ML12240A180

Issuance of Amendment No. 175, Emergency Plan Change to Relocate Alternate Emergency Operations Facility from 23 to 28 Miles from the Technical Support Center

ML12240A180
Person / Time
Site:	River Bend
Issue date:	09/24/2012
From:	Wang A Plant Licensing Branch IV
To:	Entergy Operations
Wang A
References
TAC ME6846
Download: ML12240A180 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 24, 2012 Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775

SUBJECT:

RIVER BEND STATION, UNIT 1 -ISSUANCE OF AMENDMENT RELATED TO THE RELOCATION OF THE BACKUP EMERGENCY OPERATIONS FACILITY (TAC NO. IVIE6846)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 175 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1 (RBS). The amendment consist of a change to the Emergency Plan (EP) in response to your application dated September 12, 2011, as supplemented by letters dated October 13, 2011, March 22, 2012, and April 3, 2012.

The amendment approves a change to the site EP to relocate the existing backup emergency operations facility (BEOF) for RBS from its current location at the Entergy Operations-Baton Rouge Division Office, located at 1509 Government Street in Baton Rouge, Louisiana, approximately 23 miles southeast of RBS, to the Entergy Customer Service Center, located at 5564 Essen Lane in Baton Rouge, Louisiana, approximately 28 miles southeast of RBS. Based on the U.S. Nuclear Regulatory Commission (NRC) staff's review and walkthrough of the current and proposed BEOF locations, the NRC staff concludes that the proposed facility meets the functional guidelines for a BEOF contained in NUREG-0696, "Functional Criteria for Emergency Response Facilities," February 1981, and continues to meet or exceed the capabilities of the current BEOF facility.

- 2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

~~ \jJ (;/vvC~/

( \ \) p .

Alan B. Wang, Project Ma6jger Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-458

Enclosures:

1. Amendment No. 175 to NPF-47

2. Safety Evaluation cc w/encls: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 ENTERGY GULF STATES LOUISIANA, LLC AND ENTERGY OPERATIONS, INC.

DOCKET NO. 50-458 RIVER BEND STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 175 License No. NPF-47

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (the licensee), dated September 12,2011, as supplemented by letters dated October 13,2011, March 22, 2012, and April 3, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

-2

2. Accordingly, by Amendment No. 175, Facility Operating License No. NPF-47 is hereby amended to authorize revision to the Emergency Plan as set forth in the Entergy Operations, Inc.'s application dated September 12,2011, as supplemented by letters dated October 13, 2011, March 22, 2012, and April 3, 2012, and evaluated in the NRC staff's safety evaluation dated

3. The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

Eric J. eds, Director Office f Nuclear Reactor Regulation Date of Issuance: September 24, 2012

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 175 TO FACILITY OPERATING LICENSE NO. NPF-47 ENTERGY OPERATIONS, INC.

RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458

1.0 INTRODUCTION

In a letter dated September 12, 2011 (Reference 1), and as supplemented by letters dated October 13, 2011, March 22, 2012, and April 3, 2012 (References 2,3, and 4, respectively),

Entergy Operations, Inc. (Entergy, the licensee), proposed a change to the site Emergency Plan to relocate the backup emergency operations facility (BEOF) for River Bend Station, Unit 1 (RBS), from its current location at the Entergy Operations-Baton Rouge Division Office, located at 1509 Government Street in Baton Rouge, Louisiana, approximately 23 miles southeast of RBS, to the Entergy Customer Service Center, located at 5564 Essen Lane in Baton Rouge, Louisiana, approximately 28 miles southeast of RBS. The supplemental letters dated October 13, 2011, March 22, 2012, and April 3, 2012, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 27,2011 (76 FR 80974).

