ML25282A008
| ML25282A008 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/09/2025 |
| From: | Komm D Tennessee Valley Authority |
| To: | Division of Fuel Management, Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML25282A008 (1) | |
Text
Post Office Box 2000, Decatur, Alabama 35609-2000 October 9, 2025 10 CFR 50.54(q) 10 CFR 50, Appendix E 10 CFR 72.44(f)
ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 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 (REP). The affected documents are the BFN Emergency Plan Implementing Procedures (EPIPs) named below.
EPIP Revision Title Effective Date EPIP-1 69 Emergency Classification Procedure 09/10/2025 Description of Changes and Summary of Analysis Revision 69 of BFN EPIP-1, Emergency Classification Procedure, revised the bases for Initiating Conditions (ICs) SS5, SA5, and SU5 to add the definition of shutdown per Emergency Operating Instruction (EOI) Program Manual Section 0-I(C). This revision also added EOI Program Manual Section 0-I(C) to the References section of each IC. The revision addresses an issue identified in CR 1978670 by revising the bases for ICs SS5, SA5, and SU5 to enhance the discussion of a shutdown reactor at BFN U1, U2, and U3. The proposed change is an enhancement to aid the operator in determining a shutdown reactor by furthering the discussion that a shutdown reactor
U.S. Nuclear Regulatory Commission Page 2 October 9, 2025 is when the reactor is subcritical with reactor power below the heating range. This discussion is aligned with the definition found in EOI Program Manual Section 0-I(C).
The change to the BFN EPIP-1 does not alter the IC or Emergency Action Level (EAL) wording as approved by the Nuclear Regulatory Commission (NRC) via letter dated May 2, 2018
[ML18138A452]. The change to the bases for the affected ICs does not alter the wording of the ECL descriptions provided in the TVA REP Appendix A as approved by the NRC via letter dated May 29, 2018 [ML18138A452]. The proposed change serves to minimize human performance errors by incorporating the criteria for determining reactor shutdown as provided in the EOI referenced in the existing bases. The change does not alter the responsibility or timeliness requirements associated with emergency assessment and classification as described in the TVA REP. Therefore, the change incorporated in Revision 69 of BFN EPIP-1 continues to comply with the TVA REP. This change ensures that a standard scheme of emergency classification and action levels is in use for BFN in accordance with 10 CFR 50.47(b)(4), with the attributes specified in 10 CFR 50 Appendix E Sections IV.B and IV.C, and consistent with the NRC endorsed guidance in NUREG-0654/FEMA-REP-1 and NEI 99-01 Revision 6.
This activity is a change to the REP that is not editorial or typographical. The change does not conform to an activity that has prior approval. It was determined that the 10 CFR 50.47(b)(4) -
Emergency Classification System Planning Standard was impacted by this change; therefore, the activity could not be implemented without performing a 10 CFR 50.54(q) reduction in effectiveness evaluation. Upon completion of the Effectiveness Evaluation Form for the change described, it was concluded that the activity continues to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E and the activity does not constitute a reduction in effectiveness. Therefore, the change was allowed to be implemented without prior NRC approval.
There are no new regulatory commitments in this letter. If you have any questions regarding this submittal, please contact Emily J. Cole, Site Emergency Preparedness Manger, at (256)729-4742.
Respectfully, Daniel A. Komm Site Vice President Enclosure Browns Ferry Nuclear Plant - Site Emergency Plan Implementing Procedure Revision
U.S. Nuclear Regulatory Commission Page 3 October 9, 2025 cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRR Project Manager - Browns Ferry Nuclear Plant