CNL-16-099, Radiological Emergency Plan Revision

Radiological Emergency Plan Revision

ML16172A245
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	06/20/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNL-16-099 EPDP-3, Rev.14
Download: ML16172A245 (8)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402

CNL-16-099

June 20, 2016 10 CFR 50.54(q) 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 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327, 50-328, and 72-034

Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390, 50-391, and 72-1048

SUBJECT:

Tennessee Valley Authority -

Radiological Emergency Plan Revision

In accordance with the requirements of Title 10 of the Code of Federal Regulations

(10 CFR) 50.54(q) and 10 CFR 72.44(f), enclosed is a report of changes made to the Tennessee Valley Authority (TVA) Radiological Emergency Plan (REP). The revised documents include two appendices of the REP, one Central Emergency Control Center (CECC)

Emergency Plan Implementing Procedure (EPIP), and one TVA Nuclear Power Group (NPG) Emergency Preparedness Department Procedure (EPDP).

The affected documents and their effective dates are listed below.

Document Revision Title Effective Date REP Appendix A 107 Tennessee Valley Authority Nuclear Power Radiological Emergency Plan Appendix A: Browns Ferry Nuclear Plant 05/21/2016 REP Appendix C 110 Tennessee Valley Authority Nuclear Power Radiological Emergency Plan Appendix C: Watts Bar Nuclear Plant 06/03/2016 CECC EPIP-11 16 Security of Offs ite Emergency Fac ilities 06/02/2016 EPDP-3 14 Emergency Plan Exercises and Preparedness Drills 05/24/2016

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-1 Affected Document Description of Changes Summary of Analysis of Change REP Appendix A, Revision 107 In Drywell Radiation Emergency Action Levels (EALs) 2.3-S2 and 2.3-G2, and in Loss of Primary Containment EAL 2.5-U, references have been added to Fire Safe Shutdown (FSS) procedures in Table 2.3/2.5-U. This change is a result of the BFN transition to National Fire Protection Association Standard 805 (NFPA 805). The FSSs are replacing Safe Shutdown Instructions (SSIs) and in some places will be executed concurrently with the symptom-based Emergency Operating Instructions (EOIs) and other operating procedures. This change is considered editorial.

REP Appendix A, Revision 107 In Control Room Evacuation EALs 6.2-A and 6.2-S, reference to procedure "0-SSI-16" has been replaced with "1, 2, or 3-FSS-16-2." In EAL 6.2-S, the reference to the BFN Fire Protection Report was replaced with a reference to the NFPA 805 analysis for AREVA Fuel Peak Clad Temperature.

This change is a result of the BFN transition to NFPA 805. This change is considered editorial. REP Appendix A, Revision 107 In Table 3.2, the location description for Radiation (Rad) Monitor 90-23A was revised from "Tip Drive Area" to "RB el 565 NE." The "TIP Drive Area" is synonymous with "RB el 565 NE." The revised terminology is consistent with EOI-3. Thus, this change assists operators by aligning the REP with the EOI terminology. This change is considered editorial.

REP Appendix C, Revision 110 The name of Athens Regional Medical Center was changed to Starr Regional Medical Center. This is a name change only. The change is consistent with the list of agreement letters contained in Section 16.5 of the Generic REP. This change is considered editorial.

REP Appendix C, Revision 110 Figure 6-C was revised to update the layout of the Alternate Operations Support Center, which is located in the Outage Control Center (OCC).

No change has been made to the function of the OCC as the Alternate Operations Support Center. This change is considered editorial. REP Appendix C, Revision 110 Figures 4-A and 5-A were revised to reflect the current Protected Area Boundary, which now includes the cooling towers and the recently constructed Independent Spent Fuel Storage Installation (ISFSI). EALs 4.1, 4.2, and 4.6 reference these drawings for defining the protected area, however no changes have been made to the EALs themselves. A standard scheme of emergency classification and action levels continues to be in use. The means for determining whether a threshold has been reached remains unchanged. The changes to the protected area appropriately include other structures, and the drawings accurately reflect the current protected area boundary. There is no effect on the timeliness or capability to declare an emergency related to the protected area boundary as a result of this change.

