ML14209A863
| ML14209A863 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/27/2014 |
| From: | Justin Poole Watts Bar Special Projects Branch |
| To: | |
| Poole J | |
| Shared Package | |
| ML14209A882 | List: |
| References | |
| Download: ML14209A863 (17) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 27, 2014 APPLICANT: Tennessee Valley Authority FACILITY: Watts Bar Nuclear Power Plant, Unit 2
SUBJECT:
SUMMARY
OF JULY 16, 2014, MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING THE WATTS BAR NUCLEAR PLANT UNIT 2 OPERATING LICENSE APPLICATION On July 16, 2014, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of the Tennessee Valley Authority (TVA).
The purpose of this teleconference was for TVA staff to discuss issues related to the operating license application review for Watts Bar Nuclear Plant (WBN) Unit 2. There were two points of discussion at this meeting. The first focused on TVA's approach to address issues related to flooding analysis at the Watts Bar site, while the second focused on the NRC's requests for clarification related to TVA's partial submittal of the Fire Protection Report, which contained Parts II, Ill, IV, VIII, IX, and X. TVA plans to submit the remainder of the Fire Protection Report on August 15, 2014. A list of attendees for the teleconference is included in Enclosure 1. The handout discussing TVA's draft responses to the NRC's questions is included in Enclosure 2.
The new strategy TVA presented at this meeting for the flooding analysis at the Watts Bar site differs from the original path submitted as part of a License Amendment Request for WBN Unit 1 currently under review, which WBN Unit 2 planned to implement as well. Originally the staff had questions surrounding TVA's submitted justification of its use of different acceptance criteria for dam stability than what was described in the current final safety analysis report (FSAR) for WBN Unit 2 (and by extension of the current FSAR for WBN Unit 1). At this meeting, TVA discussed a new approach for handling the flooding issues related to the WBN site when encountering a probable maximum flood. TVA described that Tennessee Valley Authority River Operations (an independent authority on river operations issues including dam design and safety) (TVA River Ops) will evaluate the dams using thecurrent methodology and criteria, and for any dams that are found to be "at-risk," these would be further examined by TVA River Ops. TVA would propose a license condition for those dams to be upgraded to meet the new current standards and for these upgrades to be implemented in a certain timeframe. TVA also stated that they would have a third party review their calculations to ensure they reached reasonable conclusions, and submit corroborating calculations using a different computer model than the one they're currently approved to use. This additional information would serve no purpose other than providing additional justification to the data gathered from the approved model. The NRC would make no regulatory decisions based solely on the additional information.
The NRC made the comment that TVA should be sure to re-examine the effects of seismic events on surrounding structures and dikes in particular the West Saddle Dike given the change in methodology they are proposing. The NRC also requested that TVA's revised submittal
they would address the NRC's comments and concerns and planned to submit the revised request by August 31, 2014. No regulatory decisions were made during the teleconference.
During the second portion of the meeting the NRC and TVA went through each question and response found in Enclosure 2. During these exchanges, the NRC told TVA which responses satisfied their clarification requests and which ones need further explanation and/or revising of the Fire Protection Report itself. TVA stated that they would address these comments in the August 15, 2014, full submittal of the Fire Protection Report. The NRC and TVA agreed to meet at a time prior to the full submittal should further discussion be needed.
No regulatory decisions were made at this meeting.
No members of the public participated in this meeting.
Please direct any inquiries to me at 301-415-2048 or via e-mail at Justin.Poole@nrc.gov Justin C. Poole, Senior Project Manager Watts Bar Special Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-391
Enclosures:
- 1. List of Attendees
- 2. TVA Handouts cc w/encls: Distribution via Listserv
MEETING ATTENDANCE LIST Applicant: Tennessee Valley Authority Plant: Watts Bar Nuclear Plant, Unit 2
Subject:
Construction Status Date: July 16, 2014 Location: U.S. Nuclear Regulatory Commission Time: 12:30 o.m.- 3:00p.m.
