CNL-15-253, Brown Ferry, Units 1, 2, and 3 - Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk

Brown Ferry, Units 1, 2, and 3 - Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk

ML16006A124
Person / Time
Site:	Browns Ferry
Issue date:	01/05/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-15-253, TAC MF1185, TAC MF1186, TAC MF1187
Download: ML16006A124 (7)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-253 January 5, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 10 CFR 50.4 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(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 (ML13141A291)

3. Letter from TVA to NRC, CNL-15-074, "Update to 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 June 19, 2015(ML15174A149)

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

Issuance of Amendments Regarding Transition to A Risk-Informed Performance-Based Fire Protection Program In Accordance With 10 CFR 50.48(C) (CAC Nos. MF1185, MF1186, and MF1187)," dated October 28, 2015(ML15212A796)

U.S. Nuclear Regulatory Commission CNL-15-253 Page 2 January 5, 2016 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 License Amendment Request (LAR}, TVA included commitments to interim compensatory measures to reduce the 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 NFPA 805 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 any of the interim compensatory measures identified in Commitments 3 through 18. In the letter dated June 19, 2015 (Reference 3), TVA provided an updated list of regulatory commitments that superseded the previous commitment list provided in the Reference 2 letter.

Commitment 6 in the Reference 3 letter states:

"TV A 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 or when moving a filled spent fuel storage cask past the temporary diesel generators, until the modifications described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed."

This letter informs the NRC, as required by Commitment 19 of the Reference 3 letter, that Commitment 6 is no longer considered a necessary interim compensatory measure once the NFPA 805 Program Implementation has been completed (currently planned for May 23, 2016, and required by June 24, 2016 in accordance with the NRC Safety Evaluation (SE) contained in Reference 4).

The rationale for this conclusion is outlined below.

The current safe shutdown instructions (SS ls) for fire under the 10 CFR 50 Appendix R licensing basis provide a single success path to safe shutdown and involve intentionally disconnecting offsite power from the safety busses (Self-Induced Station Blackout, or SISBO}, placing significant reliance on the availability of specific Emergency Diesel Generators (EDGs) depending on the fire area involved. The new fire safe shutdown procedures (FSSs) for BFN, which are currently scheduled to be implemented by the target date of May 23, 2016, eliminate SISBO and allow for the use of any available success path to achieve a Safe and Stable condition. For example, the FSSs will allow for the use of offsite power and EDG cross-tie capabilities between units if necessary.

U.S. Nuclear Regulatory Commission CNL-15-253 Page 3 January 5, 2016 The inclusion of the temporary diesel generators (TDGs) as an interim compensatory measure was not based on risk quantification, but rather on conservative engineering judgment. The TDGs are not included in any BFN Probabilistic Risk Assessment (PRA) model.

Consistent with the Facility Operating License, Transition License Condition 2 of License Condition (13), (14), and (17) for BFN Units 1, 2, and 3, respectively, appropriate compensatory measures will remain in place until the modifications described in Attachment S to the LAR are installed.

The TDGs will continue to be available as needed during extended maintenance activities for the EDGs in compliance with Technical Specifications Section 3.8.1.B.

Therefore, after reconsideration of the importance of the TDGs, TVA has concluded that the TDGs are not needed as an interim compensatory measure for fire beyond the NFPA 805 target implementation date of May 23, 2016.

TVA has performed the appropriate reviews against the current licensing basis and determined that this commitment change is acceptable. The elimination of the commitment for this interim compensatory measure will be implemented no earlier than the target date of May 23, 2016.

The enclosure to this letter provides a complete updated NFPA 805 Regulatory Commitment List that supersedes the previous commitment list provided in the Reference 3 letter.

There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.

cy lly, tv1J<---

J W. Shea ice President, Nuclear Licensing Enclosure NFPA 805 Regulatory Commitment List, Revision 2 cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector-Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health NRC Branch Chief - Region II

ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 NFPA 805 Regulatory Commitment List Revision 2 This Enclosure provides the NFPA 805 updated List of Regulatory Commitments with the withdrawn Commitment 6 change identified in this letter indicated by a revision bar to the right of the withdrawn commitment. The updated List of Regulatory Commitments provided in this Enclosure supersedes any previous BFN NFPA 805 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. [Relocated to NFPA 805 License Amendment Request, Attachment S, Table S-3.]

3. TVA will maintain the existing hourly fire watches for all existing BFN fire areas except the following Reactor Building areas: the quads below the 565' elevation, the HPCI Room, and the torus area in each unit. These excepted locations will require once per eight hour shift roving fire watches. The fire watches will remain in place until the modifications described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

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 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).

CNL-15-253 E-1

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

TV A will implement these controls by May 31, 2013.

6. [Commitment withdrawn by TVA letter dated January 5, 2016.]

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.

CNL-15-253 E-2

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.

TV A will implement these controls by May 31, 2013.

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 1 A 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 (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.

CNL-15-253 E-3

15. TVA will implement controls to limit the unavailability of an entire EECW header (north or south) 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.

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.

TV A 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.

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.

19. TV A will inform the NRC 30 days prior to discontinuing each of the interim compensatory measures identified in Commitments 3 through 18, above.

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