RBG-48015, Change in Implementation Date for License Amendment Request, Amendment 197
| ML20083N719 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/23/2020 |
| From: | Gaston R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RBG-48015 | |
| Download: ML20083N719 (8) | |
Text
Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 RBG-48015 March 23, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Change in Implementation Date for License Amendment Request, Amendment 197 River Bend Station, Unit 1 Docket No. 50-458 Renewed Facility Operating License No. NPF-47
Reference:
NRC letter "River Bend Station, Unit 1 - Issuance of Amendment to Revise Emergency Action Levels, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors (EPID L-2018-LLA-0130) (ML19070A062) dated May 14, 2019.
In the referenced letter, the NRC approved Amendment No. 197 to Renewed Facility Operating License No. NPF-47, for River Bend Station (RBS), Unit 1. The amendment approved an update to the RBS Emergency Plan to adopt the Nuclear Energy Institute (NEI) revised Emergency Action Level scheme described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." In accordance with the referenced letter, the revised RBS Emergency Plan is required to be implemented no later than May 13, 2020.
Entergy Operations, Inc. (Entergy), is requesting an amendment to extend the RBS Emergency Plan implementation date to September 30, 2020. This extension is necessary due to unforeseen circumstances which are detailed in the enclosure. The proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).
Approval of the proposed amendment is requested by May 13, 2020.
No new regulatory commitments are included in this amendment request.
In accordance with 10 CFR 50.91, Notice for public comment; State consultation, a copy of this application, with attachments, is being provided to designated State of Louisiana and State of Texas Officials.
RBG-48015 Page 2 of 2 If there are any questions or if additional information is needed, please contact Tim Schenk, Manager, Regulatory Assurance, at 225.381.4177.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 23, 2020.
Sincerely, Ron Gaston RWG/twf
Enclosure:
Evaluation of the Proposed Change cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - River Bend Station, Unit 1 NRC Project Manager - River Bend Station, Unit 1 Louisiana Department of Environmental Quality Public Utility Commission of Texas
Enclosure to RBG-48015 Evaluation of the Proposed Change
Enclosure to RBG-48015 Page 1 of 5 EVALUATION OF THE PROPOSED CHANGE 1.0
SUMMARY
DESCRIPTION By letter dated May 14, 2019 (Reference 1), the NRC approved Amendment No. 197 to Renewed Facility Operating License No. NPF-47, for River Bend Station (RBS), Unit 1. The amendment approved an update to the RBS Emergency Plan to adopt the Nuclear Energy Institute (NEI) revised Emergency Action Level (EAL) scheme described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." In accordance with the referenced letter, the revised RBS Emergency Plan is required to be implemented no later than May 13, 2020.
Entergy Operations, Inc. (Entergy), is requesting an amendment to extend the RBS Emergency Plan implementation date to September 30, 2020.
2.0 DETAILED DESCRIPTION
2.1 Background
Entergy had planned to implement the revised RBS Emergency Plan revision by the NRC-required implementation date of May 13, 2020. However, due to the ongoing COVID-19 pandemic and the resulting impact on the station, Entergy Operations requests that the implementation date for NEI 99-01 Revision 6 EALs be extended to September 30, 2020. This extension will account for additional time to complete procedure revisions needed to support implementation. Entergy recognizes the importance of timely implementation of the Revision 6 EALs and will meet the September 30, 2020 implementation date.
2.2 Current Requirement As stated in Reference 1, the revised RBS Emergency Plan is required to be implemented no later than May 13, 2020.
2.3 Reason for the Proposed Change The ongoing COVID-19 pandemic is affecting station personnel in such a way that implementation of NEI 99-01 Revision 6 EALs will need to be delayed beyond the May 13, 2020 date specified in the approved license amendment. An extension of the implementation date to September 30, 2020 will account for unforeseen impacts on plant staff that have interfered with implementation of the Revision 6 EALs as originally planned. As stated earlier, Entergy recognizes the importance of timely implementation of the Revision 6 EALs and intends to implement the change without delay.
2.4 Description of the Proposed Change Based on the information provided in Section 2.3 above, Entergy proposes to extend the implementation date of the RBS Emergency Plan, which is based on NEI 99-01, Revision 6, to September 30, 2020.
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3.0 TECHNICAL EVALUATION
The RBS Emergency Plan currently in use was developed in accordance with earlier revisions of NEI 99-01 and has been previously approved for use by the NRC. As stated in Section 1.0 above, the NRC subsequently approved revising the RBS Emergency Plan to be based on the guidance contained in NEI 99-01, Revision 6, on May 14, 2019 (Reference 1). The revised RBS Emergency Plan is currently required to be implemented on or before May 13, 2020.
Unforeseen circumstances arising from the COVID-19 pandemic have impacted station personnel in such a way that implementation of NEI 99-01, Revision 6, cannot be accomplished by May 13, 2020.
Based on the above, Entergy requests to extend the implementation date of the NEI 99-01, Revision 6 - based RBS Emergency Plan until September 30, 2020.
