CNL-20-047, Brown Ferry Nuclear Plant, Sequoyah Nuclear Plant & Watts Bar Nuclear Plant - Tennessee Valley Authority License Amendment Request to Revise Radiological Emergency Plan Regarding On-shift Emergency Medical Technician and Onsite Ambulance
| ML20213C730 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 07/31/2020 |
| From: | Jim Barstow Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| CNL-20-047 | |
| Download: ML20213C730 (23) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-20-047 July 31, 2020 10 CFR 50.90 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 License Amendment Request to Revise Radiological Emergency Plan Regarding On-shift Emergency Medical Technician and Onsite Ambulance Requirements In accordance with 10 Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) requests an amendment to the Radiological Emergency Plan (REP) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3; Sequoyah Nuclear Plant (SQN), Units 1 and 2; and Watts Bar Nuclear Plant (WBN), Units 1 and 2.
Specifically, the proposed change involves revising the TVA REP to change the requirement from having an on-shift Emergency Medical Technician (EMT) to a requirement for an on-shift Emergency Medical Professional (which can either be an Emergency Medical Responder, an EMT, an Advanced EMT, or a Paramedic). Additionally, TVA proposes to remove the requirement for an onsite ambulance at each site. These changes will provide TVA with additional medical staffing flexibility, and will serve to resolve a non-conforming condition identified by TVA of occurrences where other medical responders have been on-shift in lieu of EMTs due to staffing perturbations. TVA has reviewed the proposed changes in accordance with 10 CFR 50.54(q), and has determined that this constitutes a reduction in the effectiveness of the approved REP, and thus requires Nuclear Regulatory Commission (NRC) approval. However, these changes are acceptable because the applicable planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revision 1, will continue to be met.
U.S. Nuclear Regulatory Commission CNL-20-047 Page 2 July 31, 2020 The Enclosure provides an evaluation of the proposed changes. The Attachment to the Enclosure provides a markup of the TVA REP.
TVA has determined that there are no significant hazards considerations associated with the proposed changes and that the changes qualify for a categorical exclusion from environmental review pursuant to 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health and the Tennessee State Department of Environment and Conservation.
To alleviate the potential for future non-conformances, TVA requests expedited approval of the proposed changes by November 30, 2020, with a 30-day implementation period.
There are no new regulatory commitments contained in this submittal. If you have any questions concerning this submittal, please contact Gordon R. Williams, Senior Manager, Fleet Licensing (Acting), at (423) 751-2687.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of July 2020.
Sincerely, James Barstow Vice President - Nuclear Regulatory Affairs & Support Services Enclosure cc (Enclosure):
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 State Health Officer, Alabama State Department of Public Health Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation
ENCLOSURE EVALUATION OF THE PROPOSED CHANGE
Subject:
Tennessee Valley Authority License Amendment Request to Revise Radiological Emergency Plan Regarding On-shift Emergency Medical Technician and Onsite Ambulance Requirements Contents 1.0
SUMMARY
DESCRIPTION ................................................................................... 2 2.0 DETAILED DESCRIPTION .................................................................................... 2 2.1 Proposed Changes ........................................................................................... 2 2.2 Background ....................................................................................................... 4
3.0 TECHNICAL EVALUATION
.................................................................................. 5 3.1 Planning Standard L.1 ...................................................................................... 6 3.2 Planning Standard L.2 ...................................................................................... 6 3.3 Planning Standard L.4 ...................................................................................... 6 3.4 Planning Standard N.2.c .................................................................................. 7 3.5 Planning Standard O.1.a .................................................................................. 7 3.6 Planning Standard O.4.h .................................................................................. 7
4.0 REGULATORY EVALUATION
.............................................................................. 7 4.1 Applicable Regulatory Requirements/Criteria ................................................ 7 4.2 Precedent .......................................................................................................... 9 4.3 No Significant Hazards Consideration ........................................................... 9 4.4 Conclusions .................................................................................................... 11
5.0 ENVIRONMENTAL CONSIDERATION
............................................................... 11
6.0 REFERENCES
..................................................................................................... 12 ATTACHMENT Proposed Radiological Emergency Plan Changes (Mark-Ups) for BFN Units 1, 2, and 3, SQN Units 1 and 2, and WBN Units 1 and 2 CNL-20-047 E1- 12
1.0
SUMMARY
DESCRIPTION This evaluation supports a request by the Tennessee Valley Authority (TVA) to amend the Radiological Emergency Plans (REP) for the following facilities:
- Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68
- Sequoyah Nuclear Plant (SQN), Units 1 and 2, Renewed Facility Operating License Nos. DPR-77 and DPR-79
- Watts Bar Nuclear Plant (WBN), Units 1 and 2, Facility Operating License Nos.