The change does not constitute a reduction in effectiveness.

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-2 Affected Document Description of Changes Summary of Analysis of Change REP Appendix C, Revision 110 An EAL related to spent fuel storage has been added to REP Appendix C. EAL 7.5 is added to provide for the declaration of an Unusual Event when damage to a loaded cask confinement boundary has occurred. The new EAL is based on NEI 99-01, Revision 4. TVA has prepared a location for an ISFSI and Watts Bar Nuclear Plant (WBN) will soon become a General Licensee under 10 CFR Part 72. The addition of this EAL ensures that the REP appropriately considers all potential accident sequences and types, including damage to spent fuel storage casks located at the ISFSI.

The new EAL appropriately considers the release of radioactive materials and the appropriate level at which an emergency should be declared. This EAL is based on the NEI 99-01, Revision 4 scheme. NUMARC/NESP-007 did not contain guidance for a spent fuel storage EAL. Revision 4 of NEI 99-01 was utilized because there are other TVA EALs currently in use that are based on NEI 99-01, Revision 4. The addition of this EAL does not represent an entire EAL scheme change. The change does not affect the timeliness of other EAL declarations.

The change does not constitute a reduction in effectiveness.

CECC EPIP-11, Revision 16 Section 7, "Records," was corrected to identify Attachment 10, Q.E.D. Saliva Alcohol Testing, as a QA record, and Attachment 4, Browns Ferry Joint Information Center (JIC), as a non-QA record. This change does not impact compliance with the planning standards of 10 CFR 50.47(b) or 10 CFR 72.44(f) and does not involve a site-specific Emergency Planning commitment. CECC EPIP-11, Revision 16 CECC and JIC sign-in logs in Attachments 7 and 8 have been revised to add a column for Contact Number. These attachments are used to document personnel who must be issued a temporary badge for entry into the facilities. The process for allowing entry remains unchanged; the change will facilitate ensuring all badges are returned after an event. Prior to the change, Security personnel had no method to contact personnel who received a temporary badge and do not return it. The additional column ensures that, in the event that someone fails to return their badge, Security can contact the person and have the badge properly returned.

This change does not impact compliance with the planning standards of 10 CFR 50.47(b) or 10 CFR 72.44(f) and does not involve a site-specific Emergency Planning commitment.

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-3 Affected Document Description of Changes Summary of Analysis of Change EPDP-3, Revision 14 The JIC Liaison position has been removed from the drill objectives. The change to remove the JIC Liaison position from the Emergency Response Organization (ERO) was previously determined to not be a reduction in effectiveness during Revision 106 to the Generic REP. The changes to drill objectives in EPDP-3 do not eliminate the evaluation of the attribute of emergency response because the objective will still evaluate the performance of the Public Information Manager. No change has been made regarding how weaknesses in the program are identified or corrected. The change does not affect actions taken during an actual emergency.

The change does not constitute a reduction in effectiveness. EPDP-3, Revision 14 The following changes were made: Section headings were renumbered and retitled to conform to Writer's

Manual (WM)-1.1. Instances of "and/or," "etc.," "i.e.," and "e.g." were replaced to the extent possible to conform with WM-1.2 and WM-1.5. "Site EP Manager" was capitalized throughout. "Section" was capitalized throughout. Definitions were reformatted to conform with WM-1.2 Outdated terminology "Service Request" was replaced with

"Condition Report" The list of acronyms and abbreviations were relocated to conform with WM-1.1 "Source Documents" and "Business Requirements" sections were removed to conform with WM-1.1. Source references were replaced throughout procedure. References were corrected in Sections 6.1 and 6.2. NIMS [National Incident Management System] was spelled out in the definitions section. "Appendix" was spelled out in Other minor editorial changes were made such as removal of unnecessary commas. The changes are considered editorial.

