CNL-14-140, Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk

Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk

ML14231A961
Person / Time
Site:	Browns Ferry
Issue date:	08/14/2014
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-14-140 L44 140814 001
Download: ML14231A961 (3)

Text

L44 140814 001 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-140 August 14, 2014 10 CFR 50.4 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, and 50-296

Subject:

Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk

References:

1. Letter from TVA to NRC, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (Technical Specification Change TS-480)" dated March 27, 2013 (ADAMS Accession No. ML13092A393)

2. Letter from TVA to NRC, "Response to NRC Request to Supplement License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187)," dated May 16, 2013 (ADAMS Accession No. ML13141A291)

By letter dated March 27, 2013 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to transition to National Fire Protection Association Standard (NFPA) 805. As part of the LAR, TVA included interim compensatory measures to reduce the fire risk during the transition to NFPA 805.

These interim compensatory measures were in addition to the existing BFN fire protection requirements existing at that time. The commitments were identified in the attachment to the Reference 1 letter as Commitments 3 through 18.

These commitments were updated by letter dated May 16, 2013 (Reference 2) and a new commitment (i.e., commitment 19) was added that required TVA to inform the NRC 30 days prior to discontinuing any of the interim compensatory measures identified in Commitments 3 through 18.

U.S. Nuclear Regulatory Commission Page 2 August 14, 2014 Commitment 3 in both the References 1 and 2 letters stated:

"TVA will maintain the existing hourly roving fire watches for all existing BFN fire areas (FAs) until the modifications described in AttachmentS, Table S-2, "Plant Modifications Committed ,"

of the enclosure to this letter are installed. The hourly roving fire watches for all existing BFN FAs is currently implemented."

This letter informs the NRC, as required by Commitment 19 of the Reference 2 letter, that Commitment 3 will be modified to only require once per shift (i.e., eight hours) roving fire watches for the following locations for each unit: the quads below Elevation 565, the High Pressure Coolant Injection (HPCI) room , and the torus area. The revised Commitment 3 will be:

"TVA will maintain the existing hourly fire watches for all existing BFN fire areas except the following Reactor Building areas: the quads below the 565' elevation, the HPCI Room , and the torus area in each unit. These excepted locations will require once per eight hour shift roving fire watches. The fire watches will remain in place until the modifications described in AttachmentS , Table S-2, "Plant Modifications Committed ," of the enclosure to this letter are installed."

The change from hourly to once per eight hour shift roving fire watches for these locations for each unit will be implemented no earlier than 30 days from the date of this letter.

TVA has performed the appropriate reviews against the current licensing basis and determined that this commitment change is acceptable. This is based on the low combustible loading and lack of fixed ignition sources, the fire protection features available including detection and suppression ,

the enhanced procedural controls on transient combustibles and hot work activities, and the low fire frequency in these locations.

The reduction from the existing hourly roving fire watches to once per eight hour shift roving fire watches for these locations will result in a significant reduction in the accumulation of dose in accordance with the As Low As Reasonably Achievable (ALARA) goals. The current roving fire watches receive approximately 60 millirem (mR)/day in these locations. With the commitment revision, BFN will reduce the accumulated dose by approximately 50 mR/day. The status of the units (on line or off line) has no major effect on this dose savings.

Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.

cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 August 14, 2014 cc:

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health