NPF-90 and NPF-96 Specifically, the proposed change involves revising the TVA REP to change the requirement from having an on-shift Emergency Medical Technician (EMT) to a requirement for an on-shift Emergency Medical Professional (which can be either an Emergency Medical Responder, an EMT, an Advanced EMT, or a Paramedic).
Additionally, TVA proposes to remove the requirement for an onsite ambulance for each site. These changes will provide TVA with additional medical staffing flexibility, and will serve to resolve a non-conforming condition identified by TVA of occurrences where other medical responders have been on-shift in lieu of EMTs due to staffing perturbations. TVA has reviewed the proposed changes in accordance with 10 CFR 50.54(q), and has determined that this constitutes a reduction in the effectiveness of the approved REP, and thus requires Nuclear Regulatory Commission (NRC) approval. However, these changes are acceptable because the applicable planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revision 1, will continue to be met.
2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The following table itemizes the proposed changes to the REP:
Change REP Location Current Proposed 1 Section 6.8 The plant ambulance has a Sentence deleted.
radio used for communication with the local hospitals and the plant.
2 Section 12.3 The decision to transport a Replaced EMT with patient offsite shall be the Emergency Medical responsibility of the emergency Professional.
medical care provider performing patient assessment, (i.e., EMT or RN.)
If conflicting decisions arise, the option which provides the patient with the optimal level of medical care shall be chosen.
CNL-20-047 E2- 12
Change REP Location Current Proposed 3 Section 12.3 When ambulance Deleted by the site Fire transportation is indicated, Protection EMTs (using a TVA transport may be provided by ambulance) or the site Fire Protection EMTs (using a TVA ambulance) or by an agreement ambulance service. The MERT Team Leader will coordinate any request for offsite ambulance assistance through the SM.
The SM will perform initial requests and notifications for assistance.
4 Section 14.1 A medical emergency drill Revised to read: A medical involving a simulated emergency drill involving a contaminated/injured simulated contaminated/injured individual, with participation by individual, with participation by a TVA or agreement an agreement ambulance and ambulance and each each agreement hospital agreement hospital (see Section 16.5), shall be (see Section 16.5), shall be conducted each calendar year conducted each calendar year for each plant.
for each plant.
5 Section 17 EMR (Emergency Medical Deleted EMR definition.
Responder) - An individual certified under a recognized Deleted EMT definition.
TVA system to provide emergency and related services to victims of illness or injury.
EMT - Emergency Medical Technician 6 Section 17 N/A Added definition for Emergency Medical Professional: An individual certified under a recognized TVA system to provide emergency and related services to victims of illness or injury, which can be either an Emergency Medical Responder (EMR), Emergency Medical Technician (EMT), Advanced Emergency Medical Technician (AEMT), or Paramedic.
7 Appendix A, A first aid station staffed by an Revised to read: A first aid station Section 4.8.2 EMT, is located within the staffed by qualified personnel, to security fence. include an Emergency Medical Professional, is located within the security fence.
CNL-20-047 E3- 12
Change REP Location Current Proposed 8 Appendix A, A TVA ambulance is available Deleted sentence.
Section 4.8.4 at the site and is maintained by Site Fire Protection.
9 Appendix B, First aid is provided by an Revised to read: First aid is Section 6.7.2 EMT. provided by qualified personnel, to include an Emergency Medical Professional.
10 Appendix B, A minimum of one ambulance Deleted sentence.
Section 6.7.2 is also available.
11 Appendix B, A TVA ambulance is available Deleted sentence.
Section 6.7.4 at the site and is maintained and staffed in conjunction with a MERT.
12 Appendix C, 2. Site medical station and Revised to read: 2. Site medical Figure 7-C ambulance station 13 Appendix C, First aid is provided by an Revised to read: First aid is Section 6.7.2 EMT. provided by qualified personnel, to include an Emergency Medical Professional.
14 Appendix C, A minimum of one ambulance Deleted sentence.
Section 6.7.2 is also available.
15 Appendix C, A TVA ambulance is available Deleted sentence.
Section 6.7.4 at the site and is maintained and staffed in conjunction with a MERT.
