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 05/21/2016 Radiological Emergency Plan Appendix A: Browns Ferry Nuclear Plant REP Appendix C 110 Tennessee Valley Authority Nuclear Power 06/03/2016 Radiological Emergency Plan Appendix C: Watts Bar Nuclear Plant CECC EPIP-11 16 Security of Offsite Emergency Facilities 06/02/2016 EPDP-3 14 Emergency Plan Exercises and Preparedness Drills 05/24/2016

U.S. Nuclear Regulatory Commission CNL-16-099 Page 2 June 20, 2016 The enclosure provides a summary of the changes and the analysis performed that concluded the changes do not reduce the effectiveness of the REP , and the REP, as revised , continues to meet the requirements in Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b) .

There are no new regulatory commitments in this letter. If you have any questions regarding this submittal, please contact Edward D. Schrull at (423) 751-3850.

Respectfully,

~~~

J. W . Shea Vice President, Nuclear Licensing

Enclosure:

Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision cc (Enclosure) :

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Project Manager - Browns Ferry Nuclear Plant NRR Project Manager - Sequoyah Nuclear Plant NRR Project Manager - Watts Bar Nuclear Plant NRC Director - Division of Spent Fuel Management, NMSS

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision Affected Description of Changes Summary of Analysis of Change Document REP Appendix A, In Drywell Radiation Emergency Action This change is a result of the BFN transition to National Revision 107 Levels (EALs) 2.3-S2 and 2.3-G2, and in Fire Protection Association Standard 805 (NFPA 805).

Loss of Primary Containment EAL 2.5-U, The FSSs are replacing Safe Shutdown Instructions references have been added to Fire Safe (SSIs) and in some places will be executed concurrently Shutdown (FSS) procedures in Table with the symptom-based Emergency Operating 2.3/2.5-U. Instructions (EOIs) and other operating procedures. This change is considered editorial.

REP Appendix A, In Control Room Evacuation EALs 6.2-A and This change is a result of the BFN transition to Revision 107 6.2-S, reference to procedure 0-SSI-16 has NFPA 805. This change is considered editorial.

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.

REP Appendix A, In Table 3.2, the location description for The TIP Drive Area is synonymous with RB el 565 NE.

Revision 107 Radiation (Rad) Monitor 90-23A was revised The revised terminology is consistent with EOI-3. Thus, from Tip Drive Area to RB el 565 NE. this change assists operators by aligning the REP with the EOI terminology. This change is considered editorial.

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

REP Appendix C, Figure 6-C was revised to update the layout No change has been made to the function of the OCC as Revision 110 of the Alternate Operations Support Center, the Alternate Operations Support Center. This change is which is located in the Outage Control considered editorial.

Center (OCC).

REP Appendix C, Figures 4-A and 5-A were revised to reflect EALs 4.1, 4.2, and 4.6 reference these drawings for Revision 110 the current Protected Area Boundary, which defining the protected area, however no changes have now includes the cooling towers and the been made to the EALs themselves. A standard scheme recently constructed Independent Spent Fuel of emergency classification and action levels continues to Storage Installation (ISFSI). 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.

E1-1

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

Revision 4.

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, Section 7, Records, was corrected to This change does not impact compliance with the Revision 16 identify Attachment 10, Q.E.D. Saliva planning standards of 10 CFR 50.47(b) or Alcohol Testing, as a QA record, and 10 CFR 72.44(f) and does not involve a site-specific Attachment 4, Browns Ferry Joint Emergency Planning commitment.

Information Center (JIC), as a non-QA record.

CECC EPIP-11, CECC and JIC sign-in logs in Attachments 7 These attachments are used to document personnel who Revision 16 and 8 have been revised to add a column for must be issued a temporary badge for entry into the Contact Number. 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.

E1-2

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision Affected Description of Changes Summary of Analysis of Change Document EPDP-3, The JIC Liaison position has been removed The change to remove the JIC Liaison position from the Revision 14 from the drill objectives. 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, The following changes were made: The changes are considered editorial.

Revision 14 Section headings were renumbered and retitled to conform to Writers 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 Attachment 1 Other minor editorial changes were made such as removal of unnecessary commas.

E1-3

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision Affected Description of Changes Summary of Analysis of Change Document EPDP-3, The following changes were made: These changes do not impact compliance with the Revision 14 A responsibility was added for the planning standards of 10 CFR 50.47(b) or Site EP Manager to schedule 10 CFR 72.44(f) and do not involve a site-specific required meetings. This change Emergency Planning commitment.

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.

E1-4

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision Affected Description of Changes Summary of Analysis of Change Document EPDP-3, The following changes were made: The changes align definitions with regulatory Revision 14 A reference to Attachment 14 was requirements and existing REP terminology. The new added to the drill and exercise checklist tracks the key skills referenced in 10 CFR 50, instructions in Section 3.2A.2.n. Appendix E,Section IV, Paragraph F.2.j. Therefore, the This note will ensure compliance new attachment ensures continued compliance with the with Source Note R.13 (10 CFR 50, regulatory requirements.

Appendix E,Section IV, Paragraph F.2.j.) The changes to definitions and terminology aligning with The definition of Principal regulatory requirements and other REP terminology Functional Areas was revised to increase the effectiveness of the REP.

align with 10 CFR 50, Appendix E, Section IV, Paragraph F.2.b. The change to the frequency of Augmentation Exercises The terminology of Augmentation from two years to four years is within the REP Drill was revised to Augmentation requirement and ISG guidance of eight years. Because Exercise based on the definitions the change remains within the requirements specified by of drill and exercise in the REP. governing documents, there is continued compliance.

The Augmentation Exercise This change also modified the time it would take to rotate frequency was changed from two all teams through an Augmentation Exercise. No years to four years based on requirements were identified related to ensuring all teams management discretion. The REP participated in an off-hours drill or Augmentation requirement remains eight years. Exercise. The effectiveness of the REP is maintained A new Attachment Eight Year because the ability of the ERO to respond during different Demonstration of Key Skills was periods of the day/night and ensure appropriate response added based on NSIR/DPR-ISG-01 times is tested multiple times during any eight year and NEI Template Checklist for exercise cycle. The TVA ERO is made up of four teams.

Implementation of NRC Challenging In the event of an actual emergency, all four teams would Drills and Exercises Regulation. be notified and the minimum activation staff personnel The yearly drill and exercise (MASP) for all teams are required to report to the instructions were revised to align emergency facility. This same process is used for with the revised definition of Augmentation Exercises such that, while only one team is Principal Functional Areas. on duty, MASP from all four teams are expected to respond. In this way, all four teams 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.

E1-5

Enclosure Summary of the Changes and Analysis for the TVA Radiological Emergency Plan Revision Affected Description of Changes Summary of Analysis of Change Document EPDP-3, The External Flooding Drill was revised from Related to the WBN 95002 Inspection, TVA submitted Revision 14 being a required drill to being a good letters to the NRC in August 2013 discussing the details practice. 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, Attachments documenting historical drill and The changes update the drill/exercise schedule to track Revision 14 exercise performances have been updated past drills and future drills in accordance with regulatory with 2015 data. 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.

E1-6