ML13092A393

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)

ML13092A393
Person / Time
Site:	Browns Ferry
Issue date:	03/27/2013
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13092A393 (7)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 March 27, 2013 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 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:

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)

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 (ML090650597)

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 (ML090750032)

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, "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," dated March 20, 2012

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

Confirmatory Order (Effective Immediately)," dated May 18, 2012 (ML12053A188)

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, GionetfTutdesP$-1 and S-2, only), and W from the Enclosure, this letter is uncontrolled.

U. S. Nuclear Regulatory Commission Page 2 March 27, 2013 In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," the Tennessee Valley Authority (TVA) is submitting a request for amendments to the Renewed Facility Operating Licenses and Technical Specifications (TS) for Browns Ferry Nuclear Plant (BFN), Units 1, 2 and 3.

This License Amendment Request (LAR) requests Nuclear Regulatory Commission (NRC) approval for adoption of a new fire protection licensing basis that complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." This amendment request also follows the guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," as supplemented by approved Frequently Asked Questions. Upon approval, the BFN fire protection program will transition to a new Risk-Informed, Performance-Based (RI-PB) alternative in accordance with 10 CFR 50.48(c), which incorporates by reference National Fire Protection Association Standard 805 (NFPA 805). The NFPA 805 fire protection program will supersede the current fire protection program licensing basis, which is in accordance with 10 CFR 50, Appendix R.

In a letter dated March 4, 2009, TVA committed to submit a LAR by March 4, 2012 (Reference 1) for BFN Units 1, 2, and 3 to transition to 10 CFR 50.48(c), and requested the continuation of enforcement discretion through the NFPA 805 LAR approval process. In a letter dated September 17, 2009 (Reference 2) the NRC granted a three year enforcement discretion period. In accordance with NRC Enforcement Policy, the enforcement discretion period will continue until the NRC approval of the LAR is obtained. In a letter dated January 13, 2012 (Reference 3) TVA informed the NRC that the schedule for submitting an application to adopt NFPA 805 had been revised to no later than March 29, 2013. By letter dated March 20, 2012 (Reference 4) TVA requested an extension of the enforcement discretion period. By letter dated May 18, 2012 (Reference 5) the NRC issued a Confirmatory Order to revise the date for the submittal of an acceptable license amendment request to March 29, 2013. The enforcement discretion period will continue until the NRC issues a License Amendment. Submittal of this license amendment request satisfies requirement V.A. of the Reference 5 Confirmatory Order and supports continuation of enforcement discretion through the NFPA 805 LAR review and approval process. The transition to the proposed new fire protection licensing basis includes the following activities: a new fire safe shutdown analysis, a new Fire Probabilistic Risk Assessment (PRA), and completion of activities required for transitioning the licensing basis to 10 CFR 50.48(c).

The Enclosure to this letter contains the BFN Units 1, 2, and 3 NFPA 805 Transition Report (TR) and its supporting attachments. The TR provides the required technical and regulatory assessments to enable NRC review and approval of the new licensing basis. The BFN TR is based on a template developed by the NEI NFPA 805 Task Force and includes the resolution of applicable Frequently Asked Questions contained in Revision 10 of this template.

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-1 and S-2, only), and W from the Enclosure, this letter is uncontrolled.

U. S. Nuclear Regulatory Commission Page 3 March 27, 2013 The Enclosure contains security-related information. Specifically, Attachments C (Table C-1 only), E, G, S (Tables S-1 and S-2 only), and W contain security-related information and should be withheld from public disclosure under 10 CFR 2.390.

TVA requests approval of this LAR within 24 months after the date of this letter, and proposes to implement the new fire protection licensing basis in accordance with the implementation schedule provided in Section 5.5 of the TR. However, the final actions and modifications to be implemented may change as a result of the NRC review process. Specific modifications and activities required for implementation are listed in Tables S-2 and S-3, respectively, of Attachment S of the TR.