2.2 Background
Section 3.2 of the TVA REP specifies the onsite organization. The on-shift Fire Shift Operations Staff composition is per the Fire Protection Report for each site. TVA has established that the Fire Brigade includes medical response personnel, whose training has been at the EMT level. The Fire Brigade is in the process of reorganizing from being a separately staffed entity to being an Operations and Maintenance Department staffed function (Fire Operations Transition Initiative).
Training for the reorganized Fire Brigade does not require an EMT qualification for medical response. However, the requirements of the REP currently specify using personnel with EMT qualifications.
The historical context for maintaining onshift EMTs and an onsite ambulance stemmed from the site emergency response capabilities during the development of the TVA Fleet REP in the mid-1980s. Some TVA nuclear plants were geographically isolated from the general population with local volunteer only fire departments and some volunteer Emergency Medical Service (EMS) agencies being significantly delayed in responding, if at all. It was recognized that the best approach was to provide internal staffing so treatment and transport could begin from the site rather than wait for an offsite response to the site with a bare minimum of care. Adding to the geographical isolation of certain sites was the concern from multiple ambulance providers about their personnel entering the TVA plants to package and move patients being generally unfamiliar with radiological hazards. Furthermore, these providers were concerned about transporting a contaminated patient. Certain EMS CNL-20-047 E4- 12
agencies did not want to risk transporting a patient in an ambulance only to remove it from service due to radiological contamination, as many did not have a reserve unit available. During this time period, the state required minimum staffing of an ambulance consisting of one EMT and one ambulance driver. In response, TVA as a fleet, opted to train all onshift medical personnel to a minimum of EMT and have an ambulance onsite to transport contaminated patients to the local hospital. Since that time, TVA has partnered more closely with local ground and air medical EMS agencies. Local Emergency Management Agencies have robustly increased their response area and capabilities. As a result of providing information, education, and training concerning contaminated patients, including how to handle and treat them to prevent the spread of contamination, EMS agencies are more agreeable to provide transportation partnerships. Therefore, TVA no longer needs to employ the strategy of using an onsite ambulance (manned by EMTs) to transport contaminated patients to medical facilities.
3.0 TECHNICAL EVALUATION
10 CFR 50.47(b)(2) requires the on-shift accident response staffing to be defined and maintained in the Emergency Plan. 10 CFR 50.47(b)(12) requires that Emergency Plans include arrangements for medical services for contaminated individuals. Additionally, 10 CFR 50.47(b)(14) and (b)(15) require periodic exercises and radiological emergency response training, respectively. 10 CFR 50 Appendix E further establishes minimum requirements for Emergency Plans for use in attaining an acceptable state of emergency preparedness.Section IV.E.5 to 10 CFR 50 Appendix E requires provisions be made for emergency facilities and equipment with arrangements for medical service providers to handle radiological emergencies onsite.Section IV.E.6 requires arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary.Section IV.F1.vii requires training for medical support personnel.
NUREG-0654 FEMA-REP-1, Revision 1,Section II provides the following planning standards related to medical response which is applicable to the TVA nuclear sites:
L. Medical and Public Health Support
- 1. Each organization shall arrange for local and backup hospital and medical services having the capability of evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.
- 2. Each licensee shall provide for onsite first aid capability.
- 4. Each organization shall arrange for transporting victims of radiological accidents to medical support facilities.
N. Exercises and Drills 2.c A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.
CNL-20-047 E5- 12
O. Radiological Emergency Response Training 1.a Training for hospital personnel, ambulance/rescue, police and fire departments shall include the procedures for notification, basic radiation protection, and their expected roles.
4.h Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories: Medical support personnel.
The following sections describe the compliance with these planning standards relative to the changes identified in Section 2.1 to this Enclosure.
3.1 Planning Standard L.1 This Planning Standard is not affected by these changes. The arrangements for offsite medical care for contaminated injured individuals will remain in place, and do not require modification.
3.2 Planning Standard L.2 This Planning Standard is affected by Changes 5, 6, 7, 9, and 13.
Change 5 - This is an administrative change because the terms Emergency Medical Responder and Emergency Medical Technician are defined within the new definition of the Emergency Medical Professional, as described in Change 6.
Changes 6, 7, 9, and 13 - These changes replace having a dedicated EMT on shift with an Emergency Medical Professional. The on-shift Emergency Medical Professional can be either an EMR, EMT, Advanced EMT, or Paramedic (in order of lowest to highest level of qualification). In addition, other shift watch positions meet this Planning Standard, such as Assistant Unit Operator Fire Brigade Members who are assigned the Advanced Fire Brigade Member curricula under the Fire Operations Transition Initiative. This curricula includes First Aid training (which includes administering Cardiopulmonary Resuscitation, use of the automated external defibrillator, and understanding bloodborne pathogens). First Aid is the medical treatment that is required by the Planning Standard. Therefore, this Planning Standard will continue to be met.
3.3 Planning Standard L.4 This Planning Standard is affected by Changes 1, 2, 3, 10, 11, 12, 14, and 15.
Change 1 - Radio communication with the local hospitals is a backup method of communication. The primary method of communication is via telephone to the primary and backup medical response centers. Backup radio communications still remain available through site portable radios, as identified in site Emergency Plan Implementing Procedures (EPIPs). Removal of the ambulance radio as a requirement will therefore have no adverse effect on site response effectiveness.
Furthermore, offsite EMS will be the primary entity to contact the hospitals with a CNL-20-047 E6- 12
patient care report, and in a Mass Casualty Incident that function is assumed by the EMS Triage and Transportation Officers. A radio is maintained to communicate with offsite agencies responding to an incident at the plant.
Changes 2 - Decision making on transporting an injured contaminated individual is not adversely affected. TVAs Standing Orders and Protocols (medical guidance for patient assessment and treatment provided by the TVA Sr. Physician) provide direction to the Medical Emergency Response Team (MERT) for treatment and assessment to determine if offsite transport is required. TVAs Standing Orders and Protocols, training on their implementation, and the ability of Emergency Medical Professionals to determine when transport is required has already been established and is in place for EMR, EMT, Advanced EMT, and Paramedic qualified individuals at all three nuclear sites. Accordingly, this Planning Standard will continue to be met with this change.
Changes 3, 10, 11, 12, 14, and 15 - These changes will not have an adverse effect on MERT response. The principal use of the onsite ambulance is to store medical supplies and equipment in addition to being a means of transporting an injured contaminated individual from the Protected Area (PA) to the Owner Controlled Area, where transfer can be effected to offsite ambulance services, as required. However, the EPIPs already contain direction to request offsite response and to coordinate this response with Nuclear Security for escort into the PA. Response equipment is already staged in the plant. The ambulance, as an alternate First Aid Station, has been maintained as a backup to staged equipment, and can be continued to be used as such. Accordingly, this Planning Standard will continue to be met.
3.4 Planning Standard N.2.c This Planning Standard is affected by Change 4.
Change 4 - This is an administrative change. Even without the participation of a TVA ambulance, the required drills will continue to be performed with offsite ambulance services, as required by the Planning Standard.
3.5 Planning Standard O.1.a This Planning Standard is not affected by these changes. Training for offsite medical and emergency response personnel will continue to include the procedures for notification, basic radiation protection, and their expected roles. For those local services support organizations who will enter the site, training will continue to include site access procedures and authorization.
3.6 Planning Standard O.4.h This Planning Standard is not affected by these changes. The REP training program will remain in place for medical support personnel, and does not require revision.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.
CNL-20-047 E7- 12
The regulations in 10 CFR 50.54(q) provide direction to licensees seeking to revise their Emergency Plan.
The requirements related to nuclear power plant Emergency Plans are given in the standards in 10 CFR 50.47, "Emergency plans." 10 CFR 50.47(b) states:
The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:
Item 1 of this Part states:
(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
Item 2 of this Part states:
(2) On-shift facility 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, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
Item 3 of this Part states:
(3) Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.
Item 8 of this Part states:
(8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained Item 12 of this Part states:
(12) Arrangements are made for medical services for contaminated injured individuals.
Item 14 of this Part states:
(14) Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
CNL-20-047 E8- 12
Item 15 of this Part states:
(15) Radiological emergency response training is provided to those who may be called on to assist in an emergency..
10 CFR 50 Appendix E Sections IV.A, IV.E.5, IV.E.6, and IV.F1.vii elaborate on these requirements.
NUREG-0654/FEMA-REP-1, Revision 1,Section II, "Planning Standards and Evaluation Criteria," items L.1, L.2, L.4, N.2.c, O.1.a, and O.4.h address the 10 CFR 50.47(b)(12) Planning Standards with respect to this change. Section 3.0 to this License Amendment Request demonstrates that these Planning Standards will continue to be met.
TVA has determined that the proposed changes do not require any exemptions or relief from regulatory requirements and do not affect conformance with any 10 CFR 50, Appendix A, General Design Criteria (GDC) described in the affected plants' Updated Final Safety Analysis Reports (UFSARs).
