IR 05000259/2009501

Download: ML093230808

Text

November 19, 2009

Mr. Preston Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT: BROWNS FERRY NUCLEAR PLANT - NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000259/2009501, 05000260/2009501 AND 05000296/2009501

Dear Mr. Swafford:

On November 6, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Browns Ferry Nuclear Plant, Units 1, 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on November 6, 2009, with Mr. R.

West and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/Heather Gepford RA for/ Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68

Enclosure:

Inspection Report 05000259/2009501, 05000260/2009501 and 05000296/2009501

w/Attachment:

Supplemental Information

cc w/encl.: (See page 2)

November 19, 2009 Mr. Preston

SUMMARY OF FINDINGS

IR 05000259, 05000260, 05000296/2009501; 11/02 - 06/2009; Browns Ferry Nuclear Plant, Units 1, 2, and 3; Exercise and Baseline Inspection.

The report covered an announced inspection by two emergency preparedness inspectors, an emergency preparedness specialist, and a project engineer. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Emergency Preparedness 1EP1 Exercise Evaluation

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC to determine if the exercise would test major elements of the emergency plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The onsite inspection consisted of the following review and assessment:

• The adequacy of the licensee's performance in the biennial exercise conducted on November 04, 2009, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards (RSPSs) in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and protective action recommendations, respectively.

• The overall adequacy of the licensee's emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities" and Emergency Plan commitments. The facilities assessed were the Control Room simulator, Technical Support Center (TSC), Operations Support Center (OSC) and Emergency Operations Facility (EOF).

• Other performance areas besides the RSPS, such as the emergency response organization's (ERO) recognition of abnormal plant conditions, command and control, intra- and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures.

• Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14).

• The post-exercise critique process and the presentation to the licensee's senior management conducted on November 06, 2009, to evaluate the licensee's self-assessment of its ERO performance during the exercise and to ensure compliance with 10 CFR 50 Appendix E.IV.F.2.g.

The inspectors reviewed various documents which are listed in the Attachment to this report.

b. Findings

No findings of significance were identified. 1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, revision 89 of the Browns Ferry Emergency Plan was implemented. The licensee determined that in accordance with 10 CFR 50.54(q), the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors conducted a sampling review of the implementing procedure changes made between June 1, 2008 and October 30, 2009 to evaluate for potential decreases in effectiveness of the Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, AEmergency Action Level and Emergency Plan Changes.@ The applicable planning standard (PS), 10 CFR 50.47(b)(4) and its related 10 CFR 50, Appendix E requirements were used as reference criteria.

The inspectors reviewed various documents which are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

Cornerstone: Emergency Preparedness The inspectors sampled licensee submittals for three Performance Indicators (PI) listed below. For each of the submittals reviewed, the inspectors reviewed the period from April 1, 2008, through June 30, 2009. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, ARegulatory Assessment Indicator Guideline,@ Revision 5, were used to verify the basis in reporting for each data element.

• Emergency Response Organization Drill/Exercise Performance (DEP)

• Emergency Response Organization Readiness (ERO)

• Alert and Notification System Reliability (ANS) The inspectors reviewed portions of the raw PI data developed from monthly performance indicator reports and discussed the methods for compiling and reporting the PIs with cognizant emergency preparedness personnel. The inspectors also independently screened drill and exercise opportunity evaluations, drill participation reports, and drill evaluations. Selected reported values were calculated to verify their accuracy. The inspectors compared graphical representations from the most recent PI report to the raw data to verify that the data was correctly reflected in the report.

Reviewed documents are listed in the Attachment.

b. Findings

No findings of significance were identified.

4OA6 Meetings, including Exit

On November 06, 2009, the lead inspector presented the inspection results to Mr. R. West and other members of your staff. The inspector confirmed that proprietary information was not provided during the inspection.

ATTACHMENT: