ML20085G896

Issuance of Amendment Nos. 312, 335, and 295 Regarding Request to Revise Emergency Plan Staff Augmentation Times

ML20085G896
Person / Time
Site:	Browns Ferry
Issue date:	06/26/2020
From:	Michael Wentzel NRC/NRR/DORL/LPL2-2
To:	Jim Barstow Tennessee Valley Authority
Micheal Wentzel - 301-415-6459
References
EPID L-2019-LLA-0202
Download: ML20085G896 (21)

Text

June 26, 2020 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 ISSUANCE OF AMENDMENT NOS. 312, 335, AND 295 REGARDING REQUEST TO REVISE EMERGENCY PLAN STAFF AUGMENTATION TIMES (EPID L-2019-LLA-0202)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 312, 335, and 295 to Renewed Facility Operating Licenses Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively. These amendments are in response to your application dated September 18, 2019.

These amendments revise the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Emergency Plan to extend staff augmentation times for certain Emergency Response Organization functions.

A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Michael J. Wentzel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 312 to DPR-33

2. Amendment No. 335 to DPR-52

3. Amendment No. 295 to DPR-68

4. Safety Evaluation cc: Listserv

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 312 Renewed License No. DPR-33

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated September 18, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 312, Renewed Facility Operating License No. DPR-33 is hereby amended to authorize revision to the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Emergency Plan as set forth in Tennessee Valley Authoritys application dated September 18, 2019, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.06.26 Gavrilas 13:47:42 -04'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: June 26, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 335 Renewed License No. DPR-52

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated September 18, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, by Amendment No. 335, Renewed Facility Operating License No. DPR-52 is hereby amended to authorize revision to the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Emergency Plan as set forth in Tennessee Valley Authoritys application dated September 18, 2019, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.06.26 Gavrilas 13:48:07 -04'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: June 26, 2020

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 295 Renewed License No. DPR-68

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated September 18, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, by Amendment No. 295, Renewed Facility Operating License No. DPR-68 is hereby amended to authorize revision to the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Emergency Plan as set forth in Tennessee Valley Authoritys application dated September 18, 2019, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Mirela Mirela Gavrilas Date: 2020.06.26 13:48:34 Gavrilas -04'00' Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: June 26, 2020

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 312, 335, AND 295 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-33, DPR-52, AND DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION

By letter dated September 18, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19262F378), the Tennessee Valley Authority (TVA, the licensee) submitted a request for changes to the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (Browns Ferry) Emergency Plan pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the Browns Ferry Emergency Plan to change the emergency response organization (ERO) staffing composition and to increase the staff augmentation times from 30 minutes to 60 minutes and from 60 minutes to 90 minutes for certain ERO positions from the time of declaration of an Alert or higher emergency classification level (ECL).

The proposed revisions include:

Eliminating 30-minute augmented ERO positions; Extending the requirement for dispatch of sampling (offsite radiological field monitoring) teams and augmentation of ERO positions to 60 and 90 minutes, as applicable; Reducing the number of radiation protection (RP) immediate response positions; Transitioning on-shift dose assessment from RP to Chemistry; Removing maintenance personnel from on-shift; Extending the 60-minute augmented response by the Radwaste Operator to 90 minutes; Removing, as needed, support positions from certain emergency plan figures; and Applying the term activated to facility response.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance on which the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff based its review are provided below.

Enclosure 4

2.1 Regulatory Requirements The planning standards in 10 CFR 50.47(b) identify the requirements that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that the licensee can, and will, take adequate protective measures in the event of a radiological emergency. Specifically, on-shift and augmented ERO staffing is addressed under 10 CFR 50.47(b)(2), which states:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

In addition, Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Part A, Organization, states, in part:

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization.

2.2 Guidance Regulatory Guide (RG) 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors (ADAMS Accession No. ML090440294), provides guidance on methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations - in this case, 10 CFR 50.47(b)(2) and Section IV.A of Appendix E to 10 CFR Part 50. RG 1.101 endorses Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ADAMS Accession No. ML040420012), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for NRC licensees, and State and local governments to develop acceptable radiological emergency plans and to improve emergency preparedness.

In NUREG-0654, Revision 1,Section II, Planning Standards and Evaluation Criteria, Evaluation Criteria II.B.1 and II.B.5 address planning standard 10 CFR 50.47(b)(2). Evaluation Criterion II.B.1 states that [e]ach licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal shift complement. Evaluation Criterion II.B.5 states, in part, that:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ADAMS Accession No. ML16124A002), provides examples of the scope and detail of information that should be provided in license amendment requests related to ERO staffing and augmentation to facilitate NRC review.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of the proposed changes to the Browns Ferry Radiological Emergency Plan, as described in the application dated September 18, 2019. The NRC staffs technical evaluation is detailed below.

3.1 Enhancements The NRC staff performed an evaluation of the proposed changes to the Browns Ferry ERO based upon the applicable major functional areas as described in Table B-1 of NUREG-0654.

Many of the proposed changes are supported by enhancements to equipment (technology) and by procedural, training, and process improvements, as described below. Collectively, these enhancements compensate for the proposed increases in augmentation timing and the proposed reduction in available on-shift maintenance expertise.

Plant Computer: The Browns Ferry Plant Computer System was upgraded to an Integrated Computer System (ICS). The benefits of the ICS upgrade include:

Programming capability for automated response such as indication of critical parameter alarms; Improved plant monitoring capability for Site Emergency Director functions; Fewer keystrokes required to switch between graphical displays; and Real time plant data available through graphical displays.

Power for ICS basic functions is provided by the ICS-Uninterruptible Power Supply, which is powered from the station battery system. Real time read-only plant data is available on any desktop computer through the corporate network.

Dose Assessment: Browns Ferry dose assessment was originally performed via a manual method that used charts and radiation monitor data from the control room. The current dose assessment capability utilizes a spreadsheet which requires user input of data obtained from the ICS. The spreadsheet automatically performs the required calculations. This method of dose assessment requires minimal user input and is simpler and less time consuming.

Automated Call-Out Systems: Since initial approval of the Browns Ferry Radiological Emergency Plan, TVA has implemented enhancements to the ERO activation process, which includes updated technology capable of rapidly notifying of the ERO. The original activation method used a Radio Paging system to notify ERO members. Subsequently, TVA implemented the Tennessee Valley Authority Enterprise Emergency Notification System, which is a Web--based notification service that offers immediate and simultaneous one-to-many communications using wired and wireless communication devices (telephones, Short Message Service devices, e-mail, pagers, and faxes).

Procedure Improvements: TVA provides that Browns Ferry emergency action levels now incorporate guidance that has simplified the emergency classification process, including the use of an overview matrix of emergency action level initiating conditions and threshold values, which streamlines the process of evaluating emergency action levels against plant conditions.

Additionally, emergency operating procedures have been vastly improved through internal operating experience and industry initiatives. Emergency operating instructions now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews.

Training: TVA provides that training is used to strategically drive and sustain improved performance at Browns Ferry. Training is administered through the application of a Systematic Approach to Training to ensure that all training is conducted to the industry-accepted standards required to achieve and maintain accreditation by the National Academy of Nuclear Training.

The proficiency of the Control Room team is evaluated in the areas of critical task performance, prioritization of activities, communications, accident mitigation, event classification, teamwork, and communications.

On-Shift Staffing Levels: TVA provides that the proposed Browns Ferry on-shift staffing will be a 26-personnel complement. TVA proposes to remove two maintenance personnel from shift and to specifically identify the five fire brigade members to the on-shift staff. TVA currently includes on-shift Fire Brigade members in accordance with the Fire Protection Report. The five fire brigade members added are the same individuals that are currently on-shift.

3.2 Major Functional Areas In the application dated September 18, 2019, TVA provided a justification for the proposed Browns Ferry Radiological Emergency Plan changes that included a detailed review of each major functional area described in NUREG-0654, Table B-1.

The current Browns Ferry Radiological Emergency Plan describes the ERO as consisting of personnel staffing in the following emergency response facilities:

Control Room, Operations Support Center (OSC),

Technical Support Center (TSC), and Emergency Operations Facility, referred to in the Browns Ferry Radiological Emergency Plan as the Central Emergency Control Center (CECC).

TVA proposes to continue activating the TSC, OSC, and CECC within 60 minutes of declaring an Alert or higher ECL. Although activation of the CECC would not be required until a Site Area Emergency or higher ECL is in effect per the guidance in NUREG-0654, the proposed ERO staffing changes to the Browns Ferry Radiological Emergency Plan require the TSC, OSC, and CECC emergency response facilities to activate at an Alert or higher ECL.

The NRC staffs review of the proposed changes to the Browns Ferry Radiological Emergency Plan is described below by major functional area.

3.2.1 Major Functional Area: Plant Operations and Assessment of Operational Aspects The current on-shift staffing for plant operations and assessment of operational aspects consists of:

Position Number of On-Shift Operations Personnel Shift Manager (Senior Reactor Operator-licensed) 1 Unit Supervisors (Senior Reactor Operator-licensed) 3 Unit Operators (Reactor Operator) 6 Auxiliary Unit Operators 9 TVA is not proposing a change to this major functional area for the Browns Ferry Radiological Emergency Plan. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.2 Major Functional Area: Emergency Direction and Control The transfer of command and control responsibilities from the Control Room to the TSC and CECC, as illustrated in the table below (taken from Appendix A of the proposed Browns Ferry Radiological Emergency Plan), remains consistent with that outlined in the current Browns Ferry Radiological Emergency Plan. Both the TSC and CECC will continue to be activated within 60 minutes of declaring an Alert or higher ECL.

CONTROL ROOM TSC CECC Shift Manager/

Site Emergency Director CECC Director Emergency Director Classification ------------------> Classification Notifications (State/local) ---------------------------------------------------------------> Notifications (State/local)

Notifications (Federal) -------> Notifications (Federal)

PARs [protective action recommendations] ---------------------------------------> PARs Emergency Exposure -------> Emergency Exposure-------------> Emergency Exposure Controls Controls Controls TVA is not requesting a change to the Emergency Direction and Control major functional area and continues to meet the guidance provided by NUREG-0654. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.3 Major Functional Area: Notification/Communication The current and proposed Browns Ferry Radiological Emergency Plans assign one on-shift individual as an on-shift Communicator to perform the notification/communication function.

Browns Ferry currently has three additional communicators available within 60 minutes of declaring an Alert or higher ECL. Browns Ferry proposes to have five additional communicators available within 60 minutes of declaring an Alert or higher ECL.

The proposed Browns Ferry Radiological Emergency Plan revises the State, local, and Federal notification process by transitioning responsibility for the facility position performing State and local notifications to the State Communicator in the CECC and Federal notifications to the Operations Communicator in the TSC. The transition will continue to occur approximately 60 minutes after the declaration of an Alert or higher ECL.

Figure A-2, Minimum Emergency Response Staffing, of the proposed Browns Ferry Radiological Emergency Plan does not change the ability or timing to perform required Federal, State, and local notifications from that outlined in the current Browns Ferry Figure A-2.

Therefore, the proposed Browns Ferry Figure A-2 continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.4 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment Figure A-1, Site Emergency Organization, in the current Browns Ferry Radiological Emergency Plan has two RP personnel on-shift with an RP supervisor and six RP personnel responding within 30 minutes with six RP additional personnel responding within 60 minutes of the declaration of an Alert or higher ECL. While Figure A-1 in the current and proposed Browns Ferry Radiological Emergency Plans provides the number of responding RP Technicians, Figure A-1 does not specifically designate which RP tasks will be performed by the augmenting RP Technicians. Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan provides three RP personnel on-shift, four RP Technicians, and a driver responding within 60 minutes and four RP Technicians and a driver responding within 90 minutes of an Alert or greater ECL.

Additionally, the proposed change will result in the reduction of three RP Technicians. TVA is adding one on-shift RP Technician and providing a Chemistry Technician to perform offsite dose assessment, which is a function that was previously performed by a RP Technician.

The proposed Figure A-2 specifically identifies the personnel that will be performing the following major tasks, as applicable:

Emergency Response and Recovery Director: This major task, as it relates overall command and control and responsibility for notifications to offsite agencies, was discussed previously in the Emergency Direction and Control major functional area of this safety evaluation. TVA is not requesting a change to this overall utility emergency management and offsite agency interface major task. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

Offsite Dose Assessment: The guidance in NUREG-0654, Revision 1, Table B-1, identifies one person to perform the offsite dose assessment function as a 30-minute augmented position. TVA proposes to assign offsite dose assessment from RP personnel on-shift to the on-shift Chemistry Technician. TVA maintains that the CECC Dose Assessor will be available to perform the offsite dose assessment function within 60 minutes of declaring an Alert or higher ECL.

The proposed transfer of responsibility for offsite dose assessment to the on-shift Chemistry Technician will allow RP personnel on-shift to perform the RP radiological

assessment and protective action functions. TVA provides that collection of chemistry samples is not required within the first 90 minutes after an event. As a result, the on-shift Chemistry Technician is available to perform the offsite dose assessment function without conflicts until relieved by the CECC Dose Assessor within 60 minutes of the declaration of an Alert or higher ECL.

Based on enhancements in offsite dose assessment capability and the use of a dedicated on-shift position to perform offsite dose assessment, the NRC staff concludes that there is no loss-of-function or impact on the timing for performing offsite dose assessment on-shift. Therefore, with the proposed changes, the proposed Browns Ferry Radiological Emergency Plan will continue to meet planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

Onsite Surveys and In-Plant Surveys: The guidance in NUREG-0654 (Revision 1),

Table B-1, identifies an RP Technician on-shift, and one RP Technician augmenting within 30 minutes, with an additional RP Technician augmenting within 60 minutes of declaring an Alert or higher ECL to perform in-plant surveys. Additionally, NUREG--0654, Revision 1, Table B-1, identifies one RP Technician augmenting within 30 minutes with an additional RP Technician augmenting within 60 minutes of declaring an Alert or higher ECL to perform onsite (out-of-plant) surveys.

The current Browns Ferry Radiological Emergency Plan has one RP Technician on-shift with one RP Technician responding within 30 minutes and one additional RP Technician responding within 60 minutes of declaring an Alert or higher ECL to perform onsite surveys. Additionally, the current Browns Ferry Radiological Emergency Plan provides for one RP Technician to respond within 30 minutes to perform in-plant surveys.

Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan provides for two on-shift RP Technicians with one RP Technician responding within 60 minutes and one RP Technician will respond within 90 minutes to perform onsite (out-of-plant) and in-plant surveys. TVA is proposing to eliminate all 30-minute responders and combine the onsite (out-of-plant) and in-plant surveys for Browns Ferry.

The enhancements supporting on-shift dose assessment and improved access to real-time plant data reduce the need for the performance of onsite (out-of-plant), in-plant surveys and support the proposed changes in RP augmentation. As such, the NRC staff concludes that the proposed changes will not result in a loss of function or impact the timing for onsite (out-of-plant) and in-plant surveys. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

Offsite Surveys: The guidance in NUREG-0654, Revision 1, Table B-1, identifies two personnel to perform the offsite survey function as 30-minute augmented positions, with two additional personnel as 60-minute augmented positions.