4.2 Precedent This request is similar to a request made by Dominion Nuclear Connecticut for Millstone Units 1, 2, and 3 and ISFSI, dated May 28, 2009 (Reference 1), although this request was ultimately withdrawn in response to an NRC letter dated April 27, 2010 (Reference 2).
4.3 No Significant Hazards Consideration Tennessee Valley Authority (TVA) is proposing an amendment to modify the Radiological Emergency Plan (REP) for the Browns Ferry Nuclear Plant, Units 1, 2, and 3; the Sequoyah Nuclear Plant, Units 1 and 2; and the Watts Bar Nuclear Plant, Units 1 and 2, to change the requirement for an on-shift Emergency Medical Technician (EMT) to a requirement for an on-shift Emergency Medical Professional (which can be staffed by either an Emergency Medical Responder, an EMT, an Advanced EMT, or a Paramedic). Additionally, this proposed amendment removes the need for a dedicated onsite ambulance.
The proposed changes do not reduce the capability to meet the emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E, or the Planning Standards of NUREG-0654/FEMA-REP-1, Revision 1, which are applicable to the TVA REP. The proposed changes do not reduce the functionality, performance, or ability of TVA's Emergency Response Organization (ERO) medical response capability to respond in mitigating the consequences of accidents.
The proposed changes have been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50, Appendix E, and NUREG-0654/FEMA-REP-1, Revision 1. TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three CNL-20-047 E9- 12
standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes to the TVA REP to revise the requirements for an on-shift EMT and onsite ambulance do not reduce the capability to meet the emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed changes do not reduce the functionality, performance, or ability of TVA's ERO medical response capability to respond in mitigating the consequences of any design basis accident.
The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facilities or the manner in which the plants are operated and maintained. The proposed change does not adversely affect the ability of structures, systems, and components (SSC) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptable limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of any accident previously evaluated. Further, the proposed changes do not increase the types and amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposure.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes to the TVA REP to revise the requirements for an on-shift EMT and onsite ambulance do not involve any physical changes to plant systems or equipment credited for accident mitigation. The proposed changes do not involve the addition of any new plant equipment. The proposed changes will not alter the design configuration, or method of operation of plant equipment beyond its normal functional capabilities. The TVA ERO medical response functions will continue to be performed as required. The proposed changes do not create any new credible failure mechanisms, malfunctions, or accident initiators.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from those that have been previously evaluated.
CNL-20-047 E10- 12
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes to the TVA REP to revise the requirements for an on-shift EMT and onsite ambulance do not alter or exceed a design basis or safety limit. There are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. There are no changes to setpoints or environmental conditions of any SSC or the manner in which any SSC is operated. The applicable requirements of 10 CFR 50.47 and 10 CFR 50, Appendix E will continue to be met.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, TVA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),
and, accordingly, a finding of no significant hazards consideration is justified.
4.4 Conclusions In conclusion, and based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes to the TVA REP; (2) the changes will be in compliance with NRC 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.
5.0 ENVIRONMENTAL CONSIDERATION
The proposed changes are applicable to emergency planning requirements, and do not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and the requirements of Appendix E to 10 CFR 50. The proposed changes do 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet 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.
CNL-20-047 E11- 12
6.0 REFERENCES
- 1. Dominion Nuclear Connecticut, Inc. Letter to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Units 1, 2, 3 and ISFSI Proposed Change to the Millstone Power Station Emergency Plan, dated May 28, 2009 (ML091520618)
- 2. NRC Letter to the Dominion Connecticut, Inc., Millstone Power Station, Unit Nos. 1, 2, 3 and Independent Spent Fuel Storage Installation - Proposed Change to the Millstone Power Station Emergency Plan (TAC Nos. JO0287, ME1396 and ME1397), dated April 27, 2010 (ML100970598)
CNL-20-047 E12- 12
ATTACHMENT Proposed Radiological Emergency Plan Changes (Mark-Ups) for BFN Units 1, 2, and 3, SQN Units 1 and 2, and WBN Units 1 and 2 CNL-20-047
Radiological RADIOLOGICAL EMERGENCY PLAN REP-Generic Emergency (GENERIC PART) Rev. 0110XXX Procedure Page 41 of 94 6.7 EP Radio System The EP radio system is a VHF mobile radio system which provides redundant radio coverage of the 10-mile emergency zone. It provides radiological monitoring vans with mobile communications to other van(s) and to the following locations:
A. Radiation Protection at each plant.
B. Technical Support Center at each plant.
C. Control Room at each plant.
D. CECC in Chattanooga.
6.8 Other Radio Communications There is an in-plant repeater system utilized by Nuclear Security Service which enables transmission without interruption to various areas of the plant. A separate radio located in the plant Central Alarm Station is a direct link to the local law enforcement officials. The plant ambulance has a radio used for communication with the local hospitals and the plant.
