ML22144A100
| ML22144A100 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 05/12/2022 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Taylor A Tennessee Valley Authority |
| References | |
| L-2022-LLA-0021 | |
| Download: ML22144A100 (4) | |
Text
From:
Green, Kimberly Sent:
Thursday, May 12, 2022 11:44 AM To:
Taylor, Andrew Charles Cc:
Eckermann, J Beau
Subject:
Request for Additional Information Related to TVA's Request to Revised the TVA Plants' Radiological Emergency Plans (EPID L-2022-LLA-0021)
Attachments:
RAI for EAL HU2 LAR.pdf Follow Up Flag:
Follow up Flag Status:
Flagged
Dear Mr. Taylor,
By letter dated January 27, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22027A835), the Tennessee Valley Authority (TVA) requested changes to the radiological emergency plans 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.
Specifically, TVA proposed an exception in Initiating Condition HU2, Emergency Action Level to provide an additional method to declare an event if the operating basis earthquake seismic alarm is out of service.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified an area where additional information is needed to complete its review. Attached, please find a draft request for additional information (RAI).
A draft request for additional information (RAI) was previously transmitted to TVA by email dated May 2, 2022. At your request, a clarification call was held on May 11, 2022, to clarify the NRC staffs draft RAI. As a result of the clarification call, no changes were made to the request.
However, the word radiological was added to the title and introduction paragraph to be consistent with the January 27, request.
As agreed during the call, a response to the attached RAI is requested within 30 days from the date of this email.
The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1627 or via email at Kimberly.Green@nrc.gov.
Sincerely, Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Hearing Identifier:
NRR_DRMA Email Number:
1647 Mail Envelope Properties (DM6PR09MB5462418CD6EA8D7765A22A118FCB9)
Subject:
Request for Additional Information Related to TVA's Request to Revised the TVA Plants' Radiological Emergency Plans (EPID L-2022-LLA-0021)
Sent Date:
5/12/2022 11:43:37 AM Received Date:
5/12/2022 11:43:00 AM From:
Green, Kimberly Created By:
Kimberly.Green@nrc.gov Recipients:
"Eckermann, J Beau" <jbeckermann@tva.gov>
Tracking Status: None "Taylor, Andrew Charles" <actaylor@tva.gov>
Tracking Status: None Post Office:
DM6PR09MB5462.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1892 5/12/2022 11:43:00 AM RAI for EAL HU2 LAR.pdf 512035 Options Priority:
Normal Return Notification:
No Reply Requested:
Yes Sensitivity:
Normal Expiration Date:
REQUEST FOR ADDITIONAL INFORMATION TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-259, 50-260, 50-296, 50-327, 50-328, 50-390, 50-391 LICENSE AMENDMENT REQUEST TO REVISE THE RADIOLOGICAL EMERGENCY PLANS By application dated January 27, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22027A835), the Tennessee Valley Authority (TVA) requested U.S. Nuclear Regulatory Commission (NRC) approval of changes to 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, Radiological Emergency Plans pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR).
The following request for additional information (RAI) is needed to facilitate the NRC staffs technical review.
RAI 1
Issue:
As stated in Section 2.1, Reason for the Proposed Change, of the license amendment request (LAR), revising the HU2 EAL [emergency action level] would ensure that the SM [shift manager]/SED [site emergency director] will make a timely determination by placing a 15-minute clock on the ability to gain additional information through the addition of a Note.
Furthermore, having an additional method of event declaration may prevent avoidable notifications of unusual events by giving operators more flexibility in determination.
However, based on a review of the LAR, it appears that TVA is providing an additional HU2 threshold value, which would require an unusual event declaration if EAL 2.b is not able to be confirmed within 15 minutes, that the shift manager must confirm the occurrence of a seismic event in a manner that may require information provided in the proposed EAL #2 Basis discussion. Although TVA appears to be providing similar information as that provided by NEI 99-01, Revision 6, the proposed HU2 does not appear to consider human factors, nor does it appear to be user-friendly.
Request:
Provide a justification that supports a deviation from the guidance provided by NEI 99-01, Revision 6. This justification should specifically explain why the HU2.b threshold value, a note related to that threshold value, and the HU2.b basis discussion may all need to be referenced to support an accurate assessment for a seismic event.