RBG-47174, Proposed Emergency Plan Change
| ML11259A008 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/12/2011 |
| From: | Roberts J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RBF1-11-0117, RBG-47174 | |
| Download: ML11259A008 (10) | |
Text
Entergy Operations, Inc.
River Bend Station 5485 U.S. Highway 61N rSt. Francisville, LA 70775
-Tel 225 381 4149 Fax 225 635 5068 jrober3@entergy.com
.Jerry C. Roberts Director, Nuclear Safety Assurance September 12, 2011 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
Proposed Emergency Plan Change River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47 RBG-47174 RBF1-1 1-0117
Dear Sir or Madam:
The enclosed Emergency Plan change is hereby submitted for NRC staff review and approval as required by 10 CFR 50.54(q), 50.4, and 50.90. The proposed change relocates the Alternate Emergency Operations Facility (EOF) from 23 miles to 28 miles from the TSC.
The proposed change was evaluated against the criteria of 10 CFR 50.47, 10 CFR 50, Appendix E and other NRC guidance documents. This change has been deemed a decrease in the effectiveness of the Emergency Plan in accordance with 10 CFR 50.54(q) and the guidance contained in NRC RIS 2005-02, therefore NRC approval is required. The requested change is acceptable in that the proposed Alternate EOF facility will have the same emergency functional capabilities of protecting the health and safety of the public and emergency workers as the current Alternate EOF. There is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. This change has been reviewed and approved by the Onsite Safety Review Committee (OSRC). This change was prepared using the Emergency Plan Smart Application Template format requirements.
The proposed change has been evaluated in accordance 10 CFR 50.92(c) and it has been determined that the changes involve no significant hazards considerations. Attachment 1 provides the No Significant Hazards Consideration for the change.
Attachment 1 provides the justification for the change. Attachment 2 includes a mark-up of the latest Emergency Plan illustrating the proposed change. Attachment 3 is a revised copy of the Emergency Plan page and reflects the proposed Attachment 2 change.
Due to current Alternate EOF facility commitments, Entergy is requesting an expedited review on this request to allow moving the Alternate EOF in February 2012. Your prompt review is requested to meet the February implementation date.
Once approved, the amendment shall be implemented by March 1, 2012.
RBG-47174 Page 2 of 2 This letter contains no new commitments.
If you have any questions or require additional information, please contact Joey Clark at 225-381-4177.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September 12, 2011.
Sincerely,
/JerryC oet Director, Nuclear Safety Assurance JAC/kh Attachments: 1. Justification for Revision to Emergency Plan
- 2. Mark-up of Affected Emergency Plan Page
- 3. Proposed Emergency Plan Mark-up Information Incorporated cc: Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector P. O. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Alan Wang, Project Manager MS 0-8 B1 Washington, DC 20555-0001 Ji-Young Wiley Louisiana Department of Environmental Quality Office of Environmental Compliance P. O. Box 4312 Baton Rouge, LA 70821-4312
Attachment 1 RBG-47174 Justification for Revision to Emergency Plan
RBG-47174 Page 1 of 3 Justification for Revision to Emergency Plan 1.0. Description of Proposed Change:
This proposed change requests the relocation of the backup Emergency Operations Facility (EOF) to a location at Entergy's Customer Service Center in Baton Rouge. River Bend's backup EOF is currently located in the Entergy Operations - Baton Rouge Division Office on Government Street in Baton Rouge, approximately 23 miles southeast of RBS. The new Alternate EOF location will be at Entergy's Customer Service Office on Essen Lane in Baton Rouge, approximately 28 miles southeast of RBS.
2.0 Justification for the Request:
NUREG-0696, Table 2, "Relation of EOF Location to Habitability Criteria," dated February 1981, Note 1, requires specific Commission approval for EOF locations beyond 20 miles of the TSC and Table 2 specifies the Backup EOF is located within 10 to 20 miles of the TSC. The 20-mile limit was later modified by the Commission to 25 miles in SECY-96-170. NUREG-0737, Table 1, specifies similar criteria.
The primary EOF will remain at its current near site location approximately 1.1 miles from the plant and outside the site boundary (exclusion area boundary). The primary EOF meets all the regulatory guidance for an EOF inside the plant's ten mile radius.
Since the primary EOF is located inside the 10-mile radius, the regulatory guidance specifies an Alternate EOF is required. River Bend's current NRC-approved Alternate EOF is an Entergy facility located at 1509 Government Street in Baton Rouge approximately 23 miles from the TSC. Entergy is discontinuing the use of this facility and property. The proposed Alternate EOF location is in an Entergy facility located at 5564 Essen Lane in Baton Rouge approximately 28 miles from the TSC. All distances are straight line distances.