Portable two-way radios are available for additional site communications.
Radiological RADIOLOGICAL EMERGENCY PLAN REP-Generic Emergency (GENERIC PART) Rev. 0110XXX Procedure Page 68 of 94 12.3 Transportation of Injured Personnel The decision to transport a patient offsite shall be the responsibility of the emergency medical care provider performing patient assessment, i.e., EMTEmergency Medical Professional or RN. If conflicting decisions arise, the option which provides the patient with the optimal level of medical care shall be chosen.
When ambulance transportation is indicated, transport may be provided by the site Fire Protection EMT (using a TVA ambulance) or by an agreement ambulance service. The MERT Team Leader will coordinate any request for offsite ambulance assistance through the SM. The SM will perform initial requests and notifications for assistance.
Arrangements have been made for one or more agreement ambulance services for each nuclear facility, with trained personnel to transport patients, including those who may have been exposed to or contaminated with radioactive material. These services are designated in the site-EPIPs and letters of agreement for response are maintained. (See Section 16.5) 12.4 Local Hospital Assistance Arrangements have been made for one or more receiving hospitals for each nuclear facility.
These agreement hospitals have adequate equipment and trained personnel to care for ill and injured persons, including those who might have been exposed to or contaminated by radioactive material. Initial notifications are performed by the SM. Hospitals for each site are designated in site EPIPS and letters of agreement are maintained. (See Section 16.5) 12.5 Interagency Assistance from REAC/TS Arrangements have been made for assistance from the Radiation Emergency Assistance Center/Training Site (REAC/TS). REAC/TS is a DOE-sponsored facility operated by Oak Ridge Associated Universities Medical and Health Sciences Division in cooperation with the Oak Ridge Methodist Medical Center in Oak Ridge, Tennessee. Specialized facilities and expert personnel are available, after consultation, for backup definitive care for radiation accident victims. A letter of agreement for services is maintained. (See Section 16.5)
Radiological RADIOLOGICAL EMERGENCY PLAN REP-Generic Emergency (GENERIC PART) Rev. 0110XXX Procedure Page 75 of 94 14.0 DRILL AND EXERCISES 14.1 Drills Drills are conducted to develop and maintain key skills required for emergency response.
These drills may be conducted individually or as part of a REP exercise.
The following drills are required:
A. Medical Emergency Drills A medical emergency drill involving a simulated contaminated/injured individual, with participation by a TVA oran agreement ambulance and each agreement hospital (see Section 16.5), shall be conducted each calendar year for each plant. Scenario development, drill activities, and evaluations are jointly conducted and critiqued by EP and the site.
B. Radiological Monitoring Drills Environmental monitoring van drills shall be conducted each calendar year for each plant. These drills include collection and analyses of sample media (i.e., water, air, grass, and/or soil as may be required by the scenario), direct radiation measurements, operation of vehicles, communication equipment, sampling equipment, and recordkeeping. The scenario is developed and the drill conducted and critiqued by the site or EP.
C. Rad Protection Drills Rad Protection drills will be conducted twice each calendar year for each plant involving response to, and analysis of, simulated elevated airborne samples and direct radiation readings in the plant. The scenario is developed and the drill conducted and critiqued by the site.
D. Radiochemistry Drills Drills shall be conducted each calendar year at each plant to collect and analyze inplant liquid and gaseous samples containing actual or simulated elevated levels, including use or simulated use of the post accident sampling system. The scenario is developed and the drill conducted and critiqued by the site.
E. Radiological Dose Assessment Drills Dose assessment drills are conducted at least twice each calendar year to test the procedures, calculation techniques, computer codes, and environmental assessment abilities of the CECC staff and support groups.
These scenarios are developed and the drill conducted and critiqued by EP.
F. Fire Drills Fire drills are conducted at each plant in accordance with and as required by specific procedural requirements.
Radiological RADIOLOGICAL EMERGENCY PLAN REP-Generic Emergency (GENERIC PART) Rev. 0110XXX Procedure Page 90 of 94 17.0 DEFINITIONS AND ABBREVIATIONS (continued)
COO - Chief Operating Officer.