Headquarters, Room 0-16B04 NAME TITLE ORGANIZATION NRC/NRRIDORL/Watts Bar Special Anthony Minarik Project Manager Projects Branch NRC/NRRIDORL/Watts Bar Special Justin Poole Sr. Project Manager, WBN 2 Projects Branch NRC/NRRIDORL/Watts Bar Special Siva Lingam Project Manager, WBN 1 Projects Branch NRC/NRRIDORL/Watts Bar Special Jeanne Dian Project Manager Projects Branch Andy Han Project Manager, SON NRC/NRRIDORL/LP2-2 Yuan Cheng Hydrologist NRC/NRRIDE/EMCB Yang Li Acting Branch "Chief NRC/NRRIDE/EMCB Dan Hoang* Sr. Engineer NRC/NRRIDE/EMCB Senior Fire Protection Daniel Frumkin NRC/NRRIDRA/AFPB Engineer Enclosure 1
NAME TITLE ORGANIZATION Charles Moulton Fire Protection Engineer NRC/NRRIDRA/AFPB Scott Shaeffer* Branch Chief NRC/ Region II/DRS Gordon Arent Director, WBN Licensing TVA Erin Henderson Director, SON Licensing TVA Rusty Stroud Licensing TVA Bill Crouch Engineering TVA Bob Bryan* Licensing TVA John Sturky* Licensing TVA Charles Brush* Fire Protection EPM
- via teleconference
ENCLOSURE 2 DRAFT RESPONSES FROM TVA RE: FIRE PROTECTION REPORT
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR NRC Question 1 -Part II. page 8; The revision regarding major modifications and new installations could be interpreted to mean that new installations may be installed to a historical code of record. Although this may be appropriate for modifications, even major modifications, no basis is provided for relying on historical codes of records for new installations.
D Provide a justification for relying on historical codes of records for new installations.
Response : It is TVA's intention to utilize the most recent version of the NFPA Code when installing totally new installations. We retained the reference to the original Code of Record only for situations where we expand/add to an existing feature. In tiis case, the expansion could be considered a "new" installation; however, we would want to rna e the expansion the same as the previously existing feature for maintenance and oper tio al fidelity.
NRC Question 2 - Part II, page 11; The Corporate Engineering Chief Engineer is listed as the Authority Ha *ng Jurisdiction (AHJ).
This is inconsistent with NRC regulatory guidance; ~egulatory Guide 1.189, Revision 2, section 1.8.6, states: "The AHJ (as described in NFPA docu ents) refers to the Director of NRR . .. , or designee, consistent with the authority specified in 10 CF 1.43, Office of Nuclear Reactor Regulation. "'
D Provide a description and examples of wno is program changes.
The phras " uthority having ju isdic ion,' or its acronym AHJ , is used in NFPA documents in a broad manner, since jurisdict10ns and ap roval agencies vary, as do their responsibilities. Where public safety i 12r1 ary, the AH may be a federal , state, local, or other regional department or individual such as a fi e chief; fire marshal, chief of a fire prevention bureau , labor department, or health department; b i cfng offi ial: electrical inspector; or others having statutory authority. For insurance purposes, a insurance inspection department, rating bureau , or other insurance company representative ay b the AHJ . In many circumstances, the property owner or his or her designated agent assumes the role of the AHJ ; at government Installations, the commanding officer or departmental official may be the AHJ .
TVA is a governmental installation and has previously defined the AHJ as described above.
Regulatory Guide 1.189 is a relatively new document to which WBN Unit 1 is not committed and thus the definition of AHJ should remain consistent with the previously approved version. WBN July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR utilizes the provisions of Generic Letter 86-10 to determine when changes are required to be submitted to the NRC for approval.
Other sections of the NFPA Code provide further definition of the responsibilities of the AHJ.
These responsibilities are at a much lower level of detail than the NRC typically gets involved.
NRC Question 3 - Part II, pages 16 and 17; 0 Provide clarification regarding whether actions taken in the auxiliary control room are considered Operator Actions or Operator Manual Actions.
Response: Operator manual actions as defined in NUREG 18'52 i eludes only "those actions performed by operators to manipulate equipment and com onert s from outside the main control room to achieve and maintain post-fire hot shutdown, but no including "repairs". As stated in footnote number 1 on page 1-1 of NUREG 1852, oper or ana I actions do not include any actions within the main control room or the action(s) a sociated with abandoning the main control room in the case of fire.
Successful demonstration (i.e., achievement of 100% time margin for actions in the auxiliary control room) of the main control room abandonment procedure was achieved by reordering steps to accomplish the "required" steps earlier in the process. This resulted in a small delay of some of the previously earlier steps; however, even though it is less efficient overall, no adverse impacts were created by the new procedure order.
July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR NRC Question 4 - Part II. pages 19 to 22; It appears that TVA has replaced the Part II discussion of fire protection program management organization, authorities, and responsibilities with references to other documents. 10 CFR 50.48(a) requires the program to include this information.
