ML20282A345

Issuance of Amendment Nos. 313, 336, 296, 350, 344, 138, and 44 Revise Emergency Plan On-Shift Emergency Medical Technician & Onsite Ambulance Requirements

ML20282A345
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	11/19/2020
From:	Michael Wentzel Plant Licensing Branch II
To:	Jim Barstow Tennessee Valley Authority
Wentzel M
References
EPID L-2020-LLA-0175
Download: ML20282A345 (24)

Text

November 19, 2020 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3; SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2; WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 313, 336, 296, 350, 344, 138, AND 44 RE: REVISE EMERGENCY PLAN ON-SHIFT EMERGENCY MEDICAL TECHNICIAN AND ON-SITE AMBULANCE REQUIREMENTS (EPID L-2020-LLA-0175)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 313, 336, and 296 to Renewed Facility Operating Licenses Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively; Amendment Nos. 350 and 344 to Renewed Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2, respectively; Amendment Nos. 138 and 44 to Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant, Units 1 and 2, respectively. These amendments are in response to your application dated July 31, 2020.

The amendments revise the Radiological Emergency Plan for Browns Ferry Nuclear Plant, Units 1, 2, and 3; Sequoyah Nuclear Plant, Units 1 and 2; and Watts Bar Nuclear Plant, Units 1 and 2; to change the requirement from having an on-shift emergency medical technician to a requirement for an on-shift emergency medical professional. Additionally, the amendments remove the requirement for an on-site ambulance at each site.

J. Barstow A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Michael J. Wentzel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, 50-296, 50-327, 50-328, 50-390, 50-391,72-034, 72-052, and 72-1048

Enclosures:

1. Amendment No. 313 to DPR-33

2. Amendment No. 336 to DPR-52

3. Amendment No. 296 to DPR-68

4. Amendment No. 350 to DPR-77

5. Amendment No. 344 to DPR-79

6. Amendment No. 138 to NPF-90

7. Amendment No. 44 to NPF-96

8. Safety Evaluation cc: Listserv

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 313 Renewed License No. DPR-33

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 313, Renewed Facility Operating License No. DPR-33 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:07:16 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 336 Renewed License No. DPR-52

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, by Amendment No. 336, Renewed Facility Operating License No. DPR-52 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:07:45 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 296 Renewed License No. DPR-68

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, by Amendment No. 296, Renewed Facility Operating License No. DPR-33 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:08:12 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 350 Renewed License No. DPR-77

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 4

2. Accordingly, by Amendment No. 350, Renewed Facility Operating License No. DPR-77 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:08:38 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEQUOYAH NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 344 Renewed License No. DPR-79

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 5

2. Accordingly, by Amendment No. 344, Renewed Facility Operating License No. DPR-79 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:09:06 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-390 WATTS BAR NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 138 License No. NPF-90

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 6

2. Accordingly, by Amendment No. 138, Facility Operating License No. NPF-90 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:09:33 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-391 WATTS BAR NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 44 License No. NPF-96

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (TVA), dated July 31, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 7

2. Accordingly, by Amendment No. 44, Facility Operating License No. NPF-96 is hereby amended to authorize revision to the TVA Radiological Emergency Plan, as set forth in TVAs application dated July 31, 2020, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.11.19 Gavrilas 17:10:00 -05'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: November 19, 2020

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AMENDMENT NO. 313 TO RENEWED FACILITY OPERATING LICENSE NO. DPR 33 AMENDMENT NO. 336 TO RENEWED FACILITY OPERATING LICENSE NO. DPR 52 AMENDMENT NO. 296 TO RENEWED FACILITY OPERATING LICENSE NO. DPR 68 AMENDMENT NO. 350 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-77 AMENDMENT NO. 344 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-79 AMENDMENT NO. 138 TO FACILITY OPERATING LICENSE NO. NPF-90 AMENDMENT NO. 44 TO FACILITY OPERATING LICENSE NO. NPF-96 BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 TENNESSEE VALLEY AUTHORITY DOCKET NOS. 50-259, 50-260, 50-296, 50-327, 50-328, 50-390, 50-391,72-034, 72-052, AND 72-1048

1.0 INTRODUCTION

By letter dated July 31, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20213C730), the Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (Browns Ferry); Sequoyah Nuclear Plant, Units 1 and 2 (Sequoyah); and Watts Bar Nuclear Plant, Units 1 and 2 (Watts Bar). The requested changes would revise the Radiological Emergency Plan (REP) for Browns Ferry, Sequoyah, and Watts Bar by changing the emergency response organization at each of the sites to require an on-shift emergency medical professional rather than an on-shift emergency medical technician (EMT) and would remove the requirement for an on-site TVA ambulance at each site.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance on which the U.S. Nuclear Regulatory Commission (NRC, Commission) staff based its review are provided below.

Enclosure 8

2.1 Regulatory Requirements The planning standards in Section 50.47(b) of Title 10 of the Code of Federal Regulations (10 CFR) establish the requirements that the on-site and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that the licensee can, and will, take adequate protective measures in the event of a radiological emergency. Specifically, on-shift and augmented emergency response organization staffing is addressed under the following planning standards:

10 CFR 50.47(b) states, in part:

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 10 CFR 50.47(b)(2) states:

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.

10 CFR 50.47(b)(12) states:

Arrangements are made for medical services for contaminated injured individuals.

10 CFR 50.47(b)(14) states:

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.

10 CFR 50.47(b)(15) states:

Radiological emergency response training is provided to those who may be called on to assist in an emergency.

In addition,Section IV.E.6 of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR states that adequate provisions shall be made and described for emergency facilities and equipment, including for the following:

Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary.

2.2 Guidance Regulatory Guide 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors (ADAMS Accession No. ML090440294), provides guidance on methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations.

Regulatory Guide 1.101 endorses Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654),

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ADAMS Accession No. ML040420012),

which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for the NRC licensees and State and local governments to develop acceptable radiological emergency plans and to improve emergency preparedness.

NUREG-0654, Revision 1,Section II, Planning Standards and Evaluation Criteria, Evaluation Criterion II.B.9 states, in part:

The licensee shall provide for transportation and treatment of injured personnel who may also be contaminated.

NUREG-0654, Revision 1, Evaluation Criteria II.L.2 and II.L.4, address planning standard 10 CFR 50.47(b)(12). Evaluation Criterion II.L.2 states, [e]ach licensee shall provide for on-site first aid capability. Evaluation Criterion II.L.4 states, in part:

Each organization shall arrange for transporting victims of radiological accidents to medical support facilities.

NUREG-0654, Revision 1, Evaluation Criterion II.N.2.c, addresses the planning standard in 10 CFR 50.47(b)(14). Evaluation Criterion II.N.2.c states, in part:

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.

NUREG-0654, Revision 1, Evaluation Criteria II.O.1.a, II.O.3, and II.O.4.h, address planning standard 10 CFR 50.47(b)(15). Evaluation Criterion II.O.1.a states, [e]ach facility to which the plant applies shall provide site-specific emergency response training for those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency.

Evaluation Criterion II.O.3 states, [t]raining for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media. Evaluation Criterion II.O.4.h states, in part:

specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:

h. Medical support personnel

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed emergency plan changes, as described in the application dated July 31, 2020. The staffs technical evaluation is detailed below.

3.1 Background

TVA stated that the fire brigade at the TVA sites includes medical response personnel whose training has been at the EMT level. TVA further stated that the fire brigade is in the process of reorganizing from being a separately staffed entity to an Operations and Maintenance Department staffed function and that training for the reorganized fire brigade will not require an EMT qualification for medical response. This is contrary to what is specified in the current TVA REP, which specifies using personnel with EMT qualifications.

TVA further stated that the reason for maintaining on-shift EMTs and an on-site ambulance originated from the sites emergency response capabilities during the development of the TVA fleet REP in the mid-1980s. Some of the TVA nuclear plants were geographically isolated from the general population with local volunteer-only fire departments and some volunteer emergency medical service (EMS) agencies that were 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. In addition to the geographical isolation of some of the sites, TVA stated that there was also a concern from multiple ambulance providers about their personnel entering the TVA plants to provide care to contaminated personnel because of being generally unfamiliar with radiological hazards. Furthermore, at that time, these providers were also concerned about transporting a contaminated patient. Certain EMS 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 opted to train all on-shift medical personnel to a minimum of EMT and to have an ambulance on-site to transport contaminated patients to the local hospital.

