298
References
GNRO2022/00001
Download: ML22011A298 (11)

Text

-===-Entergy Entergy Operations, Inc.

P.O. Box 756 Port Gibson, Mississippi 39150 Jeffery A. Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station Tel: 601-437-2103 GNRO2022/00001 10 CFR 50.54(q)(5)

January 11, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Grand Gulf Nuclear Station Unit1, ANS Evaluation Report Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 In accordance with 10CFR50 50.54(q)(5) and 10CFR72.44(f), Entergy Operations Inc. (Entergy) hereby submits Grand Gulf Nuclear Station Unit 1, (GGNS) ANS (Alert and Notification System)

Evaluation Report (dated March 15, 2021 ), including a summary and analysis of the changes, which became effective December 15, 2021.

The changes to the GGNS ANS Evaluation System were evaluated by Entergy and determined to not reduce the effectiveness of the plan. Attachment 1 contains the Summary and Analysis of the GGNS ANS Evaluation Report. Attachment 2 contains the GGNS ANS Evaluation Report.

This letter contains no new commitments.

If you have any questions concerning this submittal, please contact Mr. Mike Lewis, Manager Emergency Planning, at (601) 437-2166.

GNRO-2022/00001 Page 2 of 2 Sincerely, J~ -~

JAH/rm Attachments: 1. Summary and Analysis of the Grand Gulf Nuclear Station Unit 1, ANS Evaluation Report

2. Grand Gulf Nuclear Station Unit 1, ANS Evaluation Report cc:

NRC Region IV - Regional Administrator NRC Senior Resident Inspector, Grand Gulf Nuclear Station State Health Officer, Mississippi Department of Health NRR Project Manager Director, Division of Spent Fuel Storage & Transportation, Office of Nuclear

Attachment 1 GNRO2022/00001 Summary and Analysis of the Grand Gulf Nuclear Station Unit 1, ANS Evaluation Report

Attachment 2 Page 1 of 4 1 0CFR50.54(Q}(3} Screening Procedure/Document Number: Revision:0 ENTANSERGGN201217 Equipment/Facility/Other: ANS sirens and Control System

Title:

ANS Evaluation Report Grand Gulf Nuclear Part I. Description of Activity Being Reviewed This is a totally new report written to capture a new siren and activation system.

YES ~ NO Part II. Activity Previously Reviewed? 50.54(q)(3) Continue to Evaluation is next part Is this activity fully bounded by an NRC approved 10CFRS0.90 submittal or NOT required.

Alert and Notification System Design Report? Enter justification below and If YES, identify bounding source document number/approval reference and complete Part ensure the basis for concluding the source document fully bounds the VI.

proposed change is documented below:

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

N/A APPLICABILITY CONCLUSION If there are no other controlling change processes, continue the 10CFR50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 10CFRS0.54( q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 10CFR50.54(q)(3)

Evaluation is NOT required. Identify controllinQ chanQe processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 1 OCFR50.54( q)

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Attachment 2 Page 2 of 4 10CFR50.54(Q)(3) Screening Procedure/Document Number: Revision:0 ENT ANSERGGN201217 Equipment/Facility/Other: ANS sirens and Control System

Title:

ANS Evaluation Report Grand Gulf Nuclear Part IV. Editorial Change YES ~NO 50.54(q)(3) Continue to Evaluation is next part Is this activity an editorial or typographical change such as formatting, paragraph NOT required.

numbering, spelling, or punctuation that does not change intent? Enter justification Justification: and continue to next part or complete Part VI as applicable.

Part V. Emergency Planning Element/Function Screen (Associated 10CFR50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1]

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2]

4. The process for timely augmentation of onshift staff is established and maintained. [2]

5. Arrangements for requesting and using off site assistance have been made. [3]

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3]

7. A standard scheme of emergency classification and action levels is in use. [4]

8. Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt ~

instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and ~

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6]

13. Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7]

15. Adequate facilities are maintained to support emergency response. [8]

16. Adequate equipment is maintained to support emergency response. [8]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9]

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Attachment 2 Page 3 of 4 10CFR50.54(Q)(3) Screening Procedure/Document Number: Revision:0 ENTANSERGGN201217 Equipment/Facility/Other: ANS sirens and Control System

Title:

ANS Evaluation Report Grand Gulf Nuclear

18. A range of public PARs is available for implementation during emergencies. [10]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 0]

20. A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.[10]

21. The resources for controlling radiological exposures for emergency workers are established. [11]

22. Arrangements are made for medical services for contaminated, injured individuals. [12]

23. Plans for recovery and reentry are developed. [13]

24. A drill and exercise program (including radiological, medical, health physics and other program areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14]

27. Training is provided to emergency responders. [15]

28. Responsibility for emergency plan development and review is established. [16]

29. Planners responsible for emergency plan development and maintenance are properly trained. [16]

APPLICABILITY CONCLUSION If no Part V criteria are checked, a 10CFRS0.54( q)(3) Evaluation i s ~ required; document the basis for conclusion below and complete Part VI.

