CNL-16-107, Revision to NFPA 805 Interim Compensatory Measures Commitments Regarding Fire Watches and Voluntary Commitment to Notify NRC of Commitment Revisions

Revision to NFPA 805 Interim Compensatory Measures Commitments Regarding Fire Watches and Voluntary Commitment to Notify NRC of Commitment Revisions

ML16190A242
Person / Time
Site:	Browns Ferry
Issue date:	07/07/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF1185, CAC MF1186, CAC MF1187, CNL-16-107
Download: ML16190A242 (7)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-107 July 7, 2016 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:

Revision to NFPA 805 Interim Compensatory Measures Commitments Regarding Fire Watches and Voluntary Commitment to Notify NRC of Commitment Revisions

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-14-140, "Change in Commitment Related to Interim Compensatory Measures to Reduce Fire Risk, dated August 14, 2014 (ML14231A961)

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 CFR50.48(c) (CAC Nos. MF1185, MF1186, and MF1187), dated October 28, 2015 (ML15212A796)

5. Letter from TVA to NRC, CNL-16-059, Revision to NFPA 805 Interim Compensatory Measures Commitments Regarding Hot Work and Combustible Controls dated May 10, 2016 (ML16133A581)

U.S. Nuclear Regulatory Commission CNL-16-107 Page 2 July 7, 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. In an attachment to the Reference 1 letter, TVA identified a list of 18 new regulatory commitments to address fire risk in certain fire areas.

By letter dated May 16, 2013 (Reference 2), TVA added Commitment 19 to the previous list of regulatory commitments that required TVA to inform the NRC 30 days prior to revising the listed commitments.

In a subsequent letter dated August 14, 2014 (Reference 3), TVA provided notification to NRC of a revision to Commitment 3 regarding hourly fire watches in certain fire areas.

Commitment 3, last updated in Reference 3, stated:

"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.

This letter informs the NRC that TVA is revising Commitment 3 as follows.

[TVA will maintain the existing hourly fire watches in Fire Areas 4 through 15, 18, 19, 22, 23, and 24. TVA will maintain shiftly patrols (based on 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) in Fire Areas 1-1, 1-2, 1-3, 1-4, 1-5, 2-1, 2-2, 2-3, 2-4, 2-5, 3-1, 3-2, 3-3, 3-4, 20, 21, and 25-1. FA 16 is covered by Commitment 13. In Fire Area 26, TVA will maintain a shiftly patrol except for an hourly fire watch in areas where risk significant fire scenarios exist. Fire Areas 1-6, 2-6, 17, 25-2, and 25-3 no longer require compensatory measures. Fire Areas not previously defined before the transition to the NFPA 805 licensing basis do not require additional compensatory measures. 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.]

The bases for revising Commitment 3 are as follows. The required changes to the Fire Protection Program for the transition to the BFN NFPA 805 licensing basis was approved by NRC in the Safety Evaluation (SE) issued October 28, 2015 (Reference 4). The transition license conditions included the development of new procedures and processes to evaluate changes to the Fire Protection Program. Those procedures have been developed and implemented.

U.S. Nuclear Regulatory Commission CNL-16-107 Page 3 July 7, 2016 These procedures were applied in evaluating the interim compensatory measures previously specified in Commitment 3, and resulted in more appropriate compensatory measures for certain fire areas being identified. These revised compensatory measures in each fire area affected are based on a review of relevant modifications (if any) for fire risk, the status of those modifications, the presence of existing fire protection features (such as detection and automatic suppression), the presence of risk significant fire scenarios, and the establishment of newly-issued and upgraded administrative controls (such as for transient combustibles, ignition sources, and housekeeping) put in place as part of the transition to the NFPA 805 licensing basis.

As a result, hourly fire watches in some fire areas can be reduced to shiftly patrols (based on 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts). In other fire areas, no modifications for those areas remain to be completed, and a sensitivity study demonstrated that the large-scope modifications (such as Emergency High Pressure Makeup) do not significantly impact fire risk in those areas, and fire watches are thus no longer necessary.

Further, Commitment 3 originally required the continuation of compensatory measures addressing Appendix R deficiencies in existing fire areas. The NFPA 805 analytical bases identified new fire areas and revised others, and these were also evaluated to determine appropriate compensatory measures. In these additional or revised fire areas, fire watches are not deemed appropriate or necessary based on relevant modifications, the status of the modifications, existing fire protection features, risk significant fire scenarios, upgraded administrative controls, and existing routine inspections or operator rounds.

