ML18309A019

Site Emergency Plan Implementing Procedure Revision

ML18309A019
Person / Time
Site:	Browns Ferry
Issue date:	11/05/2018
From:	Hughes D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML18309A019 (2)

Text

Tennessee Valley Authority , Post Office Box 2000, Decatur, Alabama 35609-2000 November 5, 2018 10 CFR 50.4 10 CFR 50.54(q) 10 CFR 50, Appendix E 1O 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 Effective Date EPIP-15 0013 Emergency Exposure 10/04/2018 Description of Changes and Summary of Analysis EPIP-15, Revision 13, incorporated changes to the Emergency Exposure Reference Guide flowchart in Appendix B of the procedure. The diamond shaped decision blocks and the footnote reference definitions for notes 2 and 3 were rewritten on page 11 of the procedure. These changes were proposed to improve alignment of the flowchart with guidance in the Radiological Emergency Plan (REP). This activity was determined to be a non-editorial or typographical change to the REP and did not conform to an activity that had prior approval. The 10 CFR 50.47(b)(11 )

planning standard (Radiological Exposure Control) was impacted by this change; therefore, it was determined that a 10 CFR 50.54(q) Reduction in Effectiveness evaluation was required . The changes evaluated in this revision ensure that the procedure is aligned with regulatory and procedural requirements listed in Block 3 of the Effectiveness Evaluation form and remove ambiguity associated with the listed emergency exposure limits. The changes were designed to

U.S. Nuclear Regulatory Commission Page 2 November 5, 2018 improve the readability of the sections that list emergency dose limits. In conclusion , the activity did not constitute a reduction in effectiveness and was implemented without prior approval.

EPIP-1 5, Revision 13, also incorporated several editorial changes . Quotation marks were added around the title of EPA-400-R-92-001 and 1O CFR 20.1201 in sections 1.1 and 2.1 of EPIP-15.

Quotation marks were also added around the title of NPG-SPP-05.1O in step 3.3.B. Unnecessary spaces were removed around dashes throughout the document. The word "Appropriate" was added and the word "Risk" was made lower case in the second column of the table in step II of Appendix A to ensure alignment with the table in EPA-400. Lastly, "Site Emergency Director (SEO)" was added in the first paragraph of Appendix B after the acknowledgement statement.

These activities were changes to the REP; however, they were editorial in nature. Therefore, a 10 CFR 50 .54(q) Reduction in Effectiveness evaluation was not required , and the activity was implemented without prior approval.

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.

D. L. Hughes 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