2.0 REGULATORY EVALUATION

This safety evaluation addresses the impact of the proposed changes on the RBS Emergency Plan. The regulatory requirements and guidance on which the NRC staff based its acceptance are as follows:

2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix E,Section IV.E.8.b.

specifies the requirements for emergency facilities and equipment. A licensee may locate a primary emergency operations facility (EOF) less than 10 miles from the nuclear power reactor site(s), but in such cases, must have a backup EOF located between 10 miles and 25 miles of the nuclear power reactor site(s). A licensee desiring to locate an EOF more than 25 miles from a nuclear power reactor site(s) must request Commission prior approval. This requirement for Enclosure 2

-2 Commission prior approval does not differentiate between a primary and backup facility. The NRC staff will issue a license amendment for the proposal upon Commission approval.

2.2 Guidance SECY-96-170, "Assessment of Exceptions Granted for Locations and Staffing Times of Emergency Operations Facilities," dated August 5, 1996 (Reference 5), provided a summary of exceptions to the guidance provided in NUREG-0696, "Functional Criteria for Emergency Response Facilities," dated February 1981 (Reference 6), for the locations of EOFs and BEOFs to the Commission. The summary identified 19 BEOFs located greater than the original 20-mile distance with nine located greater than 25 miles. RBS's location for the current BEOF was provided to the Commission for approval in SECY-83-152, "Backup Emergency Operations Facility for the Clinton Power Station, Unit 1 and River Bend Station Units 1 and 2," dated April 28, 1983 (Reference 7). At that time, Commission approval was required for BEOFs more than 20 miles from the Technical Support Center (TSC). Approval for the location of the RBS BEOF was provided by NRC letter to the Gulf States Utilities Company, dated June 1, 1983 (Reference 8).

NUREG-0696 Table 2, "Relation of EOF Location to Habitability Criteria," specifies that a BEOF need not be a separate, dedicated facility, but when activated, shall provide continuity of dose prediction and decision-making functions by arranging for portable backup equipment, and that no special provisions for protection factors or ventilation protection are needed.

3.0 TECHNICAL EVALUATION

3.1 Background The current NRC-approved BEOF at the Entergy Operations in Baton Rouge is approximately 23 miles from the TSC. Entergy is discontinuing the use of this facility and property. The distance from the RBS to the proposed BEOF location at the Entergy Customer Service Center in Baton Rouge is 28 miles. NRC staff conducted a walkthrough of the current BEOF location and the proposed BEOF location with the licensee's personnel on February 14, 2012.

The NRC staff considered the following factors in conducting the evaluation of Entergy's proposal to relocate the RBS BEOF.

Functions The proposed facility will have the capabilities to: (1) obtain and display plant data and radiological information; (2) assess plant and radiological release conditions; (3) perform offsite dose projections; (4) make public protective action recommendations, and (5) perform offsite notifications to State and local agencies. The proposed RBS BEOF also has a backup generator capable of supplying all of the electrical loads within the facility to provide for the continued capability to perform BEOF functions. The proposal meets the functional guidance for continuity of dose prediction and decision-making functions for a BEOF as provided in NUREG-0696.

-3 Location The licensee's proposal results in a BEOF that is 28 miles from the RBS, which is 5 miles further from the plant than the current BEOF. By letter dated March 22, 2012, in response to the NRC staff's request for additional information (RAI) dated February 24, 2012 (Reference 9), the licensee provided an analysis which indicated that the relocation will add approximately 8-10 minutes of travel time for emergency response organization (ERO) members responding from the onsite EOF. For events that require ERO members to report directly to the BEOF, the licensee determined that travel time is about the same. Based on this analysis, the licensee indicated that the proposed BEOF can become operational within the 90-minute goal set for the onsite EOF and, therefore, the relocation of the BEOF would not adversely affect timeliness in staffing the facility.

