ML041810056
| ML041810056 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 06/24/2004 |
| From: | Manny Comar NRC/NRR/DLPM/LPD2 |
| To: | Singer K Tennessee Valley Authority |
| Comar M, NRR/DLPM/415-6074 | |
| References | |
| TAC MB9130 | |
| Download: ML041810056 (13) | |
Text
June 24, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice president Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
SUBJECT:
SAFETY EVALUATION OF THE TENNESSEE VALLEY AUTHORITY PROPOSED RADIOLOGICAL EMERGENCY PLAN CHANGES FOR THE WATTS BAR NUCLEAR PLANT, UNIT 1 (TAC NO. MB9130)
Dear Mr. Singer:
By letter dated May 22, 2003, as supplemented by letters dated January 29, and May 13, 2004, Tennessee Valley Authority (the licensee) submitted proposed changes to the Watts Bar Nuclear Plant Radiological Emergency Plan (REP). The proposed changes are to: (1) remove two maintenance personnel and one Chemist used as advanced radiation workers from onshift positions to augmented positions, and (2) extend the activation time of the Emergency Response Organization for the Technical Support Center and the Operation Support Center from 60 minutes to 90 minutes.
The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the proposed Watts Bar REP changes and supporting documentation. We have concluded that the proposed changes meet the standards of Title 10, of the Code of Federal Regulations (10 CFR)
Section 50.47(b) and the requirements to Appendix E of 10 CFR Part 50. Therefore, the proposed changes are approved. The basis for our conclusions is contained in the enclosed safety evaluation.
Mr. Karl Singer June 24, 2004 On February 25, 2002, the NRC issued an Order modifying the operating license for Watts Bar to require compliance with the interim safeguards and security compensatory measures listed in to the order. Please note that in case of conflicts between the changes approved by this letter and the requirements contained in the interim compensatory measures (ICM), the requirements of the order accompanying the ICM take precedence.
Sincerely,
/RA/
Manny M. Comar, Project Manager, Section 2 Project Directorate ll Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-390
Enclosure:
Safety Evaluation cc w/encl: See next page
Mr. Karl Singer June 24, 2004 On February 25, 2002, the NRC issued an Order modifying the operating license for Watts Bar to require compliance with the interim safeguards and security compensatory measures listed in to the order. Please note that in case of conflicts between the changes approved by this letter and the requirements contained in the interim compensatory measures (ICM), the requirements of the order accompanying the ICM take precedence.
Sincerely,
/RA/
Manny M. Comar, Project Manager, Section 2 Project Directorate ll Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-390
Enclosure:
Safety Evaluation cc w/encl: See next page Distribution:
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RidsNrrDLpmLpdii-2 (WBurton)
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NAME MComar:ckg BClayton EWeiss* WBurton DATE 6/23/04 6/23/04 5/19/04 6/23/04 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EMERGENCY PLAN CHANGES TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNIT 1 DOCKET NO. 50-390
1.0 INTRODUCTION
In the application dated May 22, 2003, as supplemented by letters dated January 29, and May 13, 2004, Tennessee Valley Authority (TVA, the licensee) submitted proposed changes to the Watts Bar Nuclear Plant (WBN), Unit 1, Radiological Emergency Plan (REP). The proposed changes are to: (1) remove two maintenance personnel and one Chemist used as advanced radiation workers (ARW) from onshift positions to augmented positions, and (2) extend the activation time of the Emergency Response Organization (ERO) for the Technical Support Center (TSC) and the Operation Support Center (OSC) from 60 minutes to 90 minutes.
2.0 REGULATORY EVALUATION
The regulatory requirements and guidance for which the Nuclear Regulatory Commission (NRC) staff based its acceptance are as follows:
2.1 Regulations
- Title 10, Code of Federal Regulations (10 CFR) Section 50.47(b)(1) states, in part:
. . . and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- 10 CFR 50.47(b)(2) states, in part: ". . . adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and . . . .