Figure A-1 in the current Browns Ferry Radiological Emergency Plan identifies two RP/support personnel responding within 30 minutes and two RP/support personnel responding within 60 minutes of the declaration of an Alert or higher ECL to perform offsite surveys.

Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan provides that one RP Technician and one support person (serving as the vehicle driver) would respond within 60 minutes and that one RP Technician and one support person (vehicle driver) would respond within 90 minutes of declaring an Alert or higher ECL to perform offsite surveys.

Initial field team response involves primarily environmental radiation and contamination assessments, plume tracking, and using dose assessment instrumentation. Actions include driving to and from field positions, reading dose rate instrumentation, and communicating results to the TSC and/or CECC. The first survey team can effectively track a potential plume and/or cover the necessary area to identify whether a plume exists during the early stages of an event. The second team, dispatched at 90 minutes, will support continued plume tracking capability as well as sampling activities.

TVA states, [] that the use of in-plant and effluent monitors effectively supports event classification as well as onsite and offsite protective actions []. This effectively supports event classification, as well as onsite and offsite protective actions if warranted, such that performance of this major task at 60 minutes following the declaration of an Alert or higher ECL does not adversely impact site response.

Based on the assessment above, the NRC staff concludes that there is no loss of function or impact on the timing for performing offsite surveys. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.5 Major Functional Area: Plant System Engineering, Repair, and Corrective Actions This major functional area includes the following tasks:

Technical Support: The guidance in NUREG-0654, Revision 1, Table B-1, identifies one on-shift Shift Technical Advisor and one Core/Thermal Hydraulic Engineer to be available in 30 minutes, and one Electrical and one Mechanical Engineer to be available in 60 minutes following the declaration of an Alert or higher ECL.

The current Browns Ferry Radiological Emergency Plan identifies an on-shift Shift Technical Advisor with a Core/Thermal Hydraulic Engineer, a Mechanical Engineer, and an Electrical Engineer augmenting within 60 minutes of the declaration of an Alert or higher ECL.

TVA proposes to transfer the Core/Thermal Hydraulic Engineer task to a Core Damage Assessor at the CECC, who will respond in 60 minutes to the CECC after the declaration of an Alert or higher ECL. TVAs Radiological Emergency Plan states that the Core Damage Assessor is specifically identified and is qualified to perform the core/thermal-hydraulic function for all TVA sites. Additionally, TVA proposes to extend the response time for the Core/Thermal Hydraulic Engineer and Rad Waste Operator to 90 minutes. The Mechanical Engineer and the Electrical Engineer will continue to respond within 60 minutes of the declaration of an Alert or higher ECL.

The NRC staff finds that transferring the 60-minute augmentation Core/Thermal Hydraulic Engineer function from the TSC to the CECC Core Damage Assessor and extending the response time for the Core/Thermal Hydraulic Engineer and Rad Waste Operator to 90 minutes to be acceptable, as there is no loss of function or impact on the timing for providing the Core/Thermal Hydraulic Engineer task. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

Repair and Corrective Actions: The guidance in NUREG-0654, Revision 1, Table B-1, specifies the major task of Repair and Corrective Actions to be fulfilled on-shift by a total of two personnel and [m]ay be provided by shift personnel assigned other functions.

One person would perform the function of a mechanic and one person would perform the function of an electrician. One electrician and one instrument and controls Technician would respond within 30 minutes to augment the ERO. One mechanic, one Rad Waste Operator, and one additional electrician would respond within 60 minutes to augment the ERO.

The current Browns Ferry Radiological Emergency Plan has one mechanic and one electrician on-shift with one additional electrician and an instrument maintenance technician responding within 30 minutes and one additional mechanic and one additional electrician responding within 60 minutes of the declaration of an Alert or higher ECL.

The proposed Browns Ferry Radiological Emergency Plan would eliminate the on-shift repair team staffing, with one mechanic and one electrician augmenting within 60 minutes with a Rad Waste Operator and an instrument and controls Technician responding within 90 minutes of the declaration of an Alert or higher ECL.