In a second RAI (Reference 9), the NRC staff inquired whether the licensee had evaluated other facilities located within 25 miles of RBS as a possible site for the proposed BEOF. In its letter dated March 22,2012, the licensee indicated that four other Entergy facilities closer to RBS were reviewed for potential use as the BEOF. The licensee's review determined that none of the four other Entergy facilities possessed the necessary space and supporting infrastructure (telecommunications, data acquisition, computer access) that are found at the proposed BEOF. In addition, the licensee's review identified potential concerns with cyber security, physical security, and available parking at the other Entergy facilities. Since the proposed location serves as a primary Entergy information technology (IT) hub, with redundant computer capabilities, along with being a continuously occupied and physically secured facility, the proposed location does not pose the concerns present at the other locations evaluated.

The proposed RBS BEOF has 1,650 square feet in three rooms of reserved space on the second floor, not including a break room, hallway, and restrooms. Additional space is available on the first floor if needed in an emergency. The three rooms are designated as the main conference room, dose assessment room, and the NRC room. The current RBS BEOF has 1,410 square feet of space in an auditorium containing lockers with communications equipment, and computers, as well as 500 square feet in an adjacent room deSignated for the NRC for a total of 1,910 square feet of deSignated space. The licensee indicated that there should be 29 responders to the RBS EOF: 13 from RBS, six from the Louisiana Department of Environmental Quality (LDEQ), nine from the NRC (per NUREG-0696), and one from the Federal Emergency Management Agency (FEMA). LDEQ is the only State or local agency that sends responders to the RBS EOF. Although the proposed RBS BEOF is smaller in size than the current BEOF, the NRC staff believes that the improved quality (additional IT equipment, modern restrooms, overall facility conditions, located in an occupied building rather than an abandoned one, and compliance with access requirements of the Americans with Disabilities Act) of the proposed facility is a more important factor in the NRC staff's conclusion than the loss of the 260 square feet of floor space.

-4 Communications The proposed RBS BEOF is also currently utilized as Entergy's Electrical Outage Call Center and, as such, has sufficient internal and external telecommunications, including Internet access, to support BEOF functions. The proposed location, like the existing one, provides for reliable voice and data communication to the TSC and control room, as well as reliable voice communications to the Operations Support Center and to the NRC, State, and local emergency operations centers. Additionally, the licensee has installed a public address system in the dose assessment and NRC rooms to allow for facility briefings.

State and Local Agreement The licensee has discussed the proposed relocation of the BEOF with State and local agencies, as well as FEMA Region VI. The licensee's letter dated October 13, 2011, provides letters from the following agencies documenting that the respective agency has no issues or concerns with the proposed BEOF relocation in calendar year 2012 to the Entergy Customer Service Center, located at 5564 Essen Lane in Baton Rouge:

• Louisiana Governor's Office of Homeland Security and Emergency Preparedness

• Louisiana Department of Environmental Quality

• MiSSissippi State Department of Health

• West Feliciana Parish Homeland Security and Emergency Preparedness

• Pointe Coupee Parish Homeland Security and Emergency Preparedness

• East Baton Rouge Parish Homeland Security and Emergency Preparedness

• West Baton Rouge Parish Homeland Security and Emergency Preparedness

• Federal Emergency Management Agency, Region VI 4.0 RELOCATION OF BEOF

SUMMARY

As noted in the Section 2.1 of this safety evaluation, a licensee desiring to locate an EOF more than 25 miles from a nuclear power reactor site(s) must request Commission prior approval.

This requirement for Commission prior approval does not differentiate between a primary and backup facility. In SECY-12-0097, "Entergy Operations, Inc.'s Request to Relocate the River Bend Station Backup Emergency Operations Facility," dated July 13, 2012 (Reference 10), the NRC staff recommended that the Commission approve the proposal to relocate the RBS BEOF to Entergy's Customer Service Center in Baton Rouge, Louisiana. The Commission approved the staff's recommendation in Staff Requirements Memoranda (SRM) - SECY-12-0097, "Entergy Operations, Inc.'s Request to Relocate the River Bend Station Backup Emergency Operations Facility," dated August 20,2012 (Reference 11).

