CNL-13-118, Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk
| ML13333A169 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/22/2013 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-13-118 | |
| Download: ML13333A169 (3) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-13-118 November 22, 2013 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 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:
Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk
References:
- 1. Letter from TVA to NRC, "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)" dated March 27, 2013 (ADAMS Accession No. ML13092A393)
- 2. Letter from TVA to NRC, "Response to NRC Request to Supplement License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187)," dated May 16, 2013 (ADAMS Accession No. ML13141A291)
By letter dated March 27, 2013 (Reference 1), Tennessee Valley Authority (TVA) submitted a
.license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to transition to National Fire Protection Association Standard (NFPA) 805. As part of the LAR, TVA included interim compensatory measures to reduce the fire risk during the transition to NFPA 805. These interim compensatory measures were in addition to the existing BFN fire protection requirements existing at that time. The commitments were identified in the attachment to the Reference 1 letter as Commitments 3 through 18. These commitments were updated by letter dated May 16, 2013 (Reference 2) and a new commitment (i.e.,
commitment 19) was added that required TVA to inform the NRC 30 days prior to discontinuing each of the interim compensatory measures identified in Commitments 3 through 18 of Enclosure 2 to the Reference 2 letter.
Printed on recycled paper a
U.S. Nuclear Regulatory Commission Page 2 November 22, 2013 Commitment 4 in both the References 1 and 2 letters stated:
"TVA will implement stricter control of transient combustibles for the following BFN FAs
[Fire Areas]: 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."
This letter is provided to inform the NRC, as required by Commitment 19 of the Reference 2 letter, that the above commitment will be modified to delete Fire Area (FA) 26 from the above commitment requirement. The change to plant procedures deleting (i.e., discontinuing) the stricter transient combustible controls for FA 26 described above will be implemented no earlier than 30 days from the date of this letter.
TVA has performed the appropriate reviews against the current licensing basis and determined that this commitment change is acceptable as transient fire scenarios do not constitute a significant contribution to total Core Damage Frequency for FA 26. Fire Area 26 includes the Turbine Building, Radwaste Building, Main Steam Valve Vaults, and Cable Tunnel to fire door 440. The TVA evaluation that was the basis for adding the interim compensatory measures did not identify FA 26 as a high risk area with regard to transient combustibles. Rather the evaluation only determined that FA 26 was a high risk area with regard to hot work activities. Thus, TVA is continuing to maintain the interim compensatory measure (i.e., Commitment 5 in the References 1 and 2 letters) requiring additional controls on hot work activities in FA 26, which are in place to reduce the frequency of a fire.
Furthermore, this change does not affect the normal transient combustible controls currently in place for FA 26.
Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.
Respec y,
SShea ic President, Nuclear Licensing cc: See Page 3
U.S. Nuclear Regulatory Commission Page 3 November 22, 2013 cc :
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health