ML12083A198

Request for Extension of Enforcement Discretion Regarding Transition to National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition

ML12083A198
Person / Time
Site:	Browns Ferry
Issue date:	03/20/2012
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12083A198 (10)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 March 20, 2012 10 CFR 50.4 10 CFR 50.48 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Request for Extension of Enforcement Discretion Regarding Transition to National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition, for Browns Ferry Nuclear Plant Units 1, 2, and 3,

References:

1. Letter from TVA to NRC, "Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Letter of Intent to Adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition," dated March 4, 2009.

2. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, And 3

- Response to Letter of Intent to Adopt Title 10 of The Code of Federal Regulations, Part 50, Section 48(c)," dated September 17, 2009

3. Letter from TVA to NRC, "Revised Submittal Schedule for License Amendment Request to Adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition, for Browns Ferry Nuclear Plant Units 1, 2, and 3," dated January 13, 2012.

4. Letter from TVA to NRC, "Additional Planned Fire Risk Reduction Modifications for Browns Ferry Nuclear Plant Units 1, 2, and 3," dated February 17, 2012.

5. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, and 3

- National Fire Protection Association (NFPA) - 805 License Amendment Request Delay," dated March 9, 2012. ,OL42

U.S. Nuclear Regulatory Commission Page 2 March 20, 2012 By letter dated March 4, 2009 (Reference 1), the Tennessee Valley Authority (TVA) informed the NRC of plans to submit a license amendment request to adopt National Fire Protection Association Standard 805 (NFPA Standard 805), Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition within approximately three years of the reference letter. By letter dated September 17, 2009 (Reference 2), the NRC acknowledged TVA's intent to transition Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 to NFPA 805 and in accordance with the NRC's Interim Enforcement Policy granted BFN Enforcement Discretion for Certain Fire Protection Issues for a period of three years beginning on March 4, 2009.

At a public meeting between the NRC staff and TVA representatives on December 8, 2011, TVA described the strategy it has pursued of performing modifications to the BFN and its associated procedures in parallel with development of a license amendment request to adopt NFPA Standard 805. The objective of the parallel approach has been to achieve meaningful reduction in fire risk at BFN while simultaneously pursuing the regulatory basis provided by NFPA Standard 805. TVA has completed several key modifications to the facility that have improved risk and reduced the number of time critical operator manual actions required to implement the current safe shutdown fire strategy.

As a follow-up to the December 8, 2011, public meeting, in letter dated January 13, 2012 (Reference 3), TVA informed the NRC that the schedule for submitting an application to adopt the NFPA Standard 805 for BFN had been revised to no later than March 29, 2013. Additionally, TVA provided a list of completed modifications and a list of additional planned modifications and associated implementation schedules in February 17, 2012, letter (Reference 4). In a public teleconference held on February 29, 2012, TVA further outlined the reasons for the proposed revision to the NFPA 805 application submittal date and major activities that need to be completed in support of the submittal.

By letter dated March 9, 2012 (Reference 5), the NRC requested that TVA provide additional information to justify the revised license amendment submittal date. This response provides the requested additional information. Additionally, TVA will ensure that the following information is available for NRC review:

1. Listing of all fire protection-relatednoncompliances and the related compensatory measures for those noncompliances.

2. Documentation ensuring each OperatorManualAction put in place as a compensatory measure is feasible and reliable, in accordancewith the guidance in Regulatory Issue 2005-07, "CompensatoryMeasures to Satisfy the Fire ProtectionProgramRequirements",

and,

3. A description of the physical modificationsperformed, if any, to addressexisting fire protection issues and noncompliances.

U.S. Nuclear Regulatory Commission Page 3 March 20, 2012 The enclosure to this letter contains a table which provides the status and completion schedule, as of March 14, 2012, for the remaining key activities and major milestones for completing TVA's license amendment request. The targeted completion dates in the enclosure were established to provide schedule margin to ensure TVA meets the March 29, 2013 commitment to submit an NFPA 805 license amendment request.

Section 9.1 of the NRC Interim Enforcement Policy states in part that enforcement discretion may apply to noncompliances identified during the licensee transition process. This timeframe starts on the date as specified in the licensee's letter of intent to transition to 10 CFR 50.48(c) and ends (1) 3 years after that initial start date or (2) on the date as specified in the licensee's commitment letter, as amended and approved by the NRC. Additionally, SECY-12-0031 provides the NRC Staff position that enforcement discretion could be extended if the licensee provides adequate justification. In evaluating the justification provided by a licensee, the staff would consider, but not be limited by, the status of the industry peer review, plant modifications, and the licensee's compliance reviews.