Therefore, the NRC staff has reviewed the proposed RBS BEOF relocation as outlined in Entergy's letter dated September 12, 2011, as supplemented by letters dated October 13, 2011, March 22,2012, and April 3, 2012. Based on the NRC staff's review of these documents, and the NRC staff's walkthrough of the current and proposed BEOF location, the NRC staff concludes that the proposed facility meets the functional guidelines for a BEOF contained in NUREG-0696 and continues to meet or exceed the capabilities of the current BEOF facility.

The NRC staff believes that the additional 5-mile distance from the RBS TSC will have minimal

- 5 impact on the timely staffing of the proposed BEOF. In addition, the proposed BEOF's location in Entergy's Customer Service Center in Baton Rouge, which also serves as Entergy's Electrical Outage Call Center manned on a continuous basis, will ensure the continued operability and availability of the facility to serve as a BEOF. The NRC staff has determined that emergency response, communication, and coordination are not adversely affected by the relocation of the RBS BEOF to the Entergy Customer Service Center in Baton Rouge, and that the proposed BEOF would continue to protect the public health and safety, and promote the common defense and security.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on December 27, 2011 (76 FR 80975). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Roberts, J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Proposed Emergency Plan Change," dated September 12, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11259A008).

2. Roberts, J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information - Proposed Emergency Plan Change - Backup EOF Relocation," dated October 13, 2011 (ADAMS Accession No. ML11297A029).

- 6

3. Roberts, J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission.

"Response to Request for Additional Information Regarding Proposed Emergency Plan Change," dated March 22,2012 (ADAMS Accession No. ML12086A265).

4. Roberts, J. C., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information Concerning License Amendment Submittals," dated April 3, 2012 (ADAMS Accession No. ML12101A241).

5. SECY-96-170, "Assessment of Exceptions Granted for Locations and Staffing Times of Emergency Operations Facilities," dated August 5, 1996 (ADAMS Legacy Accession No. 9608080188).

6. NUREG-0696, "Functional Criteria for Emergency Response FacHities," February 1981 (ADAMS Accession No. ML051390358).

7. SECY-83-152, "Backup Emergency Operations Facility for the Clinton Power Station, Unit 1 and River Bend Station Units 1and 2," dated April 28, 1983 (ADAMS Legacy Accession No. 8305160329).

8. Eisenhut, D. G, U.S. Nuclear Regulatory Commission, letter to William J. Cahill, Jr., Gulf States Utilities Company dated June 1, 1983 (ADAMS Legacy Accession No. 8306150221).

9. Wang, A. B., U.S. Nuclear Regulatory Commission, electronic mail to Barry Burmeister and Joseph Clark, Entergy Operations, Inc. "River Bend Station, Unit 1 (RBS) Request for Additional Information Regarding Proposed Emergency Plan Change (ME7181),"

dated February 24,2012 (ADAMS Accession No. ML120550332).

10. SECY-12-0097, "Entergy Operations, Inc.'s Request to Relocate the River Bend Station Backup Emergency Operations Facility," dated July 13, 2012 .. (ADAMS Accession No. ML12118A136).

11. SRM - SECY-12-0097, "Entergy Operations, Inc.'s Request to Relocate the River Bend Station Backup Emergency Operations Facility," dated August 20,2012 (ADAMS Accession No. ML122330615).

Principal Contributor: Michael B. Norris Date: September 24, 2012

2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRAI Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458

Enclosures:

1. Amendment No. 175 to NPF-47

2. Safety Evaluation cc w/encls: Listserv 01 STRI BUTION:

LPLIV rlf PUBLIC RidsAcrsAcnw_MailCTR Resource RidsNrrOd Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMRiverBend Resource RidsNsirDprDdep Resource RidsOgcRp Resource RidsRgn4MailCenter Resource MNorris, NSIR JBurkhardt

• (BClayton for) JAnderson 08129/12 8/21/12 NRR/DORLlLPL4/BC NRRIDORLID NRR/D MEvans ELeeds AWang 09117/12 09/21/12 9124112 OFFICIAL AGENCY RECORD