TVA stated that it has since partnered more closely with local ground and air medical EMS agencies. Local emergency management agencies have also robustly increased their response area and capabilities. As a result of being provided additional information, education, and training concerning contaminated patients, including on how to handle and treat patients to prevent the spread of contamination, EMS agencies are now more agreeable to provide transportation partnerships. Therefore, TVA stated that there is no longer a need to employ the strategy of using an on-site ambulance (manned by an EMT) to transport contaminated patients to medical facilities.

3.2 Evaluation The TVA REP consists of a generic plan that addresses organizational responsibilities, capabilities, actions, and guidelines for TVA during a radiological emergency, and three plant-specific appendices containing the site-specific information.

Replace the Position of EMT with an Emergency Medical Professional TVA proposes an administrative change to Section 17.0, Definitions and Abbreviations, of the TVA REP by inserting the terms emergency medical responder and emergency medical technician into a new definition of a new term emergency medical professional.

Additionally, TVA is proposing to replace a dedicated EMT on-shift with an on-shift emergency medical professional. This emergency medical professional is defined as 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, an EMT, an advanced EMT, or a paramedic.

TVA further states that other shift watch positions meet the evaluation criteria (addressed below), such as Assistant Unit Operator Fire Brigade Members, who are assigned the Advanced Fire Brigade Member curricula under the Fire Operations Transition Initiative. The curricula include First Aid training (which includes administering cardiopulmonary resuscitation, use of the automated external defibrillator, and understanding bloodborne pathogens).

The planning basis in NUREG-0654, Evaluation Criterion II.L.2, addresses planning standard 10 CFR 50.47(b)(12). Evaluation Criterion II.L.2 specifies that each licensee shall provide for on-site first aid capability. The proposed TVA REP, who would replace the requirement for an on-shift EMT with a requirement for an emergency medical responder, would maintain the sites capability to provide on-site first aid to contaminated injured individuals. The proposed REP, therefore, would continue to conform with NUREG-0654, Evaluation Criterion II.L.2.

The planning basis in NUREG-0654, Evaluation Criterion II.O.3, addresses planning standard 10 CFR 50.47(b)(15). Evaluation Criterion II.O.3 specifies the type of training to be provided to licensee first aid team members who may be called on to assist in an emergency as: Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media. The proposed TVA REP would maintain the same level of training to licensee first aid team members, and therefore, would continue to conform with NUREG-0654, Evaluation Criterion II.O.3.

Removal of the Requirement for an On-site TVA Ambulance The planning basis in NUREG-0654, Evaluation Criterion II.B.9, addresses the planning standard 10 CFR 50.47(b)(2). Evaluation Criterion II.B.9 specifies that provisions be made for transportation and treatment of injured personnel who may also be contaminated. Additionally,Section IV.E.6 of Appendix E to 10 CFR Part 50 requires arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary. The local and backup hospitals have not changed and have current letters of agreement for support. The proposed TVA REP maintains provisions for transportation and treatment of injured personnel who may also be contaminated, and therefore, continues to conform with Evaluation Criterion II.B.9.

The planning basis in NUREG-0654, Evaluation Criterion II.L.4, addresses the planning standard 10 CFR 50.47(b)(12). Evaluation Criterion II.L.4 specifies that arrangements be made for transporting victims of a radiological accident to medical support facilities. TVA proposes to remove the requirement for an on-site ambulance at each of the three nuclear sites. TVA states that the principal use of the on-site ambulance is to store medical supplies and equipment in addition to its availability as a means of transporting an injured contaminated individual from the

sites Protected Area to the Owner-Controlled Area. Once the injured contaminated individual is in the Owner-Controlled Area, the individual would be transferred to offsite ambulance services, as required. TVA further states that current procedures for the nuclear sites already contain direction to request offsite response from the facilities with which TVA has transportation agreements and to coordinate this offsite response with Nuclear Security for escort into the Protected Area. This existing protocol makes unnecessary the strategy of using an on-site ambulance at the TVA fleet sites. In addition, response equipment for contaminated individuals is already staged at each of the nuclear facility sites. TVA explained that the current usage of the on-site ambulance as an alternate First Aid Station has been maintained as a backup to the staged response equipment and can continue to be used as such. As the proposed TVA REP maintains provisions for transporting victims of radiological accidents to medical support facilities, the proposed REP continues to conform with the applicable guidance in NUREG-0654, Evaluation Criterion II.L4.