C&I If any Part V criteria are checked, complete Part VI and perform a 10CFRS0.54( q)(3) Evaluation.

BASIS FOR CONCLUSION This 50.54(q)3 screening is for a complete change of the Alert Notification System (ANS) and an entirely new ANS Evaluation Report. Screening has determined that Planning Standard 10 CFR 50.47(b)[5] is potentially affected by this change.

A 10 CFR 50.54q(3) evaluation will be performed on this change to determine whether the effectiveness of the emergency plan is reduced and prior NRC approval is required.

EN-EP-305 R00B

Attachment 2 Page 4 of 4 10CFR50.54(Q)(3) Screening Procedure/Document Number: Revision:0 ENT ANSERGGN201217 Equipment/Facility/Other: ANS sirens and Control System

Title:

ANS Evaluation Report Grand Gulf Nuclear Part VI. Signatures:

Preparer Name (Print) s.IdPreparer ney N Signature Digidy signed by S ,dnoy N Reeves, DN:cn=SidnoyNReev05, ,

ozGntnd GJf Nudoar Station.

..us, Date:

Sidney Reeves Reeves, 111 O<PEmergency flannlng emal=sreavo1Qen1Brgy.com Reason: 5054 preparer Dele. 2021.12.0215:21 .50-otl'OO' (Optional) Reviewer Name (Print) Reviewer Signature Date:

Digitally signed by Dennis M. Coulter Dennis Coulter Dennis M. Coulter Date: 2021.12.04 11 :31 :59 -06 '00' Reviewer Name ( Print) Reviewer Signature Date:

Dlgilally signed by Anlhony J . Ringgold Anthony J. ON: cn=Anlhony J. Ringgold, c:US ,

o=Enlorgy, ou=S nior Prcj ct Manag r ,

Nucl ar, rna1 = ar1nggo@enlllrgy. com R*ason: I attest to the accuracy and Nuclear EP Project Manager Rin~:mold lnlegrily or lhl* document Dall: 2021 .12.05 05:1g 50 *0Cl'OO' Approver Name (Print) AnnrnvAr ~innature Date:

Michael Lewis Emergency Planning Manager or designee

(!/ /IIA45 2021.12.06 09:33:04 -06'00' EN-EP-305 R00B

Attachment 3 Page 1 of 4 10CFR50.54{Q){3) Evaluation Procedure/Document Number: Revision:0 ENT ANSERGGN201217 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

ANS Evaluation Report Grand Gulf Nuclear Part I. Description of Proposed Change:

This is a totally new report written to capture a new siren and activation system.

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Adobe Search Engine - GGNS Emergency Plan, EAL Technical Bases, UFSAR, & TRM Bases-" Keywords:

Alert Notification System, ANS, Siren.

Historical review of all available copies of the Grand Gulf Emergency Plan and ANS reports were conducted back to Rev 0. This change does not change the meaning or intent of any portion of the E-Plan.

Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

10 CFR 50.47[b](5); Admjpjstratjye aod physjcal means haye beep established for alerting aod proyjdjpq prompt iostructjops to the public wtthio the plume exposure pathway and the publjc ANS meets the desjqp regujrements of fEMA-BEP-l o Gyjde for Eyalyati 0 of Alert aod Notjficati 0 Systems for Nuclear Power Plants or complies wjth the licensee's f EMA-approyed ANS desjqp report and supportjng f EMA approval letter Procedures have been established for notification, by the licensee, of State and local response orQanizations and for notification of emerQency personnel by all orQanizations; the content of initial and follow up messaQes to response orQanizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

The new Alert Notification System (ANS) and Sirens meets or exceeds all specifications for the system being replaced.

The requirements are that there be an administrative and physical means for alerting the public. The ANS system must meet the design requirements of the FEMA-REP-10 Guide for evaluation of Alert and Notification Systems for Nuclear Power Plants; or comply with the licensee's FEMA approved ANS design report and supporting FEMA approval letter.

The previously approved ANS sirens are rated at 119.5 dBC @ 100'. The new sirens are rated at 123 dBC @ 100'. The previous system consisted of the 43 sirens that had four control stations. The new system has 43 sirens located in the same proximity as the previous sirens. It also has four control stations at the same locations as the previous system. The new sirens are designed to require less maintenance due to newer technology equipment powered by solar energy.

All commitments to FEMA REP-10 have been verified to have been met related to the Alert and Notification System.