COC - TVA Chattanooga Office Complex, Chattanooga, Tennessee.
DAC - Derived Air Concentration.
DDE - Deep Dose Equivalent as defined by 10 CFR 20.1201 DHS - Department of Homeland Security - An agency of the U.S. Government.
DOE - U.S. Department of Energy.
DOT - U.S. Department of Transportation.
Drill - A supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. A drill is often a component of an exercise.
EAL (Emergency Action Level) - Specific events and criteria used to determine the appropriate emergency classification.
EDO - Emergency Duty Officer.
Emergency Classification (Also Class or Classification) - A scheme derived to categorize a plant accident into one of four classes according to severity so that appropriate actions might be rapidly taken.
EMR (Emergency Medical Responder) - An individual certified under a recognized TVA system to provide emergency and related services to victims of illness or injury.
EMT - Emergency Medical Technician.
Emergency Medical Professional - An individual certified under a recognized TVA system to provide emergency and related services to victims of illness or injury, which can be either an Emergency Medical Responder (EMR), Emergency Medical Technician (EMT),
Advanced Emergency Medical Technician (AEMT), or Paramedic.
ENS (Emergency Notification System) - The phone line used to notify and inform the NRC of Event Status Data.
Environs - The atmospheric, terrestrial, and aquatic areas outside the site boundary.
EOC - Emergency Operations Center.
EOF - Emergency Operations Facility.
EP Staff - Emergency Services, Emergency Preparedness Staff.
EPA (Environmental Protection Agency) - An agency of the U.S. Government.
Radiological BROWNS FERRY NUCLEAR PLANT REP-Appendix A Emergency RADIOLOGICAL EMERGENCY PLAN Rev. 0110XXX Procedure Page 21 of 25 4.8.1 Decontamination Facilities (continued)
FIGURE A-5 EMERGENCY EQUIPMENT Location Description
- 1. RP Laboratory Service Building Emergency supplies and Radiological survey meters
- 2. Control Bay Emergency SCBAs
- 3. Control Building Mechanical Emergency supplies and Equipment Room radiological survey meters
- 4. Emergency Van General emergency supplies related to environs monitoring
- 5. Huntsville Hospital & Decatur General Supplies specific to radiological Hospital Emergency Rooms injuries
- 6. TSC Emergency supplies
- 7. OSC Emergency supplies 4.8.2 Health Stations and Supplies Emergency medical equipment is strategically located throughout the plant, with trauma kits and other specialized equipment available for use by the MERT.
A first aid station, staffed by qualified personnel, to include an EMTan Emergency Medical Professional, is located within the security fence. Medical supplies and treatments for minor injuries are available. First aid treatment is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
A medical office, staffed by registered nurses and a physician, is located on the first floor of the BFN Visitor and Training Center. Medical treatment and examinations (employment, routine, occupational) are available during the day shift, Monday - Friday.
Potassium iodide tablets for onsite personnel are controlled and stored by site RP. Specific information including authorization and dispersal of tablets is contained in the site EPIPs.
4.8.3 Receiving Hospitals and Supplies Arrangements have been made with a least one hospital to receive patients from BFN.
(See REP-Generic, Sections 12.4 and 16.5.)
4.8.4 Ambulance Service A TVA ambulance is available at the site and is maintained by Site Fire Protection.
Arrangements have been made for offsite ambulance assistance to BFN. (See REP-Generic, Sections 12.3 and 16.5.)
Radiological SEQUOYAH NUCLEAR PLANT REP-Appendix B Emergency RADIOLOGICAL EMERGENCY PLAN Rev. 0107XXX Procedure Page 15 of 28 6.7.2 First Aid Stations and Supplies Emergency medical equipment is strategically located throughout the plant, with trauma kits and other specified equipment available for use by the MERT.
First aid is provided by qualified personnel, to include an EMTan Emergency Medical Professional. Medical supplies and treatment for minor injuries are available. A minimum of one ambulance is also available. First aid treatment is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
A medical office, staffed by registered nurses, is located on site. Medical treatment and examinations (employment, routine, occupational) are available during the day shift, Monday-Friday.
Potassium lodide tablets for onsite personnel are controlled and stored by site Rad Protection. Specific information including authorization and dispersal of tablets is contained in the site EPIPs.
6.7.3 Receiving Hospitals and Supplies Arrangements have been made at least two hospitals to receive patients from SQN. (See REP Sections 12.3 and 16.5) 6.7.4 Ambulance Service A TVA ambulance is available at the site and is maintained and staffed in conjunction with the MERT. Arrangements have been made for offsite ambulance assistance to SQN.