TVA has made significant progress in several key areas of the NFPA Standard 805 transition project. The initial PRA peer review has been completed. In the area of Fundamental Fire Protection Program Review, all 14 NFPA Code Compliance Evaluations are either complete or in review. For Nuclear Safety Capability Assessment, the Safe Shutdown Equipment List and Safe Shutdown Circuit Analysis have been issued for review. The circuit analysis for Non Power Operations components has been completed. Additional details are provided in the enclosure. TVA is requesting extension of Enforcement Discretion for Certain Fire Protection Issues during the period of transition to National Fire Protection Association (NFPA) 805 for BFN Units 1, 2 and 3 until March 29, 2013.

If you have any question on these matters, please contact me at 423-718-9576.

There are no new commitments contained in this letter.

Resp ully, r

u cl g eLicensing orate Nuclear

Enclosure:

Status and Schedule of Major NFPA 805 Milestones

U.S. Nuclear Regulatory Commission Page 4 March 20, 2012 cc (Enclosure):

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

ENCLOSURE Request for Extension of Enforcement Discretion Regarding Transition to National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition for Browns Ferry Nuclear Plant Units 1, 2, and 3, Status and Schedule of Major NFPA 805 Milestones

Enclosure Status and Schedule of Major NFPA 805 Milestones (as of March 14, 2012) runaameniai ri-i Classical Fire Protection Transition Program Review 6 - Complete NFPA Code Compliance 15-Jan-10 04-Jun-12 7 - Final Review 14 total code compliance evaluations Evaluation 1 - Draft Issued for required Review Reviewing and Existing Equivalency Evaluation 01-Feb-10 20-Apr-12 Incorporating Transition Comments Final Owner Review Fire Area Licensing Action Review 02-Nov-09 28-Mar-12 Complete - Vendor Report has been issued for comment.

Nuclear Safety Capability Nuclear Safety Performance Assessment (NSCA) Criteria Transition SSEL and Logic Review and Upgrade Safe Review and Upgrade Shutdown Equipment List (SSEL) 14-Dec-09 14-May-12 Complete - Draft and Logics Calculation issued for Review SSD Circuit Analysis Review and Upgrade Safe 12-Mar-10 11-Apr-12 Complete - Draft Shutdown (SSD)Circuit Analysis Calculation issued for review Pass 1a was started to facilitate parallel path activities - initial fire area 43 of 43 Fire Areas assessments were conducted while Complete cable routing and circuit analysis was still in development to identify and address generic/high level issues 2 of 43 Fire Areas in 15 Pass lb is the completed fire area Fire Area Assessment - Pass 1 b 23-Feb-12 28-Jun-12 Progress assessment input to the Fire Risk Evaluations (FREs)

Pass 2 is final pass after FREs are 15-May-12 02-Aug-12 Not Started Plete Fire Area Assessment - Pass 2 II I Icomplete E-1

Enclosure Status and Schedule of Major NFPA 805 Milestones (as of March 14, 2012) inl11lal iMuflO~~iation Scope Identified (see See February 17, 2012 letter to NRC comments) -

NFPA 805 Modification Scoping 03-Nov-i 1 04-Oct-12 for modifications committed to be Additional Scope will implemented proactively be Determined upon Completion of FREs Non-Power Operational (NPO) Non-Power Operational Modes Modes Transition Transition Perform Circuit Analysis for NPO 18-Nov-10 19-Mar-12 Complete Components In Progress - Analysis Pinch Point Analysis is used to Pinch Point Analysis and 03-Jan-12 28-Aug-12 Currently being evaluate scenarios where a single fire Suggested Procedure 0rentlybei may damage all the credited paths for eDeveloped a Key Safety Function (KSF).

Develop Fire Probabilistic Risk Assessment (PRA)

Fire Risk Quantification 1 with most conservative assumptions on cable Complete (F&O routing, fire modeling and circulate Fire PRA Peer Review 23-Jan-12 27-Jan-12 resolution in progress) likelihood were used. Many F&Os were due to the status of incompletion or lack of refinement for high-risk scenarios.

Use of 9 8 th percentile Heat release 1

Reactor Building rate (HRRs) for transients and lack of Scoping Fire Modeling 08-Nov-12 01-May-12 walkdown completed crediting manual suppression before fire damages targets were main causes of conservatism in the model.

Crediting the delay of Flamemastic coatings for fire propagation to May be extended to address follow-up Self Igniting Cable Fire Scenarios 07-Feb-12 24-Apr-12 adjacent cable trays F&O resolution for top risk-contributing fire areas in progress E-2

Enclosure Status and Schedule of Major NFPA 805 Milestones (as of March 14, 2012) mevision i wa5 resirlcwe uo llmiieu Circuit Failure Mode and components. Revision 2 will cover 29-Aug-i 1 31-May-12 Revision 2 in Progress Likelihood Analysis more components including those with hiah risk.

