L-13-388, Notification of Schedule Change and Revision of Regulatory Commitment Regarding Submittal of 10 CFR 50.48(c) License Amendment Request

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Notification of Schedule Change and Revision of Regulatory Commitment Regarding Submittal of 10 CFR 50.48(c) License Amendment Request
ML14091A453
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 04/01/2014
From: Lieb R
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-13-388, SECY-11-006
Download: ML14091A453 (7)
v • d • e


Text

FENOC' 5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor. Ohio 43449 Raymond A Lieb 419-321-7676 President. Nuclear Fax 419-321-7582 April 1, 2014 L-13-388 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Notification of Schedule Change and Revision of Regulatory Commitment Regarding Submittal of 10 CFR 50.48(c) License Amendment Request By memorandum dated June 10, 2011, "Staff Requirements- SECY-11-0061- A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150 AG48)" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML111610616), the Nuclear Regulatory Commission (NRC) approved a staff recommendation to revise the existing enforcement policy regarding the extension of enforcement discretion for certain noncompliances related to fire protection programs. To obtain the extension, licensees were required to submit a letter by June 29, 2011, acknowledging a new commitment date for submittal of their license amendment application to adopt National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, in accordance with Section 50.48(c) of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.48(c)).

By letter dated June 29, 2011 (ADAMS Accession No. ML111800765), FirstEnergy Nuclear Operating Company (FENOC) established a formal regulatory commitment to submit an application for license amendment to implement 10 CFR 50.48(c) at the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) on or before July 1, 2014, and requested extension of the enforcement discretion period for DBNPS under the terms and conditions provided in SECY-11-0061, as approved by the Commission.

On July 12, 2011, the NRC published in the Federal Register (76 FR 40777) the "Interim Enforcement Policy for Certain Fire Protection Issues," formally establishing terms and conditions consistent with those provided in SECY-11-0061, as approved.

Davis-Besse Nuclear Power Station, Unit No. 1 L-13-388 Page 2 By letter dated August 1, 2011 (ADAMS Accession No. ML112010151), the NRC concluded that FENOC's letter of June 29, 2011 was consistent with Commission direction established in SRM SECY-11-0061 and granted the request for the extension of enforcement discretion. The term of enforcement discretion was extended to correspond with the license amendment request (LAR) submittal date. Upon submittal of an acceptable application for license amendment, enforcement discretion for previously identified noncompliances and any newly identified noncompliances could remain in effect until the NRC dispositions the license amendment request.

Basis for Schedule Change and Revision of Regulatory Commitment The NFPA 805 transition analysis for DBNPS has resulted in the identification of design modifications necessary for the implementation of a new fire protection license condition. Modifications are intended to reduce fire risk and reduce the need for operator manual actions currently in place as compensatory measures for existing fire protection design nonconformances. Key modifications, including the installation of a new, completely independent source of emergency feedwater and the addition of two reactor coolant system inventory makeup pumps, are also identified in the DBNPS Overall Integrated Plan in response to NRC Order regarding Mitigation Strategies for Beyond Design Basis External Events (FLEX Order), submitted to NRC by letter dated February 27, 2013 (ADAMS Accession No. ML13064A243). In accordance with FLEX Order obligations and the current expectations for NFPA 805 implementation, these modifications will be implemented while the current fire protection program is still in effect and will provide significant risk improvements for both FLEX and NFPA 805 transition initiatives.

The installation of the new emergency feedwater system is a modification of significant complexity intended to provide a major reduction in core damage frequency as established by probabilistic risk assessment (PRA). Effective coordination of the design activities in response to FLEX initiatives and NFPA 805 transition is essential; however, details of the modifications will not be available until approval of final design. Related operational requirements and any resulting changes to existing operator manual actions will be based on detailed modeling and validation of system performance after initial installation and testing. Because of significant reduction plant risk that is to be provided by these design improvements, the above factors should be considered the NFPA 805 license amendment application.

On November 13, 2013, a public meeting was held between the NRC and FENOC staff to discuss the status of the DBNPS NFPA 805 transition project. Specifically, FENOC informed the NRC that extension of the schedule for LAR submittal is under consideration to allow appropriate coordination of design modifications that are risk beneficial for both fire protection and FLEX initiatives at DBNPS. Consistent with Section 9.1 of the Interim Enforcement Policy, FENOC is providing the following information to justify a revised submittal schedule.

During the transition to NFPA 805, FENOC has continued to maintain fire safety at DBNPS in accordance the operating license. No vioiations of high safety

Davis-Besse Nuclear Power Station, Unit No. 1 L-13-388 Page 3 significance have been identified through NRC inspection activities, and those violations identified have been to satisfy the criteria specified for the exercise of enforcement discretion. Noncompliances are addressed through the FENOC corrective action program, and where necessary, appropriate compensatory measures are in place.

The design configuration at DBNPS includes the predominant use of several robust use of cable trays ceramic fiber routing of power cables in conduit rather than cable trays, extensive use of thermoset cables, and minimal use of large multi-conductor trunk cables. Collectively, such design features provide early mitigation of a fire should one occur, minimize the probability of large high energy fault scenarios, reduce the probability of intra-cable hot shorts, and maximize time to failure of equipment important to safety. DBNPS reactor coolant pump design has been improved by the installation of Flowserve N-9000 pump seals, reducing the probability of a loss of coolant accident as a result of fire, and addressable smoke detection is installed in high risk compartments, with individual alarms in the control room on a graphics display.

Insights from the ongoing NFPA 805 transition analysis have resulted in enhancements to the fire protection program at DBNPS. FENOC utilizes sophisticated fire risk software to implement effective fire prevention measures such as compensatory measures for hot work, reduction of transient combustible limits, and limited impairments of suppression, detection or barriers. Software settings allow sensitivity changes in individual fire areas as needed, based on results of ongoing Fire PRA results. Based on results, risk values are revised to reflect changes in risk significant fire areas. Additional programmatic changes include increased frequency of fire watches in high risk compartments, increased use of fire brigade drills in risk significant areas, enhanced provisions for the control of transient combustibles, and improved control of ignition sources.

FENOC remains fully committed to the improvement of fire protection programs through voluntary implementation of 10 CFR 50.48(c) at DBNPS and has made significant progress in the NFPA 805 transition process. Industry peer reviews, compliance reviews, and the resolution of methodology issues are complete. In parallel with NFPA 805 LAR development for DBNPS, FENOC is continuing to pursue a strategy of plant modifications along with enhancement to administrative fire protection controls.

The parallel approach will continue to reduce fire risk while the improved regulatory basis provided by NFPA 805 is developed, approved, and implemented.

In addition to the emergency feedwater and inventory makeup pump modifications intended to reduce fire risk to levels required by NFPA 805 and FLEX obligations, other actions have recently been completed or are planned to eliminate identified nonconformances with 10 CFR 50 Appendix R and to minimize the impact of a fire should one occur. Actions currently scheduled for implementation include the installation of fuses in ten direct current ammeter circuits to reduce the possibility of secondary fires and of replacement valve operators to simplify safe

Davis-Besse Nuclear Power Station, Unit No. 1 L-13-388 Page 4 shutdown repairs in case of a fire. Other actions completed or planned for implementation prior to the transition to NFPA 805 are identified in Attachment 1. A planned completion date is provided for each of the identified initiatives not yet implemented.

To support NRC oversight of NFPA 805 transition activities at DBNPS, following transition related information continue to be available for NRC staff review.

  • A listing of fire protection-related noncompliances and the related compensatory measures for those noncompliances
  • A description of physical modifications performed to address existing fire protection issues and noncompliances Consistent with the forecast for LAR submittal, regulatory commitment established in the FENOC correspondence dated June 29, 2011 is hereby revised. FENOC will submit the application for license amendment to implement 10 CFR 50.48(c) at DBNPS on or before December 31 , 2015.

Request for Continuation of Enforcement Discretion The "Interim Enforcement Policy for Certain Fire Protection Issues" published on July 12, 2011 states, in part:

If the licensee is unable to its license amendment request (LAR) the timeframe stated above, it lose its enforcement discretion. However, licensees with appropriate justification and staff approval may regain enforcement discretion once an acceptable LAR is submitted.

On February 24, 2012, the NRC staff issued SECY-12-0031, "Enforcement Alternatives for Sites that Indicate Additional Time Required to Submit Their License Amendment Requests to Transition to 10 CFR 50.48(c) National Fire Protection Association Standard 805," which presented three available alternatives regarding enforcement issues in such cases. To determine how to best support the general objectives of the staff as established in SECY-12-0031, FENOC has evaluated the scenarios and potential alternative NRC responses outlined by the staff.

The alternative preferred by the NRC staff would have a licensee preserve its enforcement discretion by arranging for substitution of the LAR submittal from another site by the committed date. Such an arrangement would result in little or no impact on the staff or the resources budgeted for the LAR review schedule but would be subject to staff acceptance based on the comparative safety benefits of the sites involved. Use of this alternative is not feasible for DBNPS, because no licensees are scheduled to submit an LAR in the time frame necessary to support FENOC's needs.

Another alternative addressed in SECY-12-0031 would apply if a licensee does not

Davis-Besse Nuclear Power Station, Unit No. 1 L-13-388 Page 5 submit an acceptable LAR by its commitment date, and the extension of enforcement discretion has not otherwise been arranged. In such cases, the staff would shift to annual performance of fire protection inspections and would take appropriate enforcement actions for identified noncompliances. Based on the results of the most recent triennial fire protection inspections, the limited extent of identified noncompliance issues to which enforcement discretion is currently applied for DBNPS, and the corrective actions in place to resolve those noncompliances, FENOC perceives safety or regulatory benefit from this approach.

The most appropriate alternative involves NRC issuance of a confirmatory order (CO) to extend enforcement discretion, thereby establishing an enforceable date for the submittal of an acceptable LAR. To support this approach, a licensee is required to provide adequate justification including the consideration of the status of the industry peer review, plant modifications, the licensee's compliance reviews, and the resolution of methodology issues. Given these considerations as well as others previously addressed, FENOC believes the justification provided herein is adequate for the extension of enforcement discretion by way of a CO. FENOC also understands that the issuance of a CO would involve the agreement to comply with the terms and conditions arising out of the regulatory commitments established herein, consent to the issuance of the confirmatory order, and the waiver of hearing rights.

Based on the above considerations, FENOC hereby requests the continuation of the current enforcement discretion for certain fire protection issues for DBNPS until an acceptable application for license amendment is submitted, consistent with the regulatory commitment established in this letter.

The regulatory commitment established in this letter is identified in Attachment 2. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager- Fleet Licensing, at 330-315-6810.

Attachments:

1. Additional Modifications and Program Changes
2. Regulatory Commitment cc: Director, NRC Office of Enforcement NRC Regional Administrator- Region Ill NRC Resident Inspector NRC . . . r,....,..,.,......

Attachment 1 L-13-388 Additional Modifications and Program Changes Page 1 of 1 Action Planned Completion Purchase replacement valve operators and develop procedural December 31, 2014 guidance as needed for cold shutdown repairs. This activity will eliminate identified procedure deficiencies for which NRC enforcement discretion is currently being applied.

Implement design modifications to address unfused direct current December 31 , 2014 ammeter circuits. This activity eliminate identified design inadequacies for which NRC enforcement discretion is currently being applied.

Re-analyze currently identified Appendix R nonconformances December 31. 2014 using appropriately conservative assumptions and methodology to reduce the number of operator manual actions without design modification.

Improve Fire Protection Program processes (e.g., hot work, combustible controls, brigade changes, radiation release) in parallel with the development of the license amendment request.

  • Revise work planning and prioritization processes to ensure Complete impaired fire mitigation/detection equipment in high risk I compartments is prioritized for increased attention.
  • Revise response procedures to require assembly of the fire Complete brigade on fire alarms in high risk compartments.
  • Update fire risk management software to require an April 30, 2014 administrative override by the Fire Marshall or Senior Reactor Operator for hot work in high risk compartments.

Provide training to licensed operators to share the insights gained April 30, 2014 from the fire probabilistic risk assessment model used in the development of the license amendment application.

Attachment 2 3-388 Regulatory Commitment Page 1 of 1 The following list identifies regulatory commitments established in this document and its attachments by FirstEnergy Nuclear Operating Company (FENOC) for Davis-Besse Nuclear Power Station, 1. Any other intended or planned actions discussed in the submittal are described for information only, and are not considered regulatory commitments.

Regulatory Commitment

1. FENOC will submit the application for license amendment to implement 10 CFR 50.48(c) at DBNPS on or before December 31, 2015.
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