ML18033B661

Forwards Request for Addl Info Re Plant Fire Protection Program,Based on Review of Util 880404 Submittal

ML18033B661
Person / Time
Site:	Browns Ferry
Issue date:	03/18/1991
From:	Williams J Office of Nuclear Reactor Regulation
To:	Nauman D TENNESSEE VALLEY AUTHORITY
References
NUDOCS 9103210431
Download: ML18033B661 (11)

Text

March 18, 1991 Docket Nos. 50-259, 50-260 and 50-296 Mr. Dan A. Nauman Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE BROWNS FERRY NUCLEAR PLANT FIRE PROTECTION PROGRAM The Plant Systems Branch, Division of Systems Technology, is reviewing the April 4, 1988 submittal by the Tennessee Valley Authority (TVA) regarding the fire protection program at the Browns Ferry Nuclear Plant (BFNP) Units 1, 2, and 3.

The staff recently completed review of the licensee's 10 CFR 50 Appendix R fire protection program for BFNP Unit 2.

The staff's current review focuses on other aspects of the BFNP fire protection program.

Further review of your April 4, 1988 request requires additional information described in the I

enclosure to this letter.

We will continue our review after receiving your response to this request.

Please contact me at (301) 492-1479 if you have any questions regarding this request.

Original signed by Joseph F. Williams, Project Manager Project Directorate II-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

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Mr. Marvin Runyon, Chairman Tennessee Valley Authority ET 12A 7A 400 West Surrmit Hill Drive Knoxville, Tennessee 37902 Mr. Edward G. Wallace

Manager, Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 5N 157B Lookout Place Chattanooga, Tennessee 37402-2801 Mr. John B. Waters, Director Tennessee Valley Authority ET 12A 9A 400 West Summi t Hi 1 1 Driv e Knoxville, Tennessee 37902 Mr. Oliver D. Kingsley, Jr.

President, Generating Group Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 General Counsel Tennessee Valley Authority 400 West Summit Hill Drive ET 11B 33H Knoxville, Tennessee 37902 h1r. Dwight Nunn Vice President, Nuclear Projects Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Dr. Mark 0. Medford Vice President, Nuclear Assurance, Licensing and Fuels Tennessee Valley Authority 6N 38A Lookout Place Chattanooga, Tennessee 37402-2801 Mr. 0. J. Zeringue, Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, Alabama 35602 Mr. P. Carier, Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, Alabama 35602 Mr. L.

W. Myers, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, Alabama 35602

Chairman, Limestone County Commission P. 0.

Box 188

Athens, Alabama 35611 Claude Earl Fox, M.D.

State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, Alabama 36130 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Mar ietta Street, N.W.

Atlanta, Georgia 30323 Mr. Charles Patterson Senior Resident Inspector Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Commission Route 12, Box 637

Athens, Alabama 35611 Tennessee Valley Authority Roc kvi 1 1 e Offi ce 11921 Rockville Pike Suite 402 Rockvi 1 1 e, Maryland 20852

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 ENCLOSURE RE VEST FOR ADDITIONAL INFORMATION RELATED TO THE FIRE PROTECTION PROGRAM FOR BROWNS FERRY NUCLEAR PLANT UNIT NOS.

1 2

AND 3 DOCKET NOS.

50-259 50-260 AND 50-296 A.

Introduction By letter of April 4, 1988, Tennessee Valley Authority (TVA), the, licensee, requested NRC review and approval of the fire protection program (FPP) for Browns Ferry Nuclear Plant (BFNP).

The licensee's request was made as a

preliminary step in implementing the guidance of Generic Letter 86-10, "Imple-mentation of Fire Protection Requirements."

Additionally, the licensee's submittal satisfied certain commitments that were made in the Nuclear Perfor-mance Plan (NPP) for BFNP.

TVA had revised its NPP in order to address concerns that were expressed by senior NRC managers regarding poor performance by TVA.

The staff recently completed its review of the FPP for BFNP Unit No.

2 (BFNP-2) related to 10 CFR 50 Appendix R requirements (NRC letters of October 21, December 8 and December 14, 1988; August 1, September 15, November 3 and November 30, 1989).

