ML100630102

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Meeting Summary - Public Meeting Category 1 - Preliminary Greater than Green Findings- Browns Ferry Nuclear Plant, Docket 50-259, 50-260, & 50-296
ML100630102
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 03/03/2010
From: Nease R
NRC/RGN-II/DRS/EB2
To: Swafford P
Tennessee Valley Authority
References
EA-09-307
Download: ML100630102 (33)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 March 3, 2010 EA-09-307 Mr. Preston D. Swafford Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

MEETING

SUMMARY

- PUBLIC MEETING CATEGORY 1 - PRELIMINARY GREATER THAN GREEN FINDINGS - BROWNS FERRY NUCLEAR PLANT, DOCKET NOS. 50-259, 50-260, AND 50-296

Dear Mr. Swafford:

This refers to the meeting conducted at your request at the NRC Region II Office on February 22, 2010, at 1:00 pm. The meeting's purpose was for the Tennessee Valley Authority (TVA) to discuss three preliminary Greater than Green findings involving the Browns Ferry fire protection program. Enclosed are a list of attendees and TVAs presentation slides.

The discussions focused on the following topics: Overview of the findings, circumstances leading to the apparent violations, risk significance, and corrective actions going forward.

During the conference, TVA agreed that violations of NRC requirements occurred and stated that corrective actions are being taken to prevent recurrence. The TVA also stated the following: 1) their evaluation of the overall risk for the apparent violation involving Appendix R,Section III.G.2 is low to moderate (White); 2) the apparent violation involving Appendix R,Section III.G.1 should be combined with the Appendix R,Section III.G.2 apparent violation; 3) the cross-cutting aspect in the problem identification and resolution area for these first two apparent violations is a legacy issue and is no longer applicable; and 4) their evaluation of the overall risk for the third apparent violation involving a change to the safe shutdown instruction entry conditions is very low (Green). The TVA committed to submit additional technical information to NRC for review. The results of NRCs review and decision will be discussed in Inspection Report 05000259, 260, 296/2010007.

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

TVA 2 Should you have any questions concerning this meeting, please contact me at (404) 562-4530.

Sincerely,

/RA Signed By/

Rebecca L. Nease, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68

Enclosures:

1. List of Attendees
2. TVAs Presentation Slides cc w/encls.: (See page 3)

TVA 2 cc w/encls:

K. J. Polson Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, AL 35609 J. J. Randich General Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, AL 35609 F. R. Godwin Manager, Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 E. J. Vigluicci Assistant General Counsel Tennessee Valley Authority 6A West Tower 400 West Summit Hill Drive Knoxville, TN 37902 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 30317 Montgomery, AL 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission 10833 Shaw Road Athens, AL 35611-6970

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Enclosure 1

OPEN REGULATORY CONFERENCE BROWNS FERRY NUCLEAR PLANT FEBRUARY 22,2010 NRC REGION II OFFICE, ATLANTA, GA Video Conferencerreleconference Attendees NRC Stewart Bailey, Senior Project Manager, NRRlDORLlLPL2-2 Eva Brown, Senior Project Manager, NRRlDORLlLPL2-2 Daniel Frumkin, Team Leader, NRRlDRAlAFPB Ray Gallucci, Senior Fire Probabilistic Safety Analysis Engineer, NRRlDRAIAPLA John Hanna, Senior Reactor Analyst, RII/DRS Kendra Hill, Reliability and Risk Engineer, RESIDRAlFRB John Hyslop, Senior Reliability and Risk Engineer, RES/DRAlFRB Alex Klein, Branch Chief, NRRlDRAlAFPB Christiana Lui, Division Director, RES/DRA Neil O'Keefe, Branch Chief, RIV Phil Qualls, Fire Protection Engineer, NRRlDRAlAFPB Thierry Ross, Senior Resident Inspector, Browns Ferry Nuclear Plant Mark Salley, Branch Chief, Fire Research Branch, RES/DRAlFRB David Stroup, Fire Protection Engineer, RES/DRAlFRB Public Eric Fleischauer, Staff Writer, The Decatur Daily Newspaper Stewart Horn Kevin McGratton, Fire Modeling Group Leader, National Institute of Standards and Technology Glenn Stewart, Exelon Generation Company, LLC William Sullivan Enclosure 1

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

Regulatory Conference 2009 Triennial Fire Protection Inspection Apparent Violations Atlanta, Georgia February 22, 2010 Enclosure 2 1

[m Agenda

  • Introduction Preston Swafford
  • Circumstances Leading to Apparent Violations Keith Polson
  • Risk Significance of Apparent Violations Rob Whalen
  • Going Forward Actions - NFPA 805 Rob Whalen
  • Closing Remarks Preston Swafford Enclosure 2 2