TVA has determined that a number of fire areas represent a higher contribution of risk to the BFN core damage frequency (CDF) as a result of a fire than other fire areas and should be subject to interim compensatory measures. This determination is based on the results of the fire probabilistic risk assessment of BFN as an NFPA 805 "compliant plant," as defined in Attachment W of the enclosure to this letter. The interim compensatory measures are in addition to the currently existing BFN fire protection requirements and compensatory measures and will apply until the modifications described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed. The additional compensatory measures are identified in the regulatory commitment attachment (Commitments 3 through 18).

There are 18 new regulatory commitments in this submittal as reflected in the attachment to this letter.

Please direct any questions concerning this matter to E. D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of March 2013.

Respe Ily, ic.P resident, Nuclear Licensing

Attachment:

List of Regulatory Commitments

Enclosure:

Browns Ferry Nuclear Plant Units 1, 2, and 3 NFPA 805 Transition Report cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Public Health Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-1 and S-2, only), and W from the Enclosure, this letter is uncontrolled.

ATTACHMENT List of Regulatory Commitments

1. TVA will submit a License Amendment Request proposing Technical Specifications requirements for the new emergency high pressure makeup pump system on a schedule to support the modification implementation date provided in Section 5.5 of the enclosure to this letter.

2. TVA will revise the program that monitors BFN Residual Heat Removal (RHR) heat exchanger performance for consistency with the assumptions of the NFPA 805 Net Positive Suction Head (NPSH), Containment Parameters, and AREVA Fuel peak centerline temperature (PCT) Analysis calculation related to the RHR heat exchanger k-factor within 6 months following NRC approval of this amendment request.

3. TVA will maintain the existing hourly roving fire watches for all existing BFN fire areas (FAs):

until the modifications described in Attachment S, 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.

4. TVA will implement stricter control of transient combustibles for the following BFN FAs:

FA 01-03, FA 01-04, FA 02-02, FA 02-03, FA 02-04, FA 03-01, FA 03-02, FA 03-03, FA 04, FA 08, FA 09, FA 16 (except for Main Control Room), FA 20, FA 21, FA 22, FA 23, FA 24, FA 25-01, and FA 26 until the modifications described for the listed FAs in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

These controls will consist of:

a. Requiring permits to allow transient combustibles into these higher risk areas;

b. Tracking these permits to control quantities of transient combustibles allowed into these fire areas; and

c. Performing once-per-shift walkdowns to ensure that transient combustible controls are satisfied (e.g., waste, debris, scraps, rags, or other combustibles resulting from work activities are removed from the subject fire areas, and that no transient combustibles are placed in the 20-foot exclusion zone(s) within the listed FAs).

TVA will implement these controls by May 31, 2013.

5. TVA will implement controls limiting hot work activities (e.g., welding, cutting, and grinding) in FA 01-03, FA 01-04, FA 02-02, FA 02-03, FA 02-04, FA 03-01, FA 03-02, FA 03-03, FA 04, FA 08, FA 09, FA 16, FA 20, FA 21, FA 22, FA 23, FA 24, FA 25-01, FA 26, and FA SWITCH until the modifications described for the listed FAs in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

If hot work activities are necessary, the existing hot work controls specified in NPG-SPP-18.4.8, Control of Ignition Sources, shall be augmented to require that the Fire Brigade or Senior Reactor Operator perform a pre-job briefing in accordance with NPG-SPP-18.2.2, Human Performance Tools, and perform a walkdown for job area familiarization prior to performing the hot work activity. This walkdown shall include, ensuring travel path is clear of obstructions, identifying the location of fire hoses and fire Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-I and S-2, only), and W from the Enclosure, this letter is uncontrolled.

extinguishers, and verifying fire suppression systems (manual and automatic) are properly aligned.

TVA will implement these controls by May 31, 2013.