- 10 CFR 50.47(b)(9), states: Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
- 10 CFR 50.47(b)(11), states, in part: The means for controlling radiological exposures, in an emergency, are established for emergency workers . . . .
Enclosure
- 10 CFR 50.54(q), states, in part: The nuclear power reactor licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of 50.47(b) and the requirements of Appendix E to this part.
2.2 Guidance
- Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 4, states, in part: The criteria and recommendations contained in Revision 1 of NUREG-0654/FEMA [Federal Emergency Management Agency]-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47(b) that must be met in onsite and off-site emergency response plans . . . . Licensees and applicants may propose means other than those specified by the provisions . . . for meeting applicable regulations.
- NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, states in part:
In Section B, Onsite Emergency Organization, "5. Each licensee shall specify . . .
functional areas of emergency activity. . . . These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum onshift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment onshift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.
In Section I, Accident Assessment, 8. Each organization, . . . shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards . . . . This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
In Section K, Radiological Exposure, 1. Each licensee shall establish onsite exposure guidelines . . . .
In Section O, Radiological Emergency Response Training, 1. Each organization shall assure the training of appropriate individuals.
3.0 TECHNICAL EVALUATION
The NRC staff has reviewed the licencee's regulatory and technical analyses in support of its proposed REP changes, which are described in their application dated May 22, 2003, as supplemented in letters dated January 29, and May 13, 2004. The detailed evaluation below will support the conclusion 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) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.
3.1 Revise the Onshift Staffing Levels and 60-Minute Response Positions.
The licensee proposes two specific changes to the onshift positions assigned emergency response functions and proposes changing the augmentation time of the TSC and OSC from 60 minutes to 90 minutes. Each of the proposed changes is discussed in the following sections.
3.1.1 Changes to Protective Actions (Radiation Protection) - Licensee Justification The removal of two maintenance personnel and one Chemist used as advanced radiation workers (ARWs) from onshift positions to augmented positions is as follows:
The minimum level of staffing at WBN for the onshift ERO exceeds the minimum NRC recommended standard deemed necessary for the performance of accident assessment and mitigation functions. 10 CFR 50.47(b)(2) states, Onshift licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times . . . . NRCs guidance for minimum onshift staffing is detailed in NUREG-0654, Table B-1. Table 2 in this submittal compares the minimum staffing requirements per NRC guidance with the minimum WBN onshift staffing requirements. These staffing levels provide assurance that onshift emergency responders can successfully perform the critical emergency response functions until augmentation personnel arrive. In addition, on-shift personnel may call out any emergency response expertise in an as-needed basis at any time to augment the NRC staff.
Regulation 10 CFR 20.1101(b) requires the use of procedures, engineering controls, and sound radiation protection principles to achieve occupational doses that are As Low As Reasonably Achievable (ALARA). WBN has radiation monitoring instrumentation in place to assist in determining in-plant dose rates.
Examples include, Area Radiation Monitors and Continuous Air Monitors. This system can be accessed on the Integrated Computer System (ICS) terminals in the Main Control Room, TSC, and OSC, and has monitoring and trending capabilities reducing the need for Radiation Protection (RP) Technicians in the field.
The WBN Health Physics Information System (HIS) 20 allows plant personnel ingress and egress into radiological controlled areas. Emergency workers acquire a self-reading electronic dosimeter in tandem with a Radiation Work Permit (RWP) to enter and exit controlled access via HIS-20.
The access control features of the system enables emergency workers to self-issue dosimetry, establish and track dose limits, verify that their radiation worker training is current and document that the worker has read and understands the RWP.
The system capabilities relieve the Health Physics (HP) Technician of administrative burdens associated with access control, personnel monitoring, and dosimetry issue. This allows the technician to be assigned to other duties.
