CNL-14-159, Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk
| ML14239A325 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/26/2014 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-14-159 | |
| Download: ML14239A325 (5) | |
Text
L44 140826 001 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-159 August 26, 2014 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)
- 3. Letter from TVA to NRC. "Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk," dated November 22, 2013 (ADAMS Accession No. ML13333A169)
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 BFN
U.S. Nuclear Regulatory Commission Page 2 August 26, 2014 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 (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.
Commitment 4 in both the References 1 and 2 letters, as modified by letter dated November 22, 2013 (Reference 3), 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, and FA 25-01 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."
Commitment 14 in both the References 1 and 2 letters stated:
"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."
This letter informs the NRC, as required by Commitment 19 of the Reference 2 letter, that that the above commitments will be modified as follows:
Commitment 4:
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 16 (except for Main Control Room and Cable Spreading Room), FA 20, FA 21, and FA 25-01 (South Section of Elevation 550 only) until the modifications described for the listed FAs in Attachment S, Table S-2, "Plant
U.S. Nuclear Regulatory Commission Page 3 August 26, 2014 Modifications Committed," of the enclosure to this letter are installed.
Transient combustibles will be controlled as follows:
- a. "In-Use" transient combustibles are acceptable without further evaluation; however, transient combustibles cannot be staged or stored in these higher risk areas unless:
- 1) a transient combustible evaluation is performed,
- 2) the transient combustibles are staged/stored in a closed metal container (e.g., cabinets, tool boxes, gang boxes, metal drums), or
- 3) the transient combustibles are continuously attended.
- b. Transient combustible evaluations for staged/stored transient combustibles will be tracked 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).
Commitment 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 (North Section of Elevation 550 only) as transient combustible-free areas, perform once-per-shift walkdowns to ensure that transient combustible controls are satisfied, 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.
The change to plant procedures revising the control of transient combustibles and limiting the affected portion of FA 25-01 described above will be implemented no earlier than 30 days from the date of this letter.
TVA has performed reviews against the current licensing basis and determined that this commitment change is acceptable and does not adversely affect the ability of the plant to safely shutdown in the event of a fire.
TVA and BFN have used the definition of "In-Use" successfully in the past by reinforcing the expectation that the craft only take what is necessary for the job and taking out what is not consumed. The "In-Use" combustibles (e.g., items similar to tubing, foreign material exclusion (FME) covers, radiation protection barricades) may be left unattended, provided they are supporting current work activities and will be removed when the associated work activities are complete. This approach does not create an unnecessary step of evaluating insignificant combustibles for day-to-day work activities. These items do not present a significant transient combustible risk.
U.S. Nuclear Regulatory Commission Page4 August 26, 2014 Metal containers have been used successfully in the past for storage/staging of smaller combustible items. Based on industry operating experience, transient combustibles stored in a metal container do not contribute to the fire loading of an area.
If the transient combustibles do not meet the definition of "In-Use" and cannot be stored in a closed metal container, then a transient combustible evaluation must be completed or the transient combustible must be attended at all times. These requirements ensure that the fire protection features and margins are preserved and the staged or stored transient combustibles are tracked appropriately.
Commitments 4 and 14 are revised to separate the requirements for high risk fire areas from those for transient combustible-free areas. Commitment 4 currently includes those fire areas designated as transient combustible free in Commitment 14. The modified Commitment 4 applies only to high risk fire areas. The modified Commitment 14 applies only to transient combustible-free areas. Because the requirements of Commitment 4 required performance of once-per-shift walkdowns to ensure that transient combustible controls are satisfied for transient combustible-free areas, as well as high risk fire areas, Commitment 14 is revised to require performance of once-per-shift walkdowns; thus maintaining this requirement for transient combustible-free areas.
The transient combustible-free requirements in FA 25-01 locations other than the North Section of Elevation 550' are relaxed by the changes to Commitments 4 and 14 described in this letter. The North Section of Elevation 550' of FA 25-01 [Intake Pumping Station],
contains cabling and equipment for all Residual Heat Removal Service Water (RHRSW) and Emergency Equipment Cooling Water (EECW) pumps. This equipment is essential for fire safe shutdown. The North Section of Elevation 550' of FA 25-01 is the only section of the Fire Area where all RHRSW and EECW equipment is together. One division is protected with a qualified 1-hour fire wrap and automatic detection and suppression while the second division is exposed and only protected by automatic suppression and detection. Therefore, the North Section of Elevation 550' of FA 25-01 is the only section of FA 25-01 that should be designated as a transient combustible-free area. Relaxing the transient combustible-free requirements in the South Section of Elevation 550' of FA 25-01 eliminates unnecessary transient combustible watches. The requirements of high risk fire areas (i.e.,
Commitment 4) are still required to be followed for all work activities in the South Section of Elevation 550' of FA 25-01. Elevation 565' of FA 25-01 is open to the atmosphere with no safe shutdown equipment directly above this elevation; therefore, the risk associated with a transient combustible fire is minimal. Thus this portion of FA 25-01 has been removed from the controls,of both Commitment 4 and Commitment 14.
Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.
ice President, Nuclear Licensing
U.S. Nuclear Regulatory Commission Page 5 August 26, 2014 cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health