(See REP Sections 12.2 and 16.5) 6.8 Additional Local Support 6.8.1 Fire Arrangements have been made for local fire support upon request. The senior fireman responding will work with and for the TVA Fire Brigade Leader directing the activities of the firemen. Sequoyah will be responsible for providing radiological protection and proper safety clearance in all fire areas. (See REP Section 16.5) 6.8.2 Law Enforcement Agreements are maintained with local law enforcement agencies to support TVA when necessary. (See REP Section 16.5) 6.9 Vendor Support If necessary, the NSSS vendor, Westinghouse, will be contacted by the TSC to provide assistance in the form of manpower, equipment, and technical backup. Other vendors will also be contacted if their assistance is needed.
6.10 Assembly/Accountability Alarm Undulating sirens are provided in strategic areas for indicating the assembly of plant personnel. A three-minute undulating siren is the signal for assembly.
Radiological WATTS BAR NUCLEAR PLANT REP-Appendix C Emergency RADIOLOGICAL EMERGENCY PLAN Rev. 0114XXX Procedure Page 23 of 29 Required calibration of equipment is carried out at intervals recommended by the supplier of the equipment or as specified in the Watts Bar FSAR.
6.7 First Aid and Medical Facilities 6.7.1 Decontamination Facilities The site is responsible for maintaining supplies and equipment to establish a temporary decontamination area for the purpose of gross radiological decontamination and injured person evaluation and stabilization. This area, complete with shower and sink, is located in the Service Building, Elevation 713'. Equipment and materials for decontamination and first aid, including a stretcher, are available.
Figure 7-C EMERGENCY EQUIPMENT Location Description
- 2. Site medical station and ambulance General use emergency medical supplies
- 3. Service Bldg. El. 713 (near breathing air Emergency SCBAs with compressor) additional cylinders
- 4. Decon Facility (Service Bldg. El. 713) Decon supplies
- 5. Emergency Van (RP, environmental Supplies specific to monitoring) environmental monitoring
- 6. Rhea County Medical Center Supplies specific to Emergency Room radiological injuries
- 7. Starr Regional Medical Center Supplies specific to Emergency Room radiological injuries 6.7.2 First Aid Stations and Supplies Emergency medical equipment is strategically located throughout the plant, with trauma kits and other specified equipment available for use by the Medical Emergency Response Team (MERT).
First aid is provided by qualified personnel, to include by an EMTan Emergency Medical Professional. Medical supplies and treatment for minor injuries are available. A minimum of one ambulance is also available. First aid treatment is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
Radiological WATTS BAR NUCLEAR PLANT REP-Appendix C Emergency RADIOLOGICAL EMERGENCY PLAN Rev. 0113XXX Procedure Page 24 of 29 6.7.2 First Aid Stations and Supplies (continued)
A medical office, staffed by registered nurses, is located at the west end of the Watts Bar Training Center. Medical treatment is available during the day and evening shifts.
Examinations (employment, routine, occupational) are available during the day shift, Monday - Friday.
Potassium Iodide tablets for onsite personnel are controlled and stored by site RP. Specific information including authorization and dispersal of tablets is contained in the site EPIPs.
6.7.3 Receiving Hospitals and Supplies Arrangements have been made with the Rhea County Medical Center and Starr Regional Medical Center to receive patients from WBN.
6.7.4 Ambulance Service A TVA ambulance is available at the site and is maintained and staffed in conjunction with the MERT. Arrangements have been made for offsite ambulance assistance to WBN.
6.8 Additional Local Support 6.8.1 Fire Arrangements have been made for local fire support upon request. The senior fireman responding will work with and for the TVA Incident Commander in directing the activities of the firemen. Watts Bar will be responsible for providing radiological protection and proper safety clearance in all fire areas.
6.8.2 Law Enforcement Agreements are maintained with local law enforcement agencies to support TVA when necessary.
6.9 Vendor Support If necessary, the NSSS vendor, Westinghouse, will be contacted by the TSC to provide assistance in the form of manpower, equipment, and technical backup. Other vendors will also be contacted if their assistance is needed.
6.10 Assembly/Accountability Alarm Undulating sirens are provided in strategic areas for indicating the assembly of plant personnel. A three minute undulating tone of the alarm is the signal for assembly.
The sirens are powered by redundant 120V ac supplies. The sirens are activated in the main control room or the auxiliary control room diesel panel.