The proposed Alternate EOF location is currently the Entergy electrical outage call center that has sufficient internal and external telecommunications and internet capabilities. The facility has a backup generator capable of supplying all of the electrical loads within the facility. There is sufficient space reserved for the Alternate EOF (AEOF) during an emergency on the second floor. There are 1650 ft2 in 3 rooms on the second floor allocated for use by Alternate EOF personnel. The square footage area does not include the adjacent break room, hallways and bathroom facilities. Additional space is also allocated on the first floor, if needed during a declared emergency. The current AEOF has 1410 ft 2 in an auditorium for the EOF operations area and 500 ft 2 in an adjacent room for an NRC conference room. There are 29 people assigned to the EOF:
River Bend 13, Louisiana Department of Environmental Quality (LDEQ) 6 and per NUREG-0696 NRC 9 and FEMA 1. -LDEQ is the only State and Local agency that sends responders to the EOF. The Alternate EOF space on the second floor allows for -57 ft2 per person without using any space on the first floor. It is preferred to keep all EOF personnel together on the same floor for improved continuity of facility operations.
The proposed Essen Lane Alternate EOF will maintain the same emergency response function capabilities as the current Alternate EOF. The proposed facility will have the capabilities to obtain and display plant data and radiological information to assess plant
RBG-47174 Page 2 of 3 and radiological release conditions, perform offsite dose projections, make public protective action recommendations and perform offsite notifications to State and Local agencies.
Since the proposed Essen Lane Alternate EOF is located 28 miles from the TSC, NRC and offsite agency staff may use the EOF, when desired, as a closer site to the plant to interact face-to-face with personnel going to and leaving the site for briefings and debriefings when the Alternate EOF is being used. The EOF has 1) space for members of an NRC site team and Federal, State, and local responders; 2) additional space for conducting briefings; 3) communication capability with other licensee and offsite emergency response facilities; 4) access to plant data and radiological information; and
- 5) access to copying equipment and office supplies.
The proposed Alternate EOF location is within 30 miles of the plant and will serve as the alternative facility during hostile action events when required. This facility will have the capability to perform offsite notifications to State and Local agencies.
State and Local agencies have been contacted concerning moving the Alternate EOF to the Essen Lane location and all have responded agreeing to the move.
2.1 Conclusion The relocation of the Alternate EOF does not alter the basic functions required of the facility as described in Section 4.1 of NUREG-0696. The facilities, equipment, and staffing of the Alternate EOF are adequate to ensure the continued effective and timely coordination of radiological and environmental assessment, determination of protective action recommendations, and communications with federal, state, and local agencies.
3.0 No Siqnificant Hazards Consideration River Bend has evaluated the proposed Emergency Plan revision against the criteria of 10 CFR 50.92(c) to determine if any significant hazards consideration is involved. River Bend has concluded that this proposed change does not involve a significant hazards consideration. The following is a discussion of how each of the 10 CFR 50.92(c) criteria is satisfied.
(1) Does not involve a significant increasein the probabilityor consequences of an accident previously evaluated.
The proposed change does not increase the probability or consequences of an accident. The change only impacts the implementation of the Emergency Plan by relocating the alternate EOF to another facility. It has no impact on plant equipment or the operation of plant equipment and thus has no impact on the probability or consequences of an event. The capabilities of the alternate EOF have not been revised from the current Emergency Plan. The proposed facility will have the capabilities to obtain and display plant data and radiological information to assess plant and radiological release conditions, perform offsite dose projections, make public protective action recommendations and perform offsite notifications to State and Local agencies.
RBG-47174 Page 3 of 3 (2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The change only impacts the implementation of the Emergency Plan by relocating the alternate EOF. The change does not impact any plant equipment or systems needed to respond to an accident, nor does it involve any analysis of plant accidents. The proposed change does not create a new or different kind of accident from any previously evaluated because this change only impacts the location of the Alternate EOF.
(3) Does not involve a significant reduction in a margin of safety.
The change to the Emergency Plan does not reduce the margin of safety currently provided by the Plan as it maintains the capabilities of the current alternate EOF.
Offsite dose calculations, offsite notifications to state and local agencies, and public protective action recommendations will continue to be performed by alternate EOF personnel. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
4'0 Environmental Impact Evaluation The proposed Plan change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
5.0 Precedent References None
Attachment 2 RBG-47174 Mark-up of Affected Emergency Plan Page
RBS - EP 13.3.6.1.5 Emergency Operations Facility (EOF)
The EOF is the emergency response facility located near the reactor site to provide continuous coordination and evaluation of EOr's activities during an emergency at RBS having or potentially having environmental consequences. The EOF has been designed to meet the requirements as specified in Supplement 1 to NUREG-0737. The EOF is activated at an Alert or higher level emergency.
