ML12066A196
| ML12066A196 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/09/2012 |
| From: | Doug Broaddus Plant Licensing Branch II |
| To: | James Shea Tennessee Valley Authority |
| Brown, Eva A. | |
| References | |
| Download: ML12066A196 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 9, 2012 Mr. Joseph W. Shea Corporate Manager - Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT, UNITS 1,2, AND 3-NATIONAL FIRE PROTECTION ASSOCIATION (NFPA)-805 LICENSE AMENDMENT REQUEST DELAY (TAC NOS. ME7841, ME7842, AND ME7843)
Dear Mr. Shea:
On March 4,2009, the Tennessee Valley Authority (TVA, the licensee) notified the U.S. Nuclear Regulatory Commission (NRC) of its intent to transition the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (BFN) to an NFPA 805 fire protection program in accordance with Section 50.48(c) to Title 10 of the Code of Federal Regulations (10 CFR). Under this initiative, the NRC has exercised enforcement discretion for most fire protection noncompliances that are identified during the licensee's transition to NFPA 805, and for certain existing identified noncompliances that reasonably may be resolved at the completion of transition. The licensee committed to submit an application by March 4, 2012, to transition to the new performance-based fire protection licensing basis. This submittal also captured a corrective action to resolve previously identified fire protection noncompliances, which were not eligible to receive enforcement discretion under Section 9.1, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," of the NRC Enforcement Policy (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML093480037)
In order to receive enforcement discretion for noncompliances, the licensee must meet the specific criteria as described in Section 9.1 of the NRC Enforcement Policy. The policy requires, in part, that the licensee submit an acceptable application to transition to the new performance-based fire protection licensing basis within 3 years of the letter of intent, or by that date as specified in the licensee's commitment letter, as amended and approved by the NRC.
J.Shea
- 2 In the licensee's revised commitment letter dated January 13, 2012 (ADAMS Accession No. ML12017A186), TVA stated that the development of a high quality application will require more time than originally anticipated, and TVA would submit its application no later than March 29, 2013. The newly proposed submittal date is beyond the enforcement discretion timeframe granted to BFN for certain fire noncompliances, which ended on March 4,2012.
In a letter dated February 17,2012, TVA also identified plant modifications that the licensee has already implemented or commits to implement, to improve plant fire safety in the interim. In a public teleconference held on February 29,2012, TVA further outlined the reasons for the delay and those major activities that need to be completed in support of the NFPA 805 submittal.
Consistent with Section 9.1 of the Interim Enforcement Policy, the NRC is requesting that TVA provide information to justify the revised submittal date. TVA is requested to submit a report on the status of the key activities and milestones necessary to submit a license amendment request as part of the transition to NFPA 805. This report should include a schedule of key activities and major milestones for completing the fire risk aspects of the license application, including conducting any industry peer reviews, completing resolution of peer review findings, revising and completing the probabilistic risk assessment, completing the subsequent fire risk evaluations, and formulation of the license amendment request. The report of TVA's status should also describe the progress made in the following areas:
- 1.
Classical fire protection transition;
- 2.
Nuclear safety performance criteria transition; and
- 3.
Non-power operation transitions.
TVA is also requested to ensure the following transition related information remains available for NRC staff review:
- 1.
Listing of all fire protection-related noncompliances and the related compensatory measures for those noncompliances;
- 2.
Documentation ensuring each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in Regulatory Issue 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements"; and,
- 3.
A description of the physical modifications performed, if any, to address existing fire protection issues and noncompliances.
J. Shea
- 3 This request was discussed with you on March 8,2012, and it was agreed that TVA would respond within 7 business days of the issuance of this letter.
If you should have any questions, please contact Ms. Eva Brown at 301-415-2315.
Sincerely, c=::>~~
Douglas A. Broaddus, Chief Plant licensing Branch 11-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296 license Nos. DPR-33, DPR-52, and DPR-68 cc: Distribution via listserv
- via email OFFICE DORULPL2-2/PM DORULPL2-2/LA DORULPL2-2/BC NAME EBrown BClayton DBroaddus DATE 03/09/12 03/09/12 03/09/12 OFFICE APLAlBC RII NAME DHarrisson EGuthrie*
DATE 3/9/12 03108/12