The changes to each compensatory measure in each fire area affected by Commitment 3 were evaluated in detail and dispositioned utilizing the NFPA 805 Fire Protection Program Change Evaluation (FPPCE) process established by new procedures issued in support of the transition to the NFPA 805 licensing basis. As required by procedure, this change evaluation included a review of NFPA 805 Chapter 3 impacts, qualitative risk evaluations, and Defense-in-Depth and Safety Margin evaluations. The resulting FPPCE was approved by the BFN Fire Protection Review Board.

In addition, Commitment 19 (Reference 2) stated: TVA will inform the NRC 30 days prior to discontinuing each of the interim compensatory measures identified in Commitments 3 through 18, above. TVA is revising this commitment to state: [Commitment completed and superseded by the transition to the NFPA 805 licensing basis].

The change to Commitment 19 is consistent with recent conversations between TVA and NRC concerning the applicability and necessity of Commitment 19 following the issuance of the SE (Reference 4) and BFNs transition to the NFPA 805 licensing basis. The issuance of the NFPA 805 programs and procedures required by the transition license conditions, coupled with TVAs existing commitment management program, obviates the need to notify NRC of changes to the interim compensatory measures identified in Commitments 3 through 18 and wait 30 days before implementing any changes, unless the application of the BFN FPPCE or commitment management process procedure and checklist identifies a requirement to notify NRC of the change. Thus, Commitment 19 is no longer necessary to provide early notification of changes to these commitments.

U.S. Nuclear Regulatory Commission CNL-16-107 Page 4 July 7, 2016 Therefore, TVA is informing the NRC that Commitment 3 has been revised, and that Commitment 19 has been completed and superseded, each in accordance with the BFN License Conditions required by Reference 4.

The revised List of Regulatory Commitments is provided in the enclosure to this letter. The changes provided in this enclosure are indicated by a revision bar to the right of the change.

The enclosure provides a complete updated commitment list that supersedes the previous commitment list provided in the Reference 5 letter. Please address any questions regarding this submittal to Edward D. Schrull at (423) 751-3850.

Resp tfullyL

Enclosure:

NFPA 805 List of Regulatory Commitments 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

CNL-16-107 Enclosure Page 1 of 3 Enclosure Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 NFPA 805 List of Regulatory Commitments Revision 4 This Enclosure provides the NFPA 805 updated List of Regulatory Commitments with the revised commitment change(s) identified in this letter indicated by a revision bar to the right of the revised commitment. The updated List of Regulatory Commitments provided in this Enclosure supersedes any previous BFN NFPA 805 List of Regulatory Commitments. Note that where a Regulatory Commitment refers to Attachment S, Table S-2, Plant Modifications Committed, of the enclosure to this letter, the attachment was included in the Letter from TVA to NRC, CNL-15-191, "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) - Revised Safe Shutdown Analysis Request for Additional Information 15, dated September 8, 2015.

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 in Fire Areas 4 through 15, 18, 19, 22, 23, and 24. TVA will maintain shiftly patrols (based on 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) in Fire Areas 1-1, 1-2, 1-3, 1-4, 1-5, 2-1, 2-2, 2-3, 2-4, 2-5, 3-1, 3-2, 3-3, 3-4, 20, 21, and 25-1. FA 16 is covered by Commitment 13. In Fire Area 26, TVA will maintain a shiftly patrol except for an hourly fire watch in areas where risk significant fire scenarios exist. Fire Areas 1-6, 2-6, 17, 25-2, and 25-3 no longer require compensatory measures. Fire Areas not previously defined before the transition to the NFPA 805 licensing basis not require additional compensatory measures 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. Commitment completed and superseded by the implementation of Table S-3, Item 45.

5. Commitment completed and superseded by the implementation of Table S-3, Item 45.

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.

CNL-16-107 Enclosure Page 2 of 3

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.

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.

TVA 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.

CNL-16-107 Enclosure Page 3 of 3

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. Commitment completed and superseded by the implementation of Table S-3, Item 45.

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, II 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.

TVA 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. [Commitment completed and superseded by the transition to the NFPA 805 licensing basis].