CNL-25-066, Emergency Preparedness Department Procedure Revision
| ML25126A071 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 05/05/2025 |
| From: | Hulvey K Tennessee Valley Authority |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CNL-25-066 | |
| Download: ML25126A071 (1) | |
Text
1101 Market Street, Chattanooga, Tennessee 37402 CNL-25-066 May 5, 2025 10 CFR 50.54(q) 10 CFR 72.44(f)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296, and 72-052 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327, 50-328, and 72-034 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390, 50-391, and 72-1048
Subject:
Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q) and 10 CFR 72.44(f), Tennessee Valley Authority (TVA) is submitting a description of changes to the TVA Radiological Emergency Plan (REP). The affected document is the Emergency Preparedness Department Procedure (EPDP) listed below.
Document Revision Title Effective Date EPDP-3 25 Emergency Plan Exercises and 4/17/2025 Preparedness Drills
U.S. Nuclear Regulatory Commission CNL-25-066 Page 2 May 5, 2025 Description of Changes and Summary Analysis CECC EPDP-3 TVA revised this EPDP as follows.
Section 2.0 x
Added statement that EPDP-3 is not applicable to Severe Accident Management Guideline (SAMG) drills as they are governed by NPG-SPP-18.3.1.
Steps 3.1.2.A - 3.2.1.A.3.a(1) - 3.2.1.B.1.b - 3.2.1.B.4.b x
Revised to specify the Eight Year Exercise Plan is maintained in the Exercise Builder Nuclear (EBN) software tool and deleted reference to Attachment 1 where applicable.
Steps 3.1.2.B - 3.1.4.B - 3.2.1.A.3.a(2) - 3.2.1.C.1.c - 3.2.2.A.5 x
Replaced reference to Attachments 7, 11, 12, 13, and 15 for tracking 8-year cycle requirements with new reference to tracking these activities via EBN.
Step 3.1.2.D x
Changed eight-year exercise plan requirements to eight-year exercise cycle requirements for consistent use throughout procedure.
Steps 3.1.4.G - 3.1.4.H - 3.2.1.A.3.c(1) - 3.2.1.A.3.d - 3.2.1.A.3.e - 3.2.1.A.6.a - 3.2.1.A.6.l, 3.2.1.A.6.o - 3.2.2.A.2 - 3.2.2.A.3 - 3.2.2.A.4 - 3.2.2.A.5.g(8) - 3.2.2.B.2.b x
Revised attachment references to reflect renumbering due to deletion of some attachments.
Step 3.2.1.A.2.e - 3.2.1.C.4.a x
Capitalized Principal Functional Areas for consistent use throughout procedure, deleted listing of the functional areas in 3.2.1.C.4.a and replaced with reference to the listing in the definitions sections of the procedure, and replaced reference to with reference to EBN.
Step 3.2.1.A.3.a(2) x Added statement that an activity to be credited for Initiating Condition (IC) tracking must meet the definition of a Performance Enhancing Experience to ensure that guidance previously provided in deleted Attachments 11, 12, and 13 was retained.
Step 3.2.1.A.5.b x
Deleted to to correct typographical error.
Steps 3.2.1.A.6.g - 3.2.1.A.6.i x
Added additional specificity regarding the level of detail for condition report (CR) description and relocated guidance related to remediation from 3.2.1.A.6.g to step 3.2.1.A.6.i with additional wording to support readability.
U.S. Nuclear Regulatory Commission CNL-25-066 Page 3 May 5, 2025 Step 3.2.1.A.6.h x
Added new step with guidance from NRC Inspection Manual 0609 Appendix B regarding timeframe for addressing weaknesses identified during drills and exercises.
Step 3.2.1.C.5 x
Added guidance for the Program Manager, Emergency Preparedness Drills and Exercises, to generate Annual and Eight-Year Drill Cycle Demonstration Requirements Status Report and to submit the reports for review and transmittal to Enterprise Content Management (ECM) at the end of each calendar year.
Step 3.2.2.A.5.c x
Updated to better reflect wording of NRC guidance for demonstration of 50.155(b)(2) strategies during exercises and added source note.
Step 3.2.2.C.2 x
Added new guidance regarding mentor responsibilities during a training drill and deleted substeps with extraneous information regarding personnel performance standards which apply during actual events and are not relevant to drill development and tracking.
Section 4.0 x
Revised to reflect tracking of Drills/Exercises in EBN and to clarify that Drill/Exercise rosters are treated as a separate quality assurance (QA) record.
Section 5.0 x
Revised to add definitions for Controller, Evaluator, Mentor, Observer, Participant, and Performance Enhancing Experience and deleted definition for SAMG Evaluator. Also deleted outdated information related to EBN software changes in the EBN definition, added additional clarifying wording to the Integrated Training Drill definition, and updated the definition of Key Skills to include additional detail previously contained in the deleted Attachment 8.
Attachments 1, 7, 11, 12, 13, 15 x
Deleted these attachments and renumbered attachments.
x Minor updates to objective wording and objective facility assignment.
x Replaced existing table for Objectives for Drills and Exercises with a new table with more detailed listing of drills and associated objectives.
Source Notes x
Updated source notes to reflect applicable regulatory guidance.
U.S. Nuclear Regulatory Commission CNL-25-066 Page 4 May 5, 2025 The above changes were evaluated in accordance with 10 CFR 50.54(q)(3). TVA determined that the changes did not reduce the effectiveness of the TVA REP. The TVA REP, as revised, continues to meet the requirements in Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b).
There are no new regulatory commitments in this letter. Please address any questions regarding this submittal to Amber V. Aboulfaida, Senior Manager, Fleet Licensing, at avaboulfaida@tva.gov.
Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant NRC Director - Division of Spent Fuel Management, NMSS Digitally signed by Edmondson, Carla Date: 2025.05.05 10:54:22
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