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First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident.
	ML14353A428
Person / Time
Site:	Browns Ferry
Issue date:	12/19/2014
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-14-222, EA-13-109
	Download: ML14353A428 (7)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-222 December 19, 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:

Tennessee Valley Authority's Browns Ferry Nuclear Plant First Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

References:

1. NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013 (ML13143A334)

2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (ML133048836)

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-1 09 BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (ML13316A853)

4. Letter from TVA to NRC, "Tennessee Valley Authority's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident (Order Number EA-13-109)," dated June 30, 2014 (ML14181B169)

U.S. Nuclear Regulatory Commission CNL-14-222 Page 2 December 19, 2014 On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Tennessee Valley Authority (TVA) . Reference 1 was immediately effective and directs TVA to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reacto r vessel by molten core debris.

Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of a phase 1 overall integrated plan pursuant to Section IV, Condition D. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 13-02 , Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the TVA overall integrated plan (OIP) for Browns Ferry Nuclear Plant (BFN) , Units 1, 2, and 3.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan . Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition D of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The Enclosure provides an update of milestone accomplishments since subm ittal of the BFN OIP , including any changes to the compliance method , schedule , or need for relief and the basis , if any .

There are no new regulatory commitments resulting from this submittal. Should you have any questions concerning the content of this letter, please contact Kevin Casey at (423) 751-8523 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day December 2014.

Respe tf ly,

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Pt esident , Nuclear Licensing E closure: Tennessee Valley Authority Browns Ferry Nuclear Plant's First Six-Month Status Report for the Implementation of Order EA 109 , "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc (Enclosure):

NRR Director- NRC Headquarters NRO Director - NRC Headquarters NRR JLD Director- NRC Headquarters NRC Regional Administrator- Region II NRR Project Manager- Browns Ferry Nuclear Plant NRR JLD Project Manager- Browns Ferry Nuclear Plant NRC Senior Resident Inspector- Browns Ferry Nuclear Plant

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT'S FIRST SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-13-109, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS" Introduction Browns Ferry Nuclear Plant (BFN) developed an Overall Integrated Plan (OIP) (Reference 5 of this Enclosure) , documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 1. This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments The following milestone has been completed since the development of the OIP (Reference 5) ,

and is current as of December 05, 2014 for the first status report.

A conceptual design meeting was held on November 14, 2014 to implement phase 1 of the order for all three units at Browns Ferry.

Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan . It provides the activity status of each item, and whether the expected completion date has changed . The dates are planning dates subject to change as design and implementation details are developed .

There are currently no revised milestone target completion dates.

Activity Status updates are shown in bold type .

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Revised Target Activity Target Milestone Completion Status Completion Date Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates:

Update 1 Dec 2014 Complete Update 2 Jun 2015 Not Started Update 3 [Simultaneous with Phase 2 OIP] Dec 2015 Not Started Update 4 Jun 2016 Not Started Update 5 Dec 2016 Not Started Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Modifications:

Hold preliminary/conceptual design meeting Nov 2014 Complete Unit 1 Design Engineering On-site/Complete Jan 2016 Not Started Unit 1 Implementation Outage Nov 2016 Not Started Unit 1 Walk Through Demonstration/Functional Nov 2016 Not Started Test Unit 2 Design Engineering On-site/Complete Jun 2016 Not Started Unit 2 Walk Through Demonstration/Functional Apr 2017 Not Started Test Unit 2 Implementation Outage Mar 2017 Not Started Unit 3 Design Engineering On-site/Complete Jul2017 Not Started Unit 3 Walk Through Demonstration/Functional Apr 2018 Not Started Test Unit 3 Implementation Outage Mar 2018 Not Started Procedure Changes Active Not Started Operations Procedure Changes Developed Jul2016 Not Started Site Specific Maintenance Procedure Developed Jul2016 Not Started Procedure Changes Active Nov 2016 Not Started Page E2 of 5

Revised Target Activity Target Milestone Completion Status Completion Date Date Phase 1 HCVS Milestone Table Training:

Training Complete Sep 2016 Not Started Completion Unit 1 HCVS Implementation Dec 2016 Not Started Unit 2 HCVS Implementation Apr 2017 Not Started Unit 3 HCVS Implementation Mar 2018 Not Started Full Site HCVS Implementation Mar 2018 Not Started Submit Completion Report [60 days after full site Jun 2018 Not Started compliance]

Changes to Compliance Method The following is a list of changes made to the information provided in the OIP submitted by Reference 5. These changes meet the NEI 13-02 compliance method .

On page 4 of 57 , the extreme cold will screen in for applicable Extreme Hazards from NEI 12-06.

On page 13 of 57 , the Vent Path and Discharge will be revised so that the effluent will be discharged at an elevated release point and the velocity and spacing of each unit will provide compliance with the Order EA-13-1 09 requirements of separation .

On page 15 of 57 , the sentence describing the motive force and cycles of operation is being changed so that the HCVS Containment Isolation Valves (CIV's) will be operable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

On page 18 of 57 , a communication system will be utilized that uses hand held radios for communication between the main control room and the remote operating station.

On page 21 of 57 , the component qualification will be revised to denote that the HCVS piping and components will be routed in a seismically qualified structure or exterior to the reactor building wall.

Currently, there are no changes to the compliance method that would be considered an alternative to NEI 13-02.

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Need for Relief/Relaxation and Basis for the Relief/Relaxation BFN expects to comply with the order implementation date and no relief/relaxation is required at this time.

Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 OIP or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status 1 Perform an assessment of temperature and radiological Open conditions to ensure that operating personnel can safely access and operate controls at the Remote Operating Station based on time constraints listed in Attachment 2.

2 Perform an evaluation for HCVS ability to operate from the Open MCR and has the abil ity to be supplied adequate amounts of pneumatic pressure for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions.

3 Perform an evaluation for FLEX portable generators and Open nitrogen cylinders use past 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions.

4 Revise 1/2/3-EOI Appendix 13 to include venting for loss of Open DC power.

5 Perform an evaluation for FLEX portable generators use for Open post 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions.

6 Electrical load shedding will be performed in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of the Closed - Calculation event. EDQ0009992013000202 Rev 1 has been issued to determine load shedding impact on the unit batteries.

7 The implementation of the HCVS DCN's will be staged so Closed - A conceptual that there is no effect on the operating units. meeting was held in November 2014 and a staging plan was used to separate the existing HWWV from the HCVS.

8 The wetwell vent will be designed to remove 1% of rated Closed - The existing wetwell thermal power at EPU conditions. vent (CLTP) and the HCVS (EPU ) has been designed for 1% of rated thermal power at EPU conditions.

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Overall Integrated Plan Phase 1 Open Item Status 9 Implement the Harris Rad io System for communication Revised - A communication between the MCR and the ROS . system will be used that uses hand held radios for communication between the main control room and the remote operating station .

Interim Staff Evaluation Open Item Status None received to date Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. NRC Order Number EA-13-1 09, "Order Modifying Licenses with Regard to Rel iable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions ,"

dated June 6, 2013 (ML13143A334)

2. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-1 09, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013

3. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (ML133048836)

4. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0", (ML14128A219)

5. Letter from TVA to NRC , "Tennessee Valley Authority's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident (Order Number EA-13-109) ," dated June 30, 2014 (ML141818169)

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