Findings &

Development of Main Control 07-Feb-12 07-May-12 Observations (F&Os)

Room Analysis resolution of peer review in progress In progress for top May be extended to address follow-up Detailed Fire Modeling 07-Feb-12 22-Jun-12 risk-contributing fire F&O resolution areas Scoping approach used; scenarios Includes follow-up F&O resolution and Post-Fire Human Reliability 12-Oct-10 11-Jul-1 2 based in progress for may be extended to address F&O Analysis top risk-contributing resolution fire areas NSCA equipment to equipment logic being incorporated; first Quantification 2 includes model Fire Risk Quantification 2 23-Jan-12 24-Jun-12 cutset review planned refinement for high-risk scenarios and in April; initial peer review F&O resolution.

Quantification 2 in progress.

Review focus is on the following Initial Peer review elements: Fire Scenario Selection, Follow-Up Focused Fire PRA Peer 25-Jun-12 29-Jun-12 F&Os being Human Reliability Analysis, Review addressed Quantification, and Uncertainty Analysis Some F&Os will not be resolved until F&O Resolution of Initial and after SER is approved (e.g., fire F&olRsolution or Iial a6-Feb-12 6-Nov-12 In-Progress procedures based on the fire PRA Follow-up Peer Reviews and fire risk evaluations need prior NRC approval)

E-3

Enclosure Status and Schedule of Major NFPA 805 Milestones (as of March 14, 2012) r eL, quipirwi Lu equipment logic being incorporated; first Those F&Os affecting the PRA model cutset review planned and resolvable before LAR approval in April; will be resolved prior to Quantification Fire Risk Quantification 3 12-Jan- 12 13-Sep-12 Quantification 2 in 3, which represents the PRA model progress.

for final risk evaluation and LAR Quantification 3 will be submittal.

continuing to address follow-up peer review F&O resolutions.

Methodology of all This is completion of the PRA model Revise and Complete the PRA elements for FRE and LAR submittal; final PRA Probabilistic Risk Assessment 12-Jan-12 6-Nov-12 completed; documentation will be completed by documentation of final November 6, 2012 for PORC/NSRB PRA will be started after quantification 3.

FREs will be performed using a Fire Risk Evaluations (FREs) 27-Mar-12 25-Jul-I 2 Pilot FRE process staggered approach for each fire area started on March 6 based on PRA quantification and fire area assessments In order to facilitate timely review, the NFPA 805 LAR will be prepared and Prep of LAR and Transition Report reviewed by BFN PORC and TVA NSRB in 3 Groups.

(Executive Summary, Sections: 1, 2, Prepare Group I Segment of [AR 23-Jul-12 27-Jul-12 3, 4.2.2, 4.2.3, 4.4, 4.6 & 4.7 -

submittal__Attachments: E, K, M, N, 0 & P)

BFN Group 1ITechnical Review 27-Jul-12 03-Aug-12 BFN Group 1 Licensing Review 30-Jul-12 06-Aug-12 BFN Group 1 PORC Subcommittee Review 08-Aug-1 2 17-Aug-1 2 E-4

Enclosure Status and Schedule of Major NFPA 805 Milestones (as of March 14, 2012) t/-%Lru[yFI UI51, OUI*AWIRSI. z'+. 1I.0, Prepare Group 2 Segment of LAR 27-Sep-12 01-Oct-12 4.2.1.1, 4.2.1.2, & 4.3 - Attachments:

submittal B, D, H, I, L & T)

BFN Group 2 Technical Review 01-Oct-12 05-Oct-12 BFN Group 2 Licensing Review 02-Oct-12 09-Oct-12 BFN Group 2 PORC Subcommittee Review 15-Oct-12 19-Oct-1 2 (Acronym List, Sections: 4.2.1.3, Prepare Group 3 Segment of LAR 22-Oct-12 26-Oct-12 4.2.1.4, 4.2.4, 4.8, 5 & 6-Attachments:

submittal__C,F,G,J,Q,R,S,U,V,W)

BFN Group 3 Technical Review 26-Oct-12 02-Nov-12 BFN Group 3 Licensing Review 29-Oct-12 05-Nov-12 BFN Group 3 PORC Subcommittee Review 05-Nov-12 12-Nov-1 2 Final PORC/NSRB Approval 12-Nov-12 05-Dec-12 Submit LAR to NRC 06-Dec-12 17-Dec-12 Final approvals and executive Submit____________________

to_ _____ _ _signature process E-5