6. TVA will implement controls to credit temporary diesel generators as an additional power source for a shutdown board, except during those periods when the temporary diesel generators are being used to support alternate decay heat removal until the modifications described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

7. TVA will implement controls to protect RHR Pump 1A and its associated support systems whenever hot work activities are performed in FA 01-04, FA 04, and FA 09 until the modifications for the listed FAs described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

8. TVA will implement controls to protect the Unit 1 RHR Train A and its associated support systems whenever hot work activities are performed in FA 08 until the modifications associated with FA 08 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

9. TVA will implement controls to protect the following equipment whenever hot work is being performed in FA 02-02 until the modifications for FA 02-02 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North Emergency Equipment Cooling Water (EECW) Header;

c. 4kV Shutdown Board B, 3EA, 3EB;

d. 250V DC Battery Charger 1;

e. 480V Reactor Motor Operated Valve (RMOV) Board 1A, 2A, 2D;

f. 480V Shutdown Boards 1A and 2A;

g. 2C RHR Pump;

h. 480V Shutdown Board 2A Transformer TS2A; and

i. Shutdown Board 250V DC Battery Charger SB-B.

TVA will implement these controls by May 31, 2013.

10. TVA will implement controls to protect the following equipment whenever hot work is being performed in FA 02-03 until the modifications for FA 02-03 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. Residual Heat Removal Service Water (RHRSW) Pump D1;

d. 4kV Shutdown Board D, 3EA, 3EB;

e. 250V DC Battery Charger 1;

f. 480V RMOV Board 1A, 2B, and 3A;

g. 480V Shutdown Boards 1A and 2B;

h. 2D RHR Pump & RHR Crosstie Unit 3 to Unit 2; and

i. 480V Shutdown Board 2B Transformer TS2B.

TVA will implement these controls by May 31, 2013.

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-I and S-2, only), and W from the Enclosure, this letter is uncontrolled.

11. TVA will implement controls to protect the following equipment whenever hot work is being performed in FA 02-04 until the modifications for FA 02-04 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. B1 and D1 RHRSW Pump;

d. 4kV Shutdown Board D, 3EA, 3EB, and 3ED;

e. Shutdown Board 250V DC Battery Charger SB-D;

f. 480V RMOV Board 1A and 3B;

g. 2D RHR Pump; and

h. 480V Shutdown Board 2B Transformer TS2B.

TVA will implement these controls by May 31, 2013.

12. TVA will implement controls to protect RHRSW Pump 2B and its associated support systems whenever hot work activities are performed in FA 03-03 until the modifications for FA 03-03 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

13. TVA will institute 30-minute roving fire watches in FA 16 for non-continuously manned areas until the modifications for FA 16 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

14. TVA will designate the FA 04, FA 08, FA 09, FA 16 (Cable Spreading Room only), FA 22, FA 23, FA 24, and FA 25-01 as transient combustible-free areas and establish the same controls as the current 20-foot exclusion zones, except that tags required by plant procedures may be present in these FAs, until the modifications for the listed FAs described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

15. TVA will implement controls to limit the unavailability of an entire EECW header (north or south) until the modifications for FA SWITCH described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

16. TVA will increase the testing frequency of automatic fire doors in FA 22, FA 23, and FA 24 to once-per-6 months until the modifications described for the listed FAs in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

17. TVA will implement controls to protect the following equipment whenever hot work is being performed in FA 20 until the modifications for FA 20 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. 4kV Shutdown Board 3EA and 3EB;

d. 480V Common Board 1 Transformer TC1A; and

e. 250V DC Battery Charger 1.

TVA will implement these controls by May 31, 2013.

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-1 and S-2, only), and W from the Enclosure, this letter is uncontrolled.

18. TVA will implement controls to ensure that Heating, Ventilation and Air Conditioning (HVAC) is available to the BFN Unit 3 Main Control Room whenever Transformer TS3A is unavailable or the EECW South Header is unavailable until the modifications for FA 20 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. Portions of the Enclosure contain Security-Related Information. Upon removal of Attachments C (Table C-1, only), E, G, S (Tables S-1 and S-2, only), and W from the Enclosure, this letter is uncontrolled.