0 Justify the replacement of the information regarding the fire protection program organization, authorities, and responsibilities, with references to other documents.
Response: The organizational information was removed based on the information contained in the NRC safety evaluation (June 26, 1991) regarding the TVA organizational topical report (TVA-NPOD89-A). The safety evaluation states that "TVA intend to reference the Topical Report TVA-N POD-A in license applications, the Updated ~mal Safety Analysis Report (UFSAR), Technical Specifications (TSs), the Nuclear Q alit ssurance Plan, and other documents that may refer to the TVA Nuclear Power o ga ization". The Fire Protection Report was originally a part of the FSAR but was later movea *nto a separate document and is considered included in the UFSAR via a referen e in UFSAR Section .1.2 and 9.5.1. Based on the above guidance, the fire protection related in ormation was remo\lea from the FPR and placed with a reference to organizational topical report TVA-NPOD89-A whic was submitted to the NRC via TVA letter dated September 5, 2013.
0 0 d to the referenced documents, and how Response: Since t e organizational information will be restored to the FPR, this question is considered not applicable. The organizational information in the FPR will be included as part of the FPR updates submit ed on a schedule consistent with 10 CFR 50.71(e).
o In light of the change in 12.3.1, provide a description of how fire pumps are started in the event of manual initiation of a preaction sprinkler system.
Response: Site personnel are trained via General Employee Training to notify the main control room when any fire is detected. The WBN fire response procedure AOI-30.1, "Plant Fires",
"Operator Actions Guidelines" directs the main control room staff to ensure the available fire pumps are running.
July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR NRC Question 6 - Part II. page 38; o In light of this deletion , provide a summary of the design criteria for the carbon dioxide systems.
If a system doesn't meet the code of record, provide a discussion here (in Part II) or an evaluation in the appropriate part of the FPR.
Response: The Carbon Dioxide system meets the concentration requirements of NFPA-12 for deep seated fires and surface fires . The requirements of the referenced system description are the same as those previously in the Fire Protection Report. Deviation from the NFPA requirement would require a revision to the FPR (Part X) which would require NRC approval.
NRC Question 7- Part II. starting on page 43; 0 Provide a description of the wireless fidelity (wi-fi) syste Response: See separate page.
c Explain the capabilities the wi-fi system reg ranee for components (power supply, radios, transmitte to the two-way plant radio system.
Response: See separate page.
0 two-way radio system that the communication.
0 0 Explain and justify why the text requiring trained personnel was deleted from the description of the requirements for the use of CCTV as a compensatory measure.
Response: Fire watch personnel are formally trained regarding their duties, methods, expectations. The closed circuit televisions (CCTVs) are one of the basic tools used by the July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR trained fire watches. The use of the CCTV requires no formal training Uoy stick operation only) and is considered "skill of the trade" due to the simplicity of its use. The statement about "trained personnel" was removed to clarify there is no formal training for the use of the CCTV. As an alternative, the wording could have been changed to "CCTVs are monitored by fire watch personnel at a frequency ..."
NRC Question 10- Part II, page 63; D For 14.2.1 (a) and (b), justify the use of "and/or" for establishing compensatory measures.
Response: Fire watches (hourly versus continuous) would be esta lished corresponding to the areas/elevations for which the fire detection equipment is eit er o erable or inoperable. The wording refers to "if the fire detection for the area is operabl (o Inoperable)." It would not be reasonable to establish a fire watch on one elevation based on the status of the fire detection on a different elevation. Fire watches will be established on o ele t1ons; however, the frequency will be based on the operability of the detection on ac oor. It is ot necessary to establish continuous fire watches on both elevations if the etection on only o e of the elevations is inoperable. No further clarificatio to the wording is warra ted D Describe the conditions where one elevation would be excludeCffrom needing tHe compensatory measures, and the conditions where ottl wo ld.
D n
Response: It was not TVA's intent to allow the plant to delay entering 14.2.3, instead the plant would enter 14.2.3 at the same time as the diesel fire pump is restored . In order to prevent any confusion on this process, TVA will revise the 14.2.b as follows :
"restore the diesel driven fire pump within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />
-AND-and enter 14.2.3 ."
July 11 , 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR A review of the remainder of Section 14 did not identify any other similar occurences.
NRC Question 12 - Part II, page 68; o For 14.2.8, describe the difference between being controlled by a "procedure" versus "an approved configuration control method".