Currently, the staff is reviewing other aspects of the FPP for BFNP not related to 10 CFR 50 Appendix R in order to fully address the licensee's request of April 4, 1988.

B.

Re uest for Additional Information The staff has completed a preliminary review of the licensee's request of April 4, 1988, and based on that review the staff has identified the following comments and questions for consideration.

The licensee is requested to revise its submittal accordingly.

1.

The licensee is requested to identify specifically how the proposed FPP (including commitments) differs from the FPP that was previously approved by the NRC (including previous commitments).

Specifically, identify in what way program requirements have been strengthened and in what way they have been relaxed.

2.

The following information should be included in (and made a part of) the FPP:

a.

Information and commitments contained in the NPP related to fire protection.

b.

The licensee's comparison of the FPP to NRC Branch Technical Position CMEB 9.5-1.

c.

The fire protection upgrade

program, including completion schedule.

3.

d.

A complete list of FPP commitments, including commitments to industry standards and any exceptions being taken to those standards.

The staff has completed its review of the licensee's FPP related to 10 CFR 50 Appendix R requirements as previously discussed.

TVA is requested to revise its FPP accordingly to reflect the staff's approved program in this

regard, paying particular attention in documenting the basis for the staff's approval and assuring that all conditions are properly recognized and complied with.

4.

The staff has completed its review related to National Fire Protection Association (NFPA) Code deviations for BFNP (NRC letters of December 14, 1988; June 6, November 3 and November 30, 1989).

TVA is requested to revise its FPP accordingly to reflect the approved methodology for implementing NFPA Code requirements, paying particular attention in documenting the basis for the staff's approval and assuring that all conditions are properly recognized and complied with.

5.

TVA's plan for implementing an onsite fire department should be included in the FPP.

6.

The licensee's NPP states that Nuclear Power's Nuclear Support (NS) organization will complete a broad review of BFNP fire protection.

TVA is requested to submit the results of the NS review for staff consideration.

7.

The licensee's NPP states that plans will be developed for achievinq compliance with the NFPA Code and with NRC's Branch Technical Position (BTP)

CMEB 9.5-1.

The licensee further states that schedules will be developed for planned modifications.

a.

Cur rent ly, the 1 icensee upgrade program does not list implementation dates for Level 3, Level 4 and Level 5 projects.

TVA is requested to comply with its commitment and provide specific imp'lementation schedules for all remaining projects.

b.

The licensee's comparison of the FPP for BFNP to the NRC BTP CMEB 9.5-1 does not adequately address many of the elements of the BTP (see Comment No.

9 below).

TVA is requested to revise its comparison accordingly.

For each element of the BTP:

state specifically whether the element is being implemented or not, any exceptions should include technical justification; state how the element is being implemented by the FPP and make reference to applicable sections of the Fire Protection Plan or other implementing documents; make reference to the upgrade projects as applicable.

8.

The licensee's evaluation of previous commitments does not provide enough detail.

For all previous commitments that are not being implemented in accordance with the originally established schedules identify the original commitment, along with technical justification for delaying implementation, or for not implementing the commitment, making reference to documentation and upgrade projects as applicable.

Any relaxation of previous commitments must be adequately justified.

9.

Additional comments, specifically related to the licensee's comparison of the FPP for BFNP to NRC BTP CHEB 9.5-1, are included in Table 1.

These comments are based on the staff's preliminary review of the licensee's submittal and are not all inclusive.

However, the comments should help TYA efforts in addressing the elements of NRC BTP CMEB 9.5-1 (see Comment No. 7.b above).

10.

The definition section of the Fire Protection Plan for the Browns Ferry Nuclear Plant states a definition for "Emergency

Response

Organization."

In order to avoid confusion with multiple uses of this term, it may be more appropiate to use the term "Fire Emergency

Response

Organization".

11.

TVA is requested to review its program for satisfying 10 CFR 50 Appendix R

requirements, as approved by the NRC staff, and assure that surveillance requirements have been established as appropriate.