Performing in-plant surveys on an as-needed basis in combination with HP coverage and use of in-plant radiation monitoring instrumentation provide the necessary support for on-shift emergency functions. In addition, WBN utilizes advanced radiation workers for REP responder duties. These trained personnel in Operations, Fire Operations, and Chemistry are qualified to perform HP surveys and use HP instrumentation to support their work in radiation and high-radiation areas. The capabilities effectively reduce the manpower requirements for in-plant surveys and the immediate need for additional HP Technician personnel. These personnel receive annual re-qualification training in the following areas:
- In-plant surveys
- Onsite out-of-plant surveys
- HP coverage for repair and corrective actions
- Personnel monitoring In addition, during emergency conditions, WBN has developed an emergency RWP with specific dose limits, and all personnel must use an Electronic Dosimeter.
NRC Staff's Evaluation Adequate [meaning in number and qualification/expertise] back-shift coverage by fully-qualified RP Technicians is essential for a successful response at the onset of an emergency. The initial facility response personnel capabilities and timely actions can be vital to the overall success of responding safely and appropriately to emergencies. Given that timely staff augmentation will occur within the prescribed time (within at least 60 minutes) at the onset of the emergency, a sufficient number of qualified RP Technicians are required to support necessary plant staff actions to assess conditions and take mitigation actions. These mitigation assessments and actions will likely involve entry into plant areas with unknown and potentially changing hazardous conditions. These entries may involve various functions (or combinations) including search and rescue, and systems actions (local manual operations). As a function of the accident and its severity, plant areas, while benign during normal operations, could present elevated levels of airborne/external radiation levels as well as immediately dangerous to life and health (IDLH) industrial hazards (e.g., explosive mixtures, smoke, toxic gas, oxygen deficiency).
Until these areas have been evaluated and sufficiently characterized, entries into unknown hazard areas require the use of adequately trained responders familiar with the facility design who are utilizing self-contained breathing apparatus (SCBA).
Entry into such areas of unknown hazards without a proper radiological evaluation (survey) shall not be allowed. Specifically,10 CFR Part 50.47(b)(11), requires licensees to control emergency workers radiation exposures consistent with EPA Emergency Worker and Lifesaving Protection Action Guides. Per 10 CFR Part 20 (20.1501), licensees are required to perform (reasonable under circumstances) evaluations of work areas for hazards to comply with (among other things) worker dose limits. While nothing in Part 20 shall be construed as limiting actions to protect health and safety of the plant and workers (licensees do have the flexibility of
10 CFR 50.54(x)), the fundamental survey requirements of Part 20 do apply relative to entering high and very high radiation areas (with the potential IDLH industrial challenges). How these evaluations are made, consistent with adequately responding to an emergency, while still complying with Part 20, is discussed below.
The Licensee proposes to take advantage of technological advances, relative to providing reasonable and effective "job coverage" for entry teams. During the initial response period of an accident, the normal prework RP Technician survey of the work area is, in most cases, not an acceptable method (i.e., there is insufficient time for the RP Technician to perform the survey and then return to brief the workers). Given the inherent nature of accidents, the work area conditions could have significantly (and unpredictably) changed by the time the workers arrive. In the vast majority of plant locations, installed radiation monitoring equipment is not adequate (or not present) alone to satisfy the evaluation need; additionally, such equipment may not be operational or reliable. Merely equipping each worker with an electronic dosimeter (ED) but no accompanying RP Technician is not an adequate, stand-alone method to satisfy the survey requirement. EDs do provide dose and dose rate alarms, but experience shows clearly that in high noise areas, these alarms are not easily heard. Workers have ignored these alarms; many ED designs are not qualified for high heat/humidity conditions; their relatively small displays may not be visible in high humidity conditions, and EDs should not be used as survey instruments. During normal, stable operations, the typical plant RP Technician controls for entering and working in high radiation areas do not allow worker entry into areas with unknown radiation levels. EDs do provide an additional level of protection for the worker, by offering an electronic time keeping backup and alerting a worker to a change in radiation levels.