The initial function of the EOF is to evaluate the magnitude and effects of actual or potential radioactive releases from the plant and to recommend appropriate offsite protective measures and to evaluate emergency conditions for potential emergency classification changes. To accomplish these functions, facilities are provided in the EOF for the evaluation of pertinent radiological, meteorological, and plant system data. The Radiological Assessment Coordinator coordinates the offsite radiological monitoring and analyzes results during emergency and recovery operations.
The overall management of EOI emergency resources is based in the EOF under the direction of the Emergency Director. The EOF Manager reports to the Emergency Director and is responsible for operations within the EOF. The EOF functions are performed in the Main Control Room or the TSC prior to the activation and staffing of the EOF. The EOF is utilized to coordinate the EOI emergency response activities with those of local, state and federal emergency response organizations, including the NRC and FEMA. The EOF is the
'location where EOI provides current information on conditions potentially affecting the public to the NRC and to state and local emergency response agencies. The EOF also functions as the post-accident recovery management center.
At an Alert, EOI will dispatch a technical representative to each of the five parish EOCs within the 10-mile EPZ and the State EOC, to ensure continuity and coordination among EOI, LDEQ, and the affected parishes.
13.3.6.1.5.1 Location The EOF is located within the RBS Training Center outside the plant security boundary but on EOI property near the intersection of U.S. Highway 61 and the River Bend Power Station Road. The RBS Training Center, in which the EOF is located, is outside the exclusion area and approximately 1.1 miles from the reactor building. The Alternate EOF is in the EQO Baton Rougo DiVi-cin Offico Entergy Customer Service Center located eil-at Governmont Stroot5564 Essen Lane in Baton Rouge, approximately 2328 miles southeast of RBS. This facility has adequate accommodations to ensure continuous emergency response operations and recovery management should the primary EOF become uninhabitable.
The justification for site location is based upon assuring accurate and timely interface and communications between EOF management personnel and onsite personnel, habitability of the EOF, and meteorology (predominant wind direction).
Revision 3X7- 13.3-1 Apti4 20! !Month 2012 1
Attachment 3 RBG-47174 Proposed Emergency Plan Mark-up Information Incorporated
RBS - EP 13.3.6.1.5 Emergency Operations Facility (EOF)
The EOF is the emergency response facility located near the reactor site to provide continuous coordination and evaluation of EOI's activities during an emergency at RBS having or potentially having environmental consequences. The EOF has been designed to meet the requirements as specified in Supplement 1 to NUREG-0737. The EOF is activated at an Alert or higher level emergency.
The initial function of the EOF is to evaluate the magnitude and effects of actual or potential radioactive releases from the plant and to recommend appropriate offsite protective measures and to evaluate emergency conditions for potential emergency classification changes. To accomplish these functions, facilities are provided in the EOF for the evaluation of pertinent radiological, meteorological, and plant system data. The Radiological Assessment Coordinator coordinates the offsite radiological monitoring and analyzes results during emergency and recovery operations.
The overall management of EOI emergency resources is based in the EOF under the direction of the Emergency Director. The EOF Manager reports to the Emergency Director and is responsible for operations within the EOF. The EOF functions are performed in the Main Control Room or the TSC prior to the activation and staffing of the EOF. The EOF is utilized to coordinate the EOI emergency response activities with those of local, state and federal emergency response organizations, including the NRC and FEMA. The EOF is the location where EOI provides current information on conditions potentially affecting the public to the NRC and to state and local emergency response agencies. The EOF also functions as the post-accident recovery management center.
At an Alert, EOI will dispatch a technical representative to each of the five parish EOCs within the 10-mile EPZ and the State EOC, to ensure continuity and coordination among EOI, LDEQ, and the affected parishes.
13.3.6.1.5.1 Location The EOF is located within the RBS Training Center outside the plant security boundary but on EOI property near the intersection of U.S. Highway 61 and the River Bend Power Station Road. The RBS Training Center, in which the EOF is located, is outside the exclusion area and approximately 1.1 miles from the reactor building. The Alternate EOF is in the Entergy Customer Service Center located at 5564 Essen Lane in Baton Rouge, approximately 28 miles southeast of RBS. This facility has adequate accommodations to ensure continuous emergency response operations and recovery management should the primary EOF become uninhabitable.
The justification for site location is based upon assuring accurate and timely interface and communications between EOF management personnel and onsite personnel, habitability of the EOF, and meteorology (predominant wind direction).
Revision 3X 13.3-1 Month 2012