ML20246G864

Site Emergency Plan Implementing Procedure Revision

ML20246G864
Person / Time
Site:	Browns Ferry
Issue date:	09/02/2020
From:	Bono S Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML20246G864 (3)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 September 2, 2020 10 CFR 50.54(q) 10 CFR 50, Appendix E 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

Subject:

Browns Ferry Nuclear Plant - Site Emergency Plan Implementing Procedure Revision In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q); 10 CFR 50, Appendix E; and 10 CFR 72.44(f), the Tennessee Valley Authority (TVA) is submitting a description of changes to the Browns Ferry Nuclear Plant (BFN) Radiological Emergency Plan. The affected document is the BFN Emergency Plan Implementing Procedure (EPIP) named below.

EPIP Revision Title Effective Date EPIP-13 0025 Dose Assessment 8/3/2020 Description of Changes and Summary of Analysis EPIP-13 Revision 25 made the following changes which were not editorial or typographical:

1. Replaced the Manual Dose Assessment Spreadsheet with Meteorological Information and Dose Assessment Software (MIDAS) as the primary method of onsite dose assessment.

This included replacing all references to the dose assessment spreadsheet with MIDAS references, and renaming Attachments 1 and 2 to align with replacing the dose assessment spreadsheet with MIDAS as the primary dose assessment method.

2. Rewrote step 3.6[1] to update the methods for obtaining meteorological data when performing the manual dose assessment.

3. Added clarifying information to provide enhanced direction for obtaining dose rates from the HCVS rad monitors on the applicable Main Control Room panels in step 1.0[1] of

U.S. Nuclear Regulatory Commission Page 2 September 2, 2020 Attachment 8. Included in this proposed change, is the addition of the MCR panel for each unit where the HCVS rad monitor is located in the table in step 1.0[1.1].

4. Added the following clarifying information to the conversion factor table in step 1.0[2] of Attachment 8:

a. Under Core Condition, identifies that the conversion factor is for RCS.

b. Add footnote to Fuel Damage to clarify that the Fuel Damage Core Condition is used for Gap, core damage, and fuel melt.

5. Added a footnote to clarify the source of information used to complete sections 1.0 and 2.0 of Attachment 5.

6. Updated all instructions related to the results of performing actions in SPDS/PEDS when performing a dose assessment. These changes resulted from updating the ICS/SPDS interface on Unit 3.

The above activities were determined to be changes to the radiological emergency plan that were not editorial or typographical in nature. These changes were also determined to not conform to activities that had prior approval. Planning Standards 10 CFR 50.47(b)(9) - Accident Assessment was determined to be impacted by these changes; therefore, it was concluded that these activities could not be implemented without performing a 50.54(q) reduction in effectiveness evaluation.

Upon completion of the Effectiveness Evaluation Form it was concluded that these activities continue to comply with the requirements of 50.47(b) and 50 Appendix E, and the activities do not constitute a reduction in effectiveness. Therefore, the activities were allowed to be implemented without prior approval.

Additionally, EPIP-13 Revision 25 removed the footnote associated with the HCVS Radiation Monitor from steps 1.0[1.1] and 2.0[1] in Attachment 8. This change to the radiological emergency plan was screened as editorial because it is an annotation change that does not affect the functions, processes, responsibilities, and requirements of the performance of the procedure. No changes to the methods currently in use for calculating the impact of a radioactive release are being made in this revision. The addition of the HCVS radiation monitor (3-RM-90-0062) was evaluated and implemented by DCN 71391. Therefore the activity can be implemented without performing a 50.54(q) reduction in effectiveness evaluation.

Finally, EPIP-13, Revision 25 included various additional changes throughout the document which were determined to be editorial or typographical in nature and could therefore be implemented without performing a 50.54(q) reduction in effectiveness evaluation.

There are no new regulatory commitments in this letter. If you have any questions regarding this submittal, please contact B. F. Tidwell at (256) 729-3666.

U.S. Nuclear Regulatory Commission Page 3 September 2, 2020 Respectfully, S. M S M.. Bo B ono Bono Site Vice President cc:

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRR Project Manager - Browns Ferry Nuclear Plant NRC Director - Division of Spent Fuel Management, NMSS