Response: Configuration control is accomplished using methods which are controlled by procedures; however, the actual document controlling the situation is not considered a "procedure". In this case, the control of the inhibited circuit can be accomplished under several different processes (e.g. , hold orders, temporary alteration, design change, etc). All of these methods are controlled by a procedure. However, the hold o der itself is not considered a procedure therefore the wording was clarified to refer to an.<app oved configuration control method.
NRC Question 13 - Part II, pages 70 and 71 o Note that "13.0" no longer has subsections "D" or "E".
recognized when Section 13.0 was subdivided and th TVA will correct the error.
0 0
is section was added a a esult of an issue identified originally at Sequoyah. It was identifi t at the Technical Specific tio s allowed the closure of Pressurizer Block valves as an interim solufo *fa Pressuri ~er Power Operated Relief Valve (PORV) was leaking. As discussed in the echnical Spe "fication 3.4.11 Bases, this is acceptable for design basis accidents since the RORVs are ot credited for immediate operation. The operators would have time to open the blocK a es *f th PORV operation was imminent. However, it was identified that certain fires had the apabili to damage the cables to the block valve that corresponds to the PORV credited for that ire. In order to prevent this occurrence, fire watches are established in accordance with the table .
0 Justify not including the second Unit 1 block valve in the table, or correct the table.
Response: The second Unit 1 block valve cabling does not transverse rooms for which the corresponding PORV is credited .
July11 , 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR D Justify continued operation of a unit with both block valves inoperable, or modify this section.
Response: PORV Operability is determined in accordance with Technical Specification (TS) 3.4.11. The TS states that separate condition entry is allowed for each PORV. If two block valves are inoperable, TS 3.4.11 .F and 3.4.11 .G direct the restoration of block valves or require a shutdown. As discussed in TS Bases 3.4.11 , closing a block valve due to a leaking PORV does not cause the block valve or PORV to be declared inoperable. Plant operation with inoperable block valves is governed by the Technical Specifications. This section of the FPR is addressing a condition of closed but operable block valves; therefore, no change to the FPR is warranted .
NRC Question 15- Part II. page 80; D Justify the deletion of 14.1.d.
Response: The Containment Purge Filter Units required safety related equipment and the corresponding fire d~tect:iQri n g* T<<><::Tgn during refueling outages when the purge equipment was not se Amendment 92, the Containment Purge equipment was re ve from the safety ana the detectors are now tested during plant operation in accordanee uirement (TIR) 14.1.b.
NRC Question 16 - Part II. page 103; D
D Response: The insp ctions of fi e ampers are performed in accordance with Fire Operating Requirement instrustion 0-FOR 30fl-3, "Fire Damper (Internal) Visual Inspection-Auxiliary, Control and Diesel Ge er or Buil ing". This is similar to the other requirements of the FPR Part II Testing and Inspection Requirements (TIRs) which are implemented in Fire Operating Requirement instructions.
NRC Question 18 - Part II. pages 138 to 141; D For, B.14.1O.o-r TVA should plan to explain these additions.
Response: These requirements and their Bases were added due to modifications performed to support Multiple Spurious Operation (MSO) scenarios. The modifications were performed to July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR replace operator manual actions with control room operator actions. They have been added for both Unit 1 and Unit 2.
NRC Question 19- Part Ill. page 5; Section 3.2, "Initial Assumptions, " includes the assumption that a plant fire could cause a trip resulting in T=O. The operator manual action analysis, in Part V and elsewhere, assumes that operators will have time to return to the control room before the plant trip.
D Provide a technical justification which demonstrates that this change to initial assumptions, that is assuming a fire can cause a plant trip, is considered in the r manual action analysis for recall of auxiliary unit operators (AUOs) to the main ~"'""'rrr"\ vr.nn*'YI Response: A preliminary version of FPR Part V, Sectio ining the requested information was provided in response to RAI question
- ed in TVA letter dated September 30, 2011 {T02 110930 001 ). The final Section 2.2.2 as shown below will be submitted in the August 15 2.2.2 There e o differences
- the act1 s or timing re uirements following t=O for the two scenarios.
This is beca se a fire that gm s to tti p int of causing damage that results in an automatic reactor trip "II ave been ass ssed by plant personnel prior to the trip as a challenging fire with the potential to a age structur-es systems, or components necessary for safe shutdown. It is not credible for a *re to rapidly ev lop and trip the reactor before the control room is aware of and in the process of a essing th fire. The rooms which contain equipment capable of tripping the reactor do not hav h1g cone ntrations of combustible material and thus a rapidly developing fire would not be credible. urt ermore, a fire directly on a component capable of tripping the reactor has a very low probability of developing into a fire that could challenge the safe shutdown capability since this type of equipment is contained within cabinets and would not be expected to affect other nearby components (i.e., would not result in spurious operations or loss of control).