Based on the availability of on-shift operators with the knowledge, skills, and abilities to perform all tasks that may be required to implement the Browns Ferry abnormal operating procedures and emergency operating procedures, the redundant and diverse emergency core cooling system design, the proposed augmenting maintenance personnel, and the processing of radwaste as part of normal operator duties, the NRC staff finds the requested changes to be acceptable. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.6 Major Functional Area: Protective Actions (In-Plant)

The guidance in NUREG-0654, Revision 1, Table B-1, specifies the major task of Protective Actions (In-Plant) to be fulfilled on-shift by a total of two personnel and [m]ay be provided by shift personnel assigned other functions. Additionally, the guidance in NUREG-0654, Table B-1, identifies two personnel to perform this function as 30-minute augmented positions with two additional personnel as 60-minute augmented positions.

Figure A-1 of the current Browns Ferry Radiological Emergency Plan has two on-shift RP Technicians fulfilling the radiation protection role and provides for augmentation by six RP Technicians and one RP supervisor within 30 minutes and six additional RP Technicians within 60 minutes of the declaration of an Alert or higher ECL.

The proposed Browns Ferry Radiological Emergency Plan maintains the commitment for two on-shift RP Technicians and adds a third RP Technician. One of the RP Technicians will be responsible to perform RP major tasks with one RP Technician performing the onsite surveys (out-of-plant) and in-plant surveys major tasks.

TVA also proposes to extend the response time for support of in-plant functions for three 30-minute RP Technicians to 60 minutes from the declaration of an Alert of higher ECL.

Additionally, TVA proposes to eliminate one 60-minute RP Technician and extend the response time of three RP Technicians from 60 minutes to 90 minutes from the declaration of an Alert or higher ECL. Two of the 60- and 90-minute RP Technicians will perform the protective actions (in-plant) function, and one of the 60- and 90-minute RP Technicians will perform onsite surveys (out-of-plant) and in-plant surveys, as needed.

TVA provides that issuance of electronic dosimeters, which are obtained prior to entry into radiologically controlled areas, would not require oversight by a RP Technician. In addition to providing dose information, electronic dosimeter systems are used by personnel as a key to unlock turnstiles to allow access to a radiologically controlled area. Electronic area radiation monitoring provides updated real time information for limited areas that allows one RP Technician to remotely monitor numerous locations. An extension of the response time for the RP personnel responsible for personnel monitoring/habitability coincides with the 60-minute activation time for emergency response facilities as described in the proposed Browns Ferry Radiological Emergency Plan.

The NRC staff finds the improved use of technology regarding access control and electronic area radiation monitoring, and the staffing of three on-shift RP Technicians, three RP Technicians augmenting in 60 minutes, and three RP Technicians augmenting in 90 minutes will not result in a loss of function or impact to the timing of the performance of protective actions. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.7 Major Functional Area: Firefighting The guidance in NUREG-0654, Revision 1, Table B-1, specifies the Firefighting major functional area to be fulfilled on-shift per the Fire Brigade per Technical Specifications. Additionally, the guidance in NUREG-0654, Table B-1, identifies augmentation by Local Support at 30 minutes.

Figure A-1 in the current Browns Ferry Radiological Emergency Plan provides a note stating that on-shift fire brigade staffing is per the Fire Protection Report.

Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan specifies five fire brigade members and one Incident Commander as on-shift personnel. TVA proposes to state the number of required personnel, rather than referencing the Fire Protection Report. TVA is not proposing to change augmentation by Local Support.

The number of personnel required by the Fire Protection Report does not change the Firefighting major functional area from the current Browns Ferry Radiological Emergency Plan.

Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.8 Major Functional Area: Rescue Operations and First-Aid The guidance in NUREG-0654, Revision 1, Table B-1, specifies the Rescue Operations and First-Aid major functional area to be fulfilled by two personnel on-shift that may be assigned other functions. Additionally, the guidance in NUREG-0654, Table B-1, identifies augmentation by Local Support.

Figure A-1 in the current Browns Ferry Radiological Emergency Plan provides a note stating that on-shift fire brigade staffing is per the Fire Protection Report and provides that this group also provides rescue operations and first aid response.

Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan specifies two personnel to perform the Rescue Operations and First-Aid major tasks, who may be provided by shift personnel assigned other functions. TVA is not proposing a change to the use of on-shift first aid responders to provide the rescue operations and first-aid functions. TVA is also not proposing to change augmentation by Local Support.

As TVA is not proposing a change to the Rescue Operations and First-Aid major functional area, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.2.9 Major Functional Area: Site Access Control and Personnel Accountability The guidance in NUREG-0654, Revision 1, Table B-1, specifies the Site Access Control and Personnel Accountability major functional area on-shift staffing be fulfilled by Security personnel in accordance with the Security Plan.

Figure A-1 in the current Browns Ferry Radiological Emergency Plan provides a note stating that on-shift Nuclear Security Personnel are staffed per the Security Plan.

Figure A-2 in the proposed Browns Ferry Radiological Emergency Plan continues to specify that Security Personnel per the Security Plan will perform the tasks associated with Site Access Control and Personnel Accountability. As such, TVA is not proposing a change to the use of on-shift Security personnel per the Security Plan. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.3 Administrative Changes TVA proposes to remove the following support positions, which are not required to perform any tasks associated with the major functional areas and/or perform administrative tasks and that are not required to implement the Browns Ferry Radiological Emergency Plan:

TSC positions of Site Vice President and Emergency Preparedness Manager OSC position of Fire Protection Briefer TSC and OSC positions of clerical staff and document control In addition, TVA proposes to remove the TSC Communicator position from the Browns Ferry Radiological Emergency Plan. This position provides information from the Control Room to the Technical Assessment Team and completes plant data sheets in the event of a loss of

electronic plant parameter displays. As provided in the Browns Ferry Radiological Emergency Plan, this position is not responsible for communication associated with any major functional area.

The NRC staff performed a review of all tasks associated with the proposed changes and determined that the removal of these positions from the Browns Ferry Radiological Emergency Plan will not impact the timing or performance of any tasks identified in the Section 3.2, Major Functional Areas, above. Therefore, the proposed Browns Ferry Radiological Emergency Plan continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50.

3.4 Summary Based on a technical and regulatory review of the proposed changes to the Browns Ferry Radiological Emergency Plan, the NRC staff finds that the proposed Browns Ferry Radiological Emergency Plan, as changed, continues to meet the planning standard in 10 CFR 50.47(b)(2) and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Therefore, the NRC staff concludes that the changes to certain ERO staffing and augmentation times for the proposed Browns Ferry Radiological Emergency Plan, as described in the application dated September 18, 2019, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Alabama State official was notified of the proposed issuance of the amendments on April 15, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the sites radiological emergency plan. The amendments relate, in part, to changes in recordkeeping, reporting, or administrative procedures or requirements. The amendments also relate, in part, to changing requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on November 19, 2019, (84 FR 63901). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The NRC has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Hoffman, NSIR Date: June 26, 2020

ML20085G896 *by e-mail concurrence OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NSIR/DPR/RLB/BC NAME MWentzel BAbeywickrama JAnderson DATE 04/03/2020 04/01/2020 03/18/2020 OFFICE OGC - NLO(w/comments)* NRR/DORL/LPLII-2/BC* NRR/DORL/D*

CErlanger (MShams NAME MWoods UShoop for)

DATE 05/06/2020 06/18/2020 06/23/2020 OFFICE NRR/D* NRR/DORL/LPLII-2/PM*

NAME HNieh (MGavrilas for) MWentzel DATE 06/24/2020 06/25/2020