Having a dedicated RP Technician focusing on performing an "as we are entering, real-time survey/evaluation of the radiological conditions, under potentially IDLH conditions (and, thus, in SCBA), is considered an essential element of an adequate response team. Once a plant area has been properly surveyed, the licensee is free to decide whether the RP Technician needs to provide continuous coverage based on procedural guidance.
The licensee will perform in-plant surveys on an as needed basis. The licensee states that the current method of using ARWs has proven to be an effective tool in supplementing the need for HP technicians. WBN has an approved emergency plan that utilizes ARWs in conjunction with HP technicians. Watts Bar utilizes 6-10 ARWs that have been trained to assist the RP Technicians in performing onsite and off-site surveys as well as provide off-site dose assessment in accordance with WBN policies and procedures. The capability to complete the functions that the three ARWs previously performed has been maintained, and the licensee has the ability to call in additional resources as needed. In addition, the licensee stated that personnel are expected to respond immediately and without delay upon notification, regardless of their location at the time. The licensee has provided adequate compensation for the three ARWs by maintaining NUREG-0654 Table B-1 30-minute augmented positions on-shift, making updates to technology, and the use of automated systems. Therefore, the proposed changes are acceptable.
3.1.2 Extending the 60-Minute Augmentation Time to 90 Minutes - Licensee Justification The changes to the TVA/WBN REP involve the extension of the times required for ERO personnel to augment on-shift personnel. Specifically, these extensions
replace the augmentation times specified in Table B-1 in NUREG-0654 and NUREG-0737, Supplement 1 which recommends 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or 60 minutes.
The current TVA/WBN REP, Figure 1-C, (page C-204) reflects the 30-minute emergency responders as on-shift responders. These personnel are augmented by 60-minute responders in the Technical Support Center (TSC), Operations Support Center (OSC), and Central Emergency Control Center (CECC) to match the NUREG-0654 guidance.
The additional 30 minutes to the original expected response time is based on a more flexible time frame for off-hour activation when ERO personnel are typically away from the plant site. Personnel are, however, expected to respond immediately and without delay upon notification, regardless of their location at the time. Additionally, this change will require that on-site ERFs [Emergency Response Facilities] also be activated within 90 minutes. These changes represent a relaxation of the current goals established in the WBN REP to staff and activate the onsite emergency facilities within approximately 60 minutes.
This also requires WBN to take exception to the guidance established in NUREG-0737, Supplement 1, Section 8.2.1.j, which states in part, that the TSC will " . . . be fully operational within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation.
10 CFR 50.47(b) and 10 CFR 50, Appendix E establish emergency planning standards that require: 1) adequate staffing, 2) satisfactory performance of key functional areas or REP critical functions, and 3) timely augmentation of the response capability. The justification in this submittal establishes that WBN will continue to meet these standards once the proposed changes are implemented.
Currently, many plant personnel are precluded from being assigned to key ERO positions due to the remote location of the plant and the associated commuting distance to the plant. The proposed change will increase the number of eligible plant personnel to fill critical ERO positions.
WBN performed a survey and evaluation of the driving time from the homes of plant personnel to the WBN site. Approximately 30 percent of the ERO live within approximately 30 minutes (driving time) from the site. Approximately 70 percent live 40 minutes or greater from the site. These percentages are comprised of predominantly engineers, maintenance, radiation protection and technical support personnel.
To meet facility and augmentation staffing requirements, WBN currently excludes personnel living greater than 40 minutes driving time or provides training to specific responders to hold dual positions until relief arrives for some critical ERO positions. Adding the proposed additional 30 minutes to the augmentation time will allow WBN to add valuable expertise by allowing additional plant personnel to fill critical ERO staff positions and could allow increasing the number of response teams from three to four. This increase in response teams would also standardize the teams with the other TVA nuclear units.