Additionally, TVA proposes to remove from the TVA REP the requirement to have an ambulance radio. The primary mechanism for communication with the local hospitals will remain by telephone with radio communication as the backup method for the TVA fleet sites.

Backup radio communications remain available through site portable radios as identified in the TVA Emergency Plan Implementing Procedures. The proposed TVA REP, therefore, maintains the same provisions for primary and backup communications with the local hospitals.

The planning basis in NUREG-0654, Evaluation Criterion II.N.2.c, addresses the planning standard 10 CFR 50.47(b)(14). Evaluation Criterion II.N.2.c specifies provisions for conducting an annual medical emergency drill. The current TVA REP requires participation by either a TVA or agreement ambulance, in addition to participation by each agreement hospital. TVA proposes an administrative change for the removal of the TVA ambulance at each of the sites from the criteria for these types of drills. The revised TVA REP would still provide for a medical emergency drill involving a simulated contaminated/injured individual with participation by an agreement ambulance and each agreement hospital each calendar year for each plant. As the proposed TVA REP maintains the provisions for a medical emergency drill involving a simulated contaminated/injured individual with participation by an agreement ambulance and each agreement hospital each calendar year for each plant, the proposed REP continues to conform with the guidance in NUREG-0654, Evaluation Criterion II.N.2.c.

The planning bases in NUREG-0654, Evaluation Criteria II.O.1.a and II.O.4.h, address the planning standard 10 CFR 50.47(b)(15). Evaluation Criteria II.O.1.a and II.O.4.h specify, respectively, that radiological emergency response training is to be provided by the licensee for those who may be called on to assist in an emergency and that training shall be provided to medical support personnel. TVA states that the proposed TVA REP provides training for the offsite medical and emergency response personnel and that the training will continue to include the procedures for notification, basic radiation protection, and the personnels expected roles.

For those local service support organizations that will enter the TVA sites, training will continue to include site access procedures and authorization. In addition, the TVA REP training program at each of the sites will remain in place for medical support personnel. As the proposed TVA REP maintains the provisions for radiological emergency response training provided by the licensee for those who may be called on to assist in an emergency, the proposed REP continues to conform with the guidance in Evaluation Criteria II.O.1.a and II.O.4.h.

3.3 Technical Conclusion For the reasons outlined above, the NRC staff finds that the proposed emergency plan changes meet the referenced planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, and provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Therefore, the NRC staff concludes that the licensees proposed changes to the TVA REP in its application dated July 31, 2020, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Alabama and Tennessee State officials were notified of the proposed issuance of the amendments on October 7, 2020. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the site emergency plan. The amendments relate, in part, to changes in recordkeeping, reporting, or administrative procedures or requirements. The amendments also relate, in part, to changing requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding, published in the Federal Register on September 8, 2020, that the amendments involve no significant hazards consideration, and there has been no public comment on this finding (85 FR 55508). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions 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.

Principal Contributor: E. Robinson, NSIR Date: November 19, 2020

ML20282A345 *by e-mail OFFICE NRR/DORL/LPLII-2/PM* NRR/DORL/LPLII-2/LA* NSIR/DPR/RLB/BC*

NAME MWentzel BAbeywickrama JAnderson DATE 10/07/2020 10/20/2020 10/06/2020 OFFICE OGC - NLO* NRR/DORL/LPLII-2/BC* NRR/DORL/D*

NAME CCarson UShoop CErlanger DATE 10/20/2020 10/26/2020 10/27/2020 OFFICE NRR/D* NRR/DORL/LPLII-2/PM*

NAME HNieh (MGavrilas for) MWentzel DATE 11/19/2020 11/19/2020