Continued use of the RBS Emergency Plan, which is based on previous revisions of the guidance of NEI 99-01, will not prevent effective and efficient execution of mitigating and recovery efforts that may be necessary should an event occur prior to the new proposed implementation date. The current RBS Emergency Plan has been in use, drilled, and evaluated since its implementation. Therefore, delaying the implementation of the NEI 99-01, Revision 6 -
based RBS Emergency Plan until September 30, 2020 will not affect the health and safety of the public or challenge nuclear safety in any manner.
Based on the above, Entergy has concluded that the proposed request minimizes potential human factors concerns with no impact to nuclear or public safety.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The regulations in 10 CFR 50.54(q) provide direction to licensees seeking to revise emergency plans. The requirements related to nuclear power plant emergency plans are contained in the standards in 10 CFR 50.47, Emergency Plans, and the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.
Paragraph 10 CFR 50.47(a)(1) states that no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
Section 50.47(b) contains standards that onsite and offsite emergency response plans must meet for the NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
One of these standards, 10 CFR 50.47(b)(4), requires that emergency plans include a standard emergency classification and action level scheme.
10 CFR 50, Appendix E, Section IV.B, Assessment Actions, requires that emergency plans include emergency action levels (EALs) that are to be used as criteria for determining the need for notification and participation of local and state agencies, and for determining when and what type of protective measures should be considered to protect the health and safety of individuals
Enclosure to RBG-48015 Page 3 of 5 both onsite and offsite. EALs are to be based on plant conditions and instrumentation, as well as onsite and offsite radiological monitoring.Section IV.B provides that initial EALs shall be discussed and agreed on by the applicant and state and local authorities, be approved by the NRC, and reviewed annually thereafter with state and local authorities. Therefore, a revision to EALs will require NRC approval prior to implementation, if it involves (1) changing from one EAL scheme to another, (2) proposing an alternate method to comply with the regulations, or (3) the EAL revision proposed by the licensee decreases the effectiveness of the emergency plan.
NRC Regulatory Issue Summary (RIS) 2005-02, Revision 1, Clarifying the Process for Making Emergency Plan Changes, issued April 19, 2011, says that a change in an EAL scheme to incorporate the improvements provided in NUMARC/NESP-007 or NEI 99-01 would not decrease the overall effectiveness of the emergency plan, but due to the potential safety significance of the change, the change needs prior NRC review and approval.
The proposed change has no impact on the ability to meet the above regulatory requirements.
4.2 Precedent The NRC approved a request for an extension of the implementation period for Revision 6 of NEI 99-01 for Arkansas Nuclear One (ANO), Units 1 and 2 on October 22, 2019 (Reference 2).
4.3 No Significant Hazards Consideration Analysis Entergy has evaluated the proposed change to the RBS Emergency Plan using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
Entergy proposes to extend the implementation date associated with the currently approved EAL scheme for RBS, which is based on the guidance provided in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." The subject implementation date is proposed to be extended from May 13, 2020, to September 30, 2020.
Basis for no significant hazards consideration determination: As required by 10 CFR 50.91(a),
Entergy analysis of the issue of no significant hazards consideration (NSHC) is presented below.
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No An Emergency Plan provides mitigative and recovery efforts associated with certain station events that could impact the health and safety of the public. The RBS Emergency Plan is unrelated to any accident or event initiator. The RBS Emergency Plan currently in use is based on NEI 99-01 guidance, as previously approved by the NRC. An Emergency Plan based on previous revisions to the NEI guidance is effective and acceptable for establishing all necessary actions necessary to mitigate the consequences of an accident previously evaluated and have been previously endorsed by the NRC. Therefore, delaying implementation of the NEI 99-01, Revision 6 - based RBS Emergency Plan does not
Enclosure to RBG-48015 Page 4 of 5 involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No As stated previously, an Emergency Plan is not associated with any accident initiator but acts only to limit the consequences of an accident. The proposed amendment does not alter any plant equipment or otherwise affect the RBS accident analyses. Therefore, delaying implementation of the NEI 99-01, Revision 6 - based RBS Emergency Plan does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No As stated previously, an Emergency Plan based on earlier revisions of the NEI guidance is effective and acceptable for establishing all necessary actions necessary to mitigate the consequences of an accident previously evaluated and have been previously endorsed by the NRC. RBS will continue to utilize the station Emergency Plan based on previous revisions of NEI 99-01 until Revision 6 of the NEI guidance is fully implemented. Therefore, delaying implementation of the NEI 99-01, Revision 6 - based RBS Emergency Plan does not involve a significant reduction in a margin of safety.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
The proposed change would extend the implementation date of the revised Emergency Plan for RBS. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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.
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6.0 REFERENCES
- 1. NRC letter "River Bend Station, Unit 1 - Issuance of Amendment to Revise Emergency Action Levels, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors (EPID L-2018-LLA-0130) (ML19070A062) dated May 14, 2019.
- 2. NRC letter "Arkansas Nuclear One, Units 1 and 2 - Issuance of Amendment Nos. 267 and 317 to Extend Implementation Dates for Amendment Nos 263 and 314 - Revision to Emergency Action Level Scheme (EPID L-2019-LLA-0192)," (ML19269B672), dated October 22, 2019