Based on the staffing that will occur in the TSC, OSC and CECC, sufficient staffing and expertise will be available to the onshift staff within 90-minutes of declaration to protect the health and safety of the public. This is due to dedicated responders promptly reporting to the event.
As stated in the Table 2, of the licensee letter dated May 13, 2004, onshift staffing at WBN for its single unit will still exceed, the recommended minimum onshift staffing levels presented in NUREG-0654 due to maintaining the 30-minute responders onshift. These additional onshift resources are available immediately and can be allocated to perform or support response activities in the areas of Radiation Protection, Core/Thermal Hydraulics assessment, Non-Licensed Operator functions (equipment operators), Fire Fighting, and Off-site Dose Assessment. Furthermore, the proposed 90-minute augmentation measures provide added support to the onshift organization in the key functional areas of command and control, technical support, maintenance, and off-site dose assessment.
TVA has concluded that the extent of on-shift staffing at WBN, as delineated in Table 2 of the supplemented letter dated May 13, 2004, provides a level of staffing and expertise that is sufficient to compensate for the extended augmentation time.
With this additional depth and expertise, the onshift staff still is capable of accomplishing the emergency response critical functions for 90 minutes without the need for an advanced augmentation by selected personnel, or for separate response goals based on the physical location of responders (i.e., on-site versus off-site). This does not preclude the Shift Manager from directing additional personnel to respond immediately to augment the shift staff at any time, regardless of the status of plant conditions or the emergency class. [Reference WBN REP Section 5.2.1(5) page 19, and WBN EPIP 2]
The staffing levels of the OSC/TSC remain the same. The three positions that are being removed from the onshift staffing will become part of the OSC augmentation staffing team. To enhance the TSC/OSC staffing, three existing manager positions are being added as minimum staffing positions. These positions, the OSC Manager, the Maintenance Manager, and the Chemistry Manager, are now required to be staffed before the OSC/TSC is considered operational. [Reference TVA/WBN REP Figures 2-C and 3-C]
WBN onshift staffing will be sufficient to manage an emergency event until additional augmentation staffing can arrive within 90 minutes.
In addition, technical advancements have been made to the TVA/WBN REP program since the original implementation of the REP for WBN in April 12, 1995.
These proposed 90-minute augmentations for the TSC and OSC are expected to be the maximum time for personnel to respond to a notification. The allowance of the 90 minutes will not be applied as permission to delay response to an
event. ERO personnel on the duty team are expected to respond to an emergency, as soon as possible and without delay. Responders are trained in specific assignments to provide subsequent ERO coverage. This expectation ensures the rapid mobilization of the necessary "fit-for-duty" emergency personnel to augment the initial response staff (on-shift personnel).
The WBN location is a remote site pursuant to the site standards contained in 10 CFR 100, with emphasis on the 2-mile distance from the center of the Unit-1 reactor. The residents in this zone are distributed such that there is a reasonable probability that appropriate protective measures could be taken in their behalf in the event of a serious accident. The largest population centers are located outside of the 5-mile emergency planning zone (EPZ) and include the towns of Spring City and Decatur. A large portion of the EPZ includes Watts Bar Lake.
A review of population changes confirms that the proposed revision is consistent with the regulatory review of record for population distributions and projections.
The population in the immediate vicinity of WBN reflects a low population zone pursuant to the standards of 10 CFR 100. The population within the 5 to 10-mile EPZs has increased moderately since the original population figures were used for the WBN Final Safety Analysis Report (FSAR) and evacuation time estimates for the WBN REP. Table 3 shows the population growth in the 10-mile EPZ based on available 2000 Census data.
Table 3 Population Growth for the WBN 10-mile EPZ Distance from WBN Initial Licensing Year 2000 0 to 5 miles 3,003 11,399 5 to 10 miles 12,479 15,816 Total 15,482 27,215 The population within the 2-mile area has remained low (approximately 728) with most increases occurring in the 3 to 5-mile siting from the plant. However, the population is still considered small enough so that prompt protective actions could be taken by TVA and the appropriate offsite authorities, prior to full augmentation by the ERO. There are no general site characteristics or general population features that are at variance with the standard for remote siting and low population.