TVA is also requested to review all conditions and commitments relative to the upgrade

program, implementation of NFPA Code requirements and implementation of BTP CHEB 9.5-1 and assure that surveillance requirements have been established as appropriate.

12.

In order to implement a revised FPP at BFNP, a change to the existing fire protection license conditions will be required.

TVA should request amendments to the BFNP operating licenses accordingly.

TABLE 1 STAFF COMMENTS RELATED TO TVA's COMPARISON OF THE FPP FOR BFNP TO BTP CMEB 9.5-1 BTP ELEMENT STAFF COMMENTS C.l. a C.l.a(1)

C.l.a(2)

C.l.a(3)(a)8(b)

C.l.a(4)

C.l.a(4)(b)

C.l.a(4)(c)

No discussion relative to procedures, equipment, or personnel required to implement the program.

TVA response does not address element.

Describe how these objectives are being met by the FPP.

How are these addressed by the FPP?

Where is the organization chart as it relates to the FPP?

Implementation is not listed under the responsibility of DNS in the Fire Protection Plan.

What offsite management positions are responsible for the functions listed?

How are assessment results and recommendations communi-cated to the Manager of NP?

TVA's response is not reflected in the Fire Protection Plan.

In general, the responsibilities and authorities of the onsite and offsite management positions have not been well defined.

What is the hierarchy of authority and responsibility for these positions and how does authority and responsibility transition from the offsite to the onsite management positions?

How do these management positions assure proper development and implementation of the FPP?

How do these management positions monitor performance of the FPP and assure that appropriate corrective actions are being taken to correct weaknesses and deficiencies?

C.l.a(4)(d) (1)

How is prompt and effective corrective action assured?

TABLE I (cont. )

STAFF COMMENTS RELATED TO TVA's COMPARISON OF THE FPP FOR BFNP TO BTP CMEB 9.5-1 ELEMENT C.l.a(4)(d)( iv)

C.l.a(4) (e)

C.I.a(4)(f)

C.I.a(4) (f)

(i)-(v)

C.I.a(5)(a)

C.I.a(5) (b)

C.l.a(7)

C.1.c(2)

C.2.a C.2. h C.2.j C.2. k COMMENTS Section 3.4 of the Fire Protection Plan states that the Fire Protection Section is responsible for this activity.

What are the specific responsibilities of the site gA department relative to fire protection?

Section 3.4 of the Fire Protection Plan states that the Fire Protection Section is responsible for responding to fire emergencies.

How does this fit in with the fire brigade?

These elements are not addressed by the Fire Protection Plan.

TYA's response is not consistent with the response provided for element C.l.a(4)(b).

How often is the medical exam performed?

Is the exam performed by a medical doctor?

TVA's response does not address the element.

What is the technical basis for not evaluating for cracks in moderate energy lines?

Is Regulatory Guide 1.39 adhered to?

State any exceptions and justification.

How is corrective action assured?

How is this activity controlled?

Is there a

procedure?

TVA's response does not address maintenance requirements.

TABLE I (cont.)

STAFF COMMENTS RELATED TO TVA's COMPARISON OF THE FPP FOR BFNP TO BTP CMEB 9.5-1 BTP ELEMENT C.3 STAFF COMMENTS Elements associated with the fire brigade have not been adequately defined within TVA's FPP.

Where have the applicable program requirements been established?

Is there a

seperate fire brigade for each unit? Where does the Fire Protection Section fit into this scheme?

C.3.d(5)

C.3.d(6)(a)

C.3.d(7)(e)

C.5.a(3)

C.5.a(4)

C.5.a(5)

C.5.d(4)

C.5.d(5)

C.e.a(e)

C.7.a(2)

Is classroom instruction repeated at least every two years?

Does practice session require each fire brigade member to actually participate in extinguishing a fire and use of an emergency breathing appar atus?

What are the specific qualification requirements?

TYA's response does not address differential pressure requirements for seals and "qualification by test" requirement for conduits.

TVA's response does not address combustible coup lings.

TYA