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Attachment 3 Page 2 of 4 10CFR50.54(Q)(3) Evaluation Procedure/Document Number: Revision:O ENTANSERGGN201217 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

ANS Evaluation Report Grand Gulf Nuclear Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47[b](5); Admjnjstratjye and physjcal means haye been established for alertjna and proyjdjna prompt jnstructjons to the public within the plume exposure pathway and the public ANS meets the desjqn requirements of fEMA-REP-10 Gujde for Eyaluatjon of Alert and Notjficatjon Systems for Nudear Power Plants or complies wjth the licensee's fEMA-approyed ANS desjgn report and supportjng fEMA approyal letter Procedures have been established for notification, by the licensee, of State and local response orQanizations and for notification of emerQency personnel by all orQanizations; the content of initial and follow up messaQes to response orQanizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

1o CFR 50 Appendix E, section IV.D.1: Admjnjstratjye and physjcal means for notjfyjng local State and federal officials and aaencjes and agreements reached wjth these officjals and agencjes for the prompt notjfjcatjon of the public and tor public eyacuatjon or other protective measures should they become necessary shall be descrjbed This descriptjon shall include jdentjficatjon of the appropriate officials by title and agency of the State and local aoyemment agencies within the EPZs 10 CFR 50 Appendix E, section IV.D.3: A licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition. Prior to initial operation greater than 5 percent of rated thermal power of the first reactor at a site, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. The design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system. The alerting and notification capability shall additionally, include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population. The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system. When there is a decision to activate the alert and notification system, the appropriate governmental authorities will determine whether to activate the entire alert and notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public alert and notification system shall remain with the appropriate governmental authorities.

NUREG 0654 Section I1.E.6 Each oraanjzatjon shall estabHsh admjnjstratjve and phvsjcat means and the tjme reaujred for notjfyjna and proyjdjna prompt jnstruct;ons to the public within the plume exposure pathway Emergency EN-EP-305 R008

Attachment 3 Page 3 of 4 10CFR50.54(Q)(3) Evaluation Procedure/Document Number: Revision:0 ENT ANSERGGN201217 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

ANS Evaluation Report Grand Gulf Nuclear Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

This new ANS Evaluation Report supports replacement of old sirens with new sirens and a new control system. This change does not reduce the effectiveness of the Emergency Plan. The new ANS control system is of newer technology and more reliable from the same control locations as the previous system. There are the same number of sirens, in the same proximity as the system being replaced. The new sirens have been confirmed to be louder than the sirens being replaced based upon vendor testing. The new sirens are designed to require less maintenance due to newer technology equipment powered by solar energy. This change continues to meet the planning standard outlined in 10 CFR 50.47[6]4. This change does not represent a reduction in the effectiveness to the emergency plan and can be incorporated without prior NRC approval.

EN-EP-3O5 ROOS

Attachment 3 Page 4 of 4 10CFR50.54(Q)(3) Evaluation Procedure/Document Number: Revision:O ENT ANSERGGN201217 Equipment/Facility/Other: Grand Gulf Nuclear Station

Title:

ANS Evaluation Report Grand Gulf Nuclear Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

1. Does the proposed change comply with 10CFR50.47(b) and 10CFR50

~YES NO Appendix E?

2. Does the proposed change maintain the effectiveness of the emergency plan

~YES NO (i.e., no reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme YES~ NO change?

If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10CFR50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to Section 6.7 Step 8.

Part VII. Signatures Preparer Name (Print) s,IdPreparer ney N Signature DlgHaly signed by Sidney N Raevn, DN cns51dney N Raevn . , c=US.

o=Grand GIAf Nudear Station, Date:

Sidney Reeves R 111 ou* Emargancy Ftannlng, amal*sraeve1@onlergy.com eeves' Reason 5054 praparer Dehr2021,12.0215*1**10~6'00' (Optional) Reviewer Name (Print) Reviewer Signature Date:

Dennis Coulter Dennis M. Coulter Digit~lly signed by ~e~nis M.,co,ulter Date. 2021.12.04 11.34.51 -06 00 Reviewer Name ( Print) Date:

AnReviewer th any Signature J Dlgllally slgnod by Anthony J. Ringgold DN* cn*AnlhonyJ, Ringgald, czUS,

• ozEnle,gy, ou"5onlor P10Joct Manager.

Nuclear EP Project Manager Ring gOId Nuclear, omaB=artnggo@onlorgy.com Reason , aUesl la tho aa:uracy and lnlogrtly of this document Dole: 2021 .12.05 05:20:28 -011'00' Approver Name (Print) AnnrovP.r Sinn:::ihire Date:

Michael Lewis Emergency Planning Manager or designee ti /4:ts 2021.12.06 09:32:35 -06'00' EN-EP-305 R008