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-4 Affected Document Description of Changes Summary of Analysis of Change EPDP-3, Revision 14 The following changes were made: A responsibility was added for the Site EP Manager to schedule required meetings. This change was made to ensure that meetings are scheduled following Graded Exercises such that appropriate levels of Site Management are available to support the NRC. A requirement was added to validate drills and exercises and to ensure the validation does not occur too far in advance of the drill or exercise. A requirement to attach objective evidence was added to Attachment 15, Checklist to Ensure Drill and Exercise Diversity, based on an NRC request. Attachment 17 regarding "Special Considerations for Large Scale, Multi-Agency Drills and Exercises" was added to add additional information regarding infrequently performed large scale exercises. Attachment 16 was clarified to state the 1250 meter mixing depth assumption would be used by FEMA. This does not change how TVA evaluates releases.

These changes do not impact compliance with the planning standards of 10 CFR 50.47(b) or 10 CFR 72.44(f) and do not involve a site-specific Emergency Planning commitment.

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-5 Affected Document Description of Changes Summary of Analysis of Change EPDP-3, Revision 14 The following changes were made: A reference to Attachment 14 was added to the drill and exercise instructions in Section 3.2A.2.n. This note will ensure compliance with Source Note R.13 (10 CFR 50, Appendix E, Section IV, Paragraph F.2.j.) The definition of Principal Functional Areas was revised to align with 10 CFR 50, Appendix E, Section IV, Paragraph F.2.b. The terminology of Augmentation "Drill" was revised to Augmentation "Exercise" based on the definitions of drill and exercise in the REP. The Augmentation Exercise frequency was changed from two years to four years based on management discretion. The REP requirement remains eight years. A new Attachment "Eight Year Demonstration of Key Skills" was added based on NSIR/DPR-ISG-01 and NEI Template Checklist for Implementation of NRC Challenging Drills and Exercises Regulation. The yearly drill and exercise instructions were revised to align with the revised definition of Principal Functional Areas.

The changes align definitions with regulatory requirements and existing REP terminology. The new checklist tracks the key skills referenced in 10 CFR 50, Appendix E, Section IV, Paragraph F.2.j. Therefore, the new attachment ensures continued compliance with the regulatory requirements.

The changes to definitions and terminology aligning with regulatory requirements and other REP terminology increase the effectiveness of the REP.

The change to the frequency of Augmentation Exercises from two years to four years is within the REP requirement and ISG guidance of eight years. Because the change remains within the requirements specified by governing documents, there is continued compliance. This change also modified the time it would take to rotate all teams through an Augmentation Exercise. No requirements were identified related to ensuring all teams participated in an off-hours drill or Augmentation Exercise. The effectiveness of the REP is maintained because the ability of the ERO to respond during different periods of the day/night and ensure appropriate response times is tested multiple times during any eight year exercise cycle. The TVA ERO is made up of four teams. In the event of an actual emergency, all four teams would be notified and the minimum activation staff personnel (MASP) for all teams are required to report to the emergency facility. This same process is used for Augmentation Exercises such that, while only one team is on duty, MASP from all four teams are expected to respond. In this way, all four team's MASP is tested every exercise. No change has been made to the expected response of the ERO. This change does not adversely impact tests of the response capability. There is no impact on emergency response actions or timeliness.

The changes do not constitute a reduction in effectiveness.

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision E1-6 Affected Document Description of Changes Summary of Analysis of Change EPDP-3, Revision 14 The External Flooding Drill was revised from being a "required" drill to being a "good practice." Related to the WBN 95002 Inspection, TVA submitted letters to the NRC in August 2013 discussing the details of a planned flood drill that was committed to be performed by the end of 2013. Based on those letters, the external flooding drill commitments identified were one-time commitments that have now been completed.

No further action is required based on the commitments.

The change maintains the effectiveness of the plan. No change was made to the frequency of the drill. Historical data and future plans for performing the drill continue to be tracked. The schedule of the drill has not been changed. The change does not constitute a reduction in effectiveness.

EPDP-3, Revision 14 Attachments documenting historical drill and exercise performances have been updated with 2015 data. The changes update the drill/exercise schedule to track past drills and future drills in accordance with regulatory requirements. The updates ensure that drills and exercises are scheduled to meet regulatory requirements for the eight year cycle.

The changes maintain the effectiveness of the plan. There is no change to how functions are fulfilled. This change does not affect the timeliness with which any functions are fulfilled.

The change does not constitute a reduction in effectiveness.