NRC Staff Evaluation
The licensee proposes to extend the augmentation times for the TSC and the OSC from 60 minutes to 90 minutes. The licensee has provided additional information regarding the technical basis, duties of the on-shift staff, revised Table 2 (attachment 1), and the CECC. The technical basis consists of:
- key functions are maintained onshift
- emergency facilities are notified at an alert declaration
- the CECC will still be activated within 60 minutes
- emergency response personnel are expected to respond immediately upon notification Advancements in technology and automation of processes have reduced the on-shift workload.
In addition, the CECC currently assists the TSC in performing:
- technical assessments
- dose/environmental assessments
- radiological assessments
- state/local governmental agency coordination
- logistics support The CECC can provide support to the main control room during the additional 30 minutes that has been proposed by WBN. This will provide reasonable assurance that protective measures can and will be implemented to protect the health and safety of the public.
The TSC and the OSC are to be fully staffed in the expected maximum time of 90 minutes and the ERO is expected to respond immediately without delay once notified. In addition, WBN has added to its onshift ERO staff a TSC Maintenance Manager, an OSC Maintenance Manager, and a Chemistry Manager. These positions will aid in the response effort by planning and directing existing on-shift staff that would report to the TSC/OSC. Given the above, the proposed changes are acceptable.
4.0 CONCLUSION
The licensee states in their subsequent letter dated May 13, 2004, that as a result of a full assessment of the Watts Bar REP in accordance with 10 CFR 50.54(q), Appendix E to 10 CFR Part 50, and other NRC guidance, the proposed REP changes are considered an alternative method for complying with the regulations, therefore, NRC approval is required prior to implementation.
The NRC staff has determined that the licensee's proposed WBN REP changes in its application dated May 22, 2003, and as supplemented by the letters dated January 29 and May 13, 2004, are acceptable. The NRC staff also finds that the WBN Emergency Plan changes meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E of 10 CFR Part 50. Therefore, the NRC staff concludes, 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) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: K. Williams Date: June 24, 2004
Mr. Karl W. Singer Tennessee Valley Authority WATTS BAR NUCLEAR PLANT cc:
Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Paul L. Pace, Manager Nuclear Operations Licensing and Industry Affairs Tennessee Valley Authority Watts Bar Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Spring City, TN 37381 Mr. James E. Maddox, Vice President Mr. Larry S. Bryant, Manager Engineering & Technical Watts Bar Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place P.O. Box 2000 1101 Market Street Spring City, TN 37381 Chattanooga, TN 37402-2801 Senior Resident Inspector Mr. William R. Lagergren Watts Bar Nuclear Plant Site Vice President U.S. Nuclear Regulatory Commission Watts Bar Nuclear Plant 1260 Nuclear Plant Road Tennessee Valley Authority Spring City, TN 37381 P.O. Box 2000 Spring City, TN 37381 County Executive Rhea County Courthouse General Counsel 375 Church Street Tennessee Valley Authority Suite 215 ET 11A Dayton, TN 37321 400 West Summit Hill Drive Knoxville, TN 37902 County Mayor P. O. Box 156 Mr. T. J. Niessen, Acting General Manager Decatur, TN 37322 Nuclear Assurance Tennessee Valley Authority Mr. Lawrence E. Nanney, Director 6A Lookout Place Division of Radiological Health 1101 Market Street Dept. of Environment & Conservation Chattanooga, TN 37402-2801 Third Floor, L and C Annex 401 Church Street Mr. Mark J. Burzynski, Manager Nashville, TN 37243-1532 Nuclear Licensing Tennessee Valley Authority Ms. Ann P. Harris 4X Blue Ridge 341 Swing Loop Road 1101 Market Street Rockwood, Tennessee 37854 Chattanooga, TN 37402-2801