Because multiple concurrent reactor protection system (RPS) logic inputs are necessary to initiate an automatic reactor trip, a fire induced automatic reactor trip is not the first observed circuit failure resulting from the fire. For this to occur, a fire has to develop to the point that multiple cables located in redundant, physically separated raceways are affected. The decision to trip the reactor manually is reached prior to or about the same time as the level of fire damage required to cause an automatic reactor trip. During this evaluation time, the July 11 , 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR control room would recall the personnel for performing the actions outside the control room and they would be dispatched if necessary by the post fire safe shutdown procedures.
Fire locations subject to high energy rapidly developing fires (e.g . electrical board rooms and transformer rooms) do not contain cables or equipment whose failure may initiate an automatic reactor trip. The control room is alerted of a fire in its early stages either by the fire detection system or as a result of visual observation by plant personnel. The operator's initial response is described above.
The time requirements for completion of operator manual actions are based on defining the initiating timet= 0 as the time when the reactor is tripped. This definition of the analytical t
= 0 is appropriate because the operator manual actions are re uire to stabilize the plant or maintain it in a stable condition after reactor trip. The opera or manual actions are not required to maintain the operating status of plant equipment prior to trip ing the reactor because the reactor is considered to be in a stable operating condition pnor to re ctor trip. Once a trip is initiated, either automatically or manually, the preve t1ve OMAs are armed to prevent spurious equipment operation and to ensure safe sh tdown can be accomplished. Since the actions are preventive rather than reactive , they ar performed per proc dur:e rather than using process instrumentation or other indication to d1a ose a need for the act1o .
1.
2.
0 nalysis volumes based on a non-physical Response: Analy is olumes (I}.V) 076 and 076A are for the same physical location (i.e ., not a result of a physical arri rs) but the two AV numbers are used to represent different power source conditions in ac r a ce w1th 10 CFR 50 Appendix R Section III.L.3. Analysis volumes 076 and 076A are both for: a postulated fire in the control building which is an alternative or dedicated shutdown area. T.h only difference between the two analysis volumes is the electrical power source. Analysis volume 076A assumes that electrical power for the control building is available from the power grid (offsite) while analysis volume 076 assumes that the offsite power source is lost and safe shutdown is achieved using only electrical power that is available onsite (emergency diesel generators, batteries , and inverters).
o How is this addressed in the description of analysis volume partitioning?
July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR Response: As discussed above, there is no physical barrier/partitioning involved in Analysis Volume 076 versus 076A but is instead a difference in the assumptions regarding onsite versus offsite power.
NRC Question 21 -Part Ill, page 87; o Provide a justification for the deletion of fire area 57 I AV-085 .
Response: Fire Area 57 (AV-085) is the Additional Diesel Generator Building which is not required for fire safe shutdown, does not impact fire safe shutdown and contains no fire safe shutdown equipment; therefore, it has been deleted from the analysis and the report for clarity.
NRC Question 22- Part Ill, diagrams; 0 The NRC reviewers could not determine whether there ere any, changes made to these diagrams. TVA should discuss this at the public meetmg.
0 0
Response: The two new diesel generators are located on the Auxiliary Building roof in two new rooms (786.0-A5 and 786.0-A6). These rooms are separated from adjacent Auxiliary Building rooms by 3-hour fire rated barriers. Each room is provided with automatic suppression and detection. The new diesel generators are provided for response to beyond design basis events (Fukushima scenarios) and are not required for fire safe shutdown nor do they impact fire safe July 11, 2014
Discussion topics/RAis for the public meeting with TVA regarding changes to selected sections of the WBN FPR shutdown. Further details of the installation will be included in the August 15, 2014 submittal of FPR Part VI.
July 11, 2014
PKG ML14209A882 Meeting Notice: ML141928314 Meetmg_ 5 ummary: ML14209A863 OFFICE DORL/LPWB/PMiT DORLILPWB/PM DORL!LPWB/LA DORLILPWB/BC DORL/LPWB/PM NAME AMinarik JPoole BCiayton JQuichocho JPoole DATE 8/26/14 8/19/14 8/19/14 8/26/14 8/27/14