II!lil Introd uction

  • A Thorough Root Cause Analysis is being Finalized
  • Corrective Actions Focus on Governance and Strengthening the Licensing Function - Cross Cutting Aspects of the Corrective Action Program Are Legacy Issues and Have Been Previously Addressed
  • Agree with NRC that Apparent Violations Do Not Present an Immediate Safety Concern:

- Apparent Violation 1 Overall Risk is Low to Moderate

- Apparent Violation 2 is due to the Same Cause as Apparent Violation 1 and is not Separate from Apparent Violation 1

- Apparent Violation 3 Risk is Very Low

  • Reaffirm Commitment to Transition the BFN Fire Protection Program to National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" Enclosure 2 3

[ml Circumstances Background - Apparent Violations 1 and 2

  • In April 2007, NRC Documented the Non-compliance regarding the Use of OMAs in Lieu of Train/Channel Separation for Section 111.G.2
  • TVA's Focus was on Obtaining Exemption to Resolve Non-compliance Instead of Making Plant Changes Enclosure 2 4

rni] Circumstances Root Causes for Apparent Violations 1 and 2 Weak/Lack of Licensing Governance and Oversight Led to:

  • Failure to Revisit BFN Appendix R Compliance when NRC Requirements Evolved and were Clarified
  • Entrenched Position Regarding BFN Compliance to Appendix R
  • Lack of Follow Through on Needed Actions due to Failure to Capture Regulatory Commitments Root Cause for Apparent Violation 3
  • Analysis Performed for Procedure Change was Inadequate Enclosure 2 5

rnJ Circumstances Corrective Actions

  • Continued Emphasis by Senior Nuclear Power Group (NPG) Leadership on 'Governance and Oversight' Accountabilities of Corporate Office Functions/Areas

- One of the Five NPG Focus Areas

- Part of Chief Nuclear Officer's Documented Strategy; Procedure Issued

- Created Corporate Vice President Position for Licensing

  • Strengthen NPG Procedures

- Increase Rigor of Analysis Performed for Changes that Affect the Fire Protection Program

- Clear Assignment of Accountabilities for Licensing Actions Enclosure 2 6

nm Circumstances

  • Corrective Action Program Improvements

- Actions Already Completed and Improvements Acknowledged during NRC Inspections

  • A Cross Cutting Attribute in Problem Identification and Resolution (PI&R) was Identified in the Apparent Violations
  • This Weakness in the Corrective Action Program is a Legacy Issue that TVA Has Already Adequately Addressed
  • Substantive Cross Cutting Issue Identified in the NRC 2007 Annual Assessment Letter (March 3, 2008). NRC Concurred with Improvements in the Corrective Action Program

- As Documented in NRC Inspection Report 2009002 - April 30, 2009

- Closed Substantive Cross Cutting Issue in PI&R Area - September 1, 2009

  • Because the Cross Cutting Aspect is a Legacy Issue, it is No Longer Applicable to these Apparent Violations Enclosure 2 7

~ Risk Significance Apparent Violation 2 - Combine with Apparent Violation 1

  • BFN Miscategorized the Requirements of Appendix R,Section III.G.2 as III.G.1 Resulting from the Entrenched Position taken regarding BFN Compliance to Appendix R
  • Details in Apparent Violation 2 Really Represent Appendix R Section III. G.2 Violations

- Based on Implementation of Appendix R Section III.G.2 Requirements at BFN, if these Areas had been Properly Classified , TVA would have taken the Same Actions as Described in Apparent Violation 1

  • Apparent Violations 1 and 2 should be Combined into a Single Violation Enclosure 2 8

1m Risk Significance Apparent Violations 1 and 2

  • TVA has Performed a Parallel Calculation of the Risk for Apparent Violations 1 and 2 using the Methodologies in NUREG 6850 and NFPA 805 Frequently Asked Questions (FAQs) and Determined it to be Low to Moderate

- TVA and NRC Analyses include Site Specific Ignition Source Frequencies and the Newest Non-suppression Probabilities Developed through the NFPA 805 FAQ Process

- TVA and NRC Analyses are Largely Consistent with the Most Notable Exception being the Factor involving Probability of Entry into the Appendix R Safe Shutdown Instructions (SSls)

- The TVA Analysis Refines the NRC Calculation Regarding Entry into the SSls using the Results of Detailed Cable Routing Review and Licensed Operator Input Compiled since the Inspection Enclosure 2 9

U!lil Risk Significance

  • TVA Analysis of NRC Defined Realistic Fire Scenarios Identified that Many of them would not Defeat Normal Safe Shutdown Capability

- TVA Completed Detailed Review and Analysis, including Cable Routing Review in order to Determine the Equipment Impacted by each Realistic Fire Scenario

- BFN Licensed Operators Evaluated Each Scenario and Determined if Emergency Operating Procedures would Provide Sufficient Guidance for Safe Shutdown or if SSI Entry is Required

- From this Analysis, TVA then Determined the Probability that Operators would Enter the SSls during the Realistic Fire Scenarios using the Most Recent NRC Guidance (draft NUREG-1921)

- The Scenarios were Binned as Shown on the Following Slide Based upon Equipment Impact Enclosure 2 10

Il!al Risk Significance Bins SSI Entry Draft NUREG-1921 Equipment Impact Criteria Required Table 5-5 EOC (AK) 1 Yes 1.0 Safe Shutdown Systems Affected - Cross-Divisional Affects

- Multiple Residual Heat Removal Heat Exchangers or Low Pressure (LP) Injection Sources Affected Multiple Spurious Actuations 2 No 0.25 Safe Shutdown Systems Affected - Single Division Unaffected

- Both 1 High Pressure (HP) and 1 LP Injection Source on Any Single Unit Affected Numerous Spurious Actuations of Equipment could Distract Operator and Cause Errant SSI Entry 3 No 0.25 Safe Shutdown Systems Affected - Single Division Unaffected

- Either 1 HP or 1 LP Injection Source on Any Unit Affected Very Limited Potential for Spurious Actuation and Very Unlikely to Distract Operator 4 No 0.05 No Safe Shutdown Systems Affected

- All HP and LP Injection Sources Available on All Units Very Limited Potential for Spurious Actuation and Very Unlikely to Distract Operator Enclosure 2 11

IlE Risk Significance Basis of Fire Human Reliability Analysis (HRA)

  • Draft NUREG-1921 Issued for Comment November 2009 (most recent NRC guidance)
  • Most Appropriate Characterization of Operator Entry into SSls when More than Adequate Equipment Remains Unaffected by Realistic Fire Scenarios would be as an Error of Commission (EOC)
  • Using Draft NUREG-1921 Figure 5-6 Flow Chart Logic, TVA Selected AK as the Applicable Human Error Probabilities (1.0, 0.25, and 0.05)
  • TVA Concludes that these Factors are Conservative and Appropriate Enclosure 2 12

UE Risk Significance

  • TVA Calculation of Core Damage Frequency (CD F)

U1 U2 U3 TVA CDF 8.4E-06 6.8E-06 6.0E-06

  • This Reflects Low to Moderate Risk (1 E-06 to 1E-05)
  • These Results are Conservative

- NRC, EPRI and the Nuclear Industry have Identified Conservatisms in the Current Fire PRA Methodologies used in Both the TVA and NRC Analyses

- NRC could Accept TVA Results and Still Conservatively Bound Plant Risk Enclosure 2 13

mil Risk Significance TVA Calculation of Large Early Release Frequency (LERF)

  • Approach Similar to that Used in NUREG/CR-6595 "An Approach for Estimating the Frequencies of Various Containment Failure Modes and Bypass Events"
  • Each Individual Fire Scenario was Assessed to Determine the Multiplier for CDF Appropriate to Calculate the LERF
  • Equivalent Scenarios were Identified in the Browns Ferry PRA Model and were used to Calculate the Multiplier
  • Application of the Multipliers Demonstrates that the LERF Value is more than a Factor of Ten Below the CDF
  • Therefore, LERF is not the Dominant Factor in this Significance Determination Enclosure 2 14

fi§] Risk Significance Technical Conclusions

  • Both NRC and TVA Analyses are Conservative
  • TVA Analysis Refines NRC Inputs Based upon Detailed Analyses Performed by TVA Following the Inspection
  • CDF (not LERF) Determines Significance of Apparent Violations 1 and 2
  • Overall Risk Associated with Apparent Violations 1 and 2 is Low to Moderate Enclosure 2 15

Ii§] Risk Significance Apparent Violation 3

  • Issue - Inappropriate Change to SSI Could Result in Delayed Entry or Prevented Entry into SSls

- This Deficiency was in Effect for 66 Days

  • TVA Performed a Qualitative Evaluation as well
  • TVA Concludes the Risk Associated with Apparent Violation 3 is Very Low Enclosure 2 16

1m Risk Significance Apparent Violation 3

  • Insights to Mitigate Risk Significance Became Available After Inspection

- Additional Walk-downs and Operator Reviews were Performed which Determine Additional Equipment Available

  • The Operators would Enter the SSls when Required in Accordance with Procedures
  • High Likelihood that Offsite Power Would Have Remained Available

- Evaluation Performed to Support Licensee Event Report Issued on November 3, 2009

- Power Available to Equipment to Perform Core Cooling and Containment Cooling Functions Enclosure 2 17

liE Risk Significance Apparent Violation 3

  • Potential Means of Ensuring that the Core Would Have Remained Covered

- Condensate and Feedwater System (combined)

- Control Rod Drive System

- Reactor Core Isolation Cooling System

- High Pressure Coolant Injection System

- Condensate System

- Low Pressure Coolant Injection I

- Low Pressure Coolant Injection II

- Core Spray System I

- Core Spray System II Enclosure 2 18

lm Risk Significance Apparent Violation 3

  • For Scenarios Involving a Loss of Offsite Power (Turbine Building Fires)

- High Likelihood that the Emergency Diesel Generators Would Have Remained Available

- High Likelihood that Equipment Would Have Been Available to Perform Core Cooling and Containment Cooling Functions Conclusion

  • The Deficient Procedure was in Place for 66 Days
  • Credit should be Permitted for Other Available Equipment
  • Qualitatively, the Risk Associated with Apparent Violation 3 is Very Low Enclosure 2 19

fi!4l Risk Significance Corrective Actions to Further Reduce Risk Significance

  • Fire Watches

- Established Roving Fire Watches (Completed)

  • To Reduce Probability of Ignition and Propagation of Fire at BFN
  • Improvements to SSls

- Examples

- Likelihood of Success Increased

  • Added Confirmation Steps for Risk Significant OMAs (Completed)

- To Improve Reliability of Operator Actions Enclosure 2 20

lm Risk Significance Corrective Actions to Further Reduce Risk Significance

  • Revise SSI Entry Conditions to Reduce Ambiguity

- Performing Detailed Analysis to Ensure Consistency between Safe Shutdown Analysis and SSI

- Ensure Operations Involvement

  • Ensure Condensate Storage Tank Suction Path for High Pressure Coolant Injection/Reactor Core Isolation Cooling (Completed)
  • The Following Actions also Serve to Mitigate Fire Risk During the Transition to NFPA 805

- BFN has a Dedicated Fire Operations Organization

- Upgraded Fire Detection and Suppression Systems as Part of Unit 1 Restart Enclosure 2 21

[is] Risk Significance Corrective Actions to Further Reduce Risk Significance

  • Plant Modifications and Additional SSI Improvements are being Developed and Prioritized as Part of NFPA 805 Transition

[ml Transition to NFPA 805 Project Goals

  • Eliminate Self Induced Station Blackout (SISBO) Methodology
  • Eliminate Time Critical OMAs
  • Revise SSls to Relieve Existing Operator Burdens
  • Establish Clear Licensing Basis
  • Eliminate Need for Compensatory Measures
  • Implement Risk-informed, Performance-based Program in accordance with 10CFRSO.48(c)

Enclosure 2 23

[ml Transition to NFPA 805 Project Approach

  • Benchmarked Industry for Best Practices
  • Project Scope Incorporates Industry Lessons Learned
  • Assigned Integrated Project Team of Full-time TVA and Contract Resources (Backfilled Site Engineers)
  • Developed Detailed Project Schedule
  • SSI Improvements and Plant Modifications will be Prioritized to Provide Early Benefit, where Appropriate
  • Additional Funding for Modification Scope is Fully Supported
  • Full Implementation of this Project is Endorsed by TVA Senior Leadership Enclosure 2 24

II!lJ Transition to NFPA 805 Current Status

  • The Transition is Progressing in Accordance with TVA's Plan

- MSO Process - 70% Complete

- Review and Upgrade Safe Shutdown Equipment List and Logic - 30% Complete

- Nuclear Safety Capability Assessment - 15% Complete

- Licensing Review - 15% Complete

- Safe Shutdown Analysis Upgrade - 5% Complete

- Circuit Analysis and Cable Routing for New Components - Begins March 2010

- Fundamental Fire Protection Code Reviews - 4% Complete

- Plant Partitioning - 240/0 Complete

- Fire PRA Component Selection - 60% Complete

- Fire Ignition Frequencies - 50% Complete Enclosure 2 25

1m Transition to NFPA 805 Strong Corporate Governance and Oversight

  • Fire Protection (FP) Program Manager Providing Technical Direction
  • Regular Weekly Team Conference and Monthly Face-to-Face Status Meetings
  • Direct Support by Experienced Corporate PRA Staff

- Staff Increased from 3 to 19 Since August 2007

  • Heavy Involvement in Industry Forums
  • Staff Supported Nine Industry Peer Reviews including Two Fire PRA Peer Reviews to Date Enclosure 2 26

[i!l Closing Remarks

  • Strengthened Governance of Plant Activities by Corporate Functional Areas
  • Apparent Violation 1 Risk is Low to Moderate
  • Apparent Violation 2 should be Combined with Apparent Violation 1
  • Apparent Violation 3 Risk is Very Low
  • Corrective Actions taken to further Reduce Risk Significance
  • Cross Cutting Issues are Legacy Issues and Have Been Previously Addressed
  • Corrective Actions will Reduce Risk during the Transition to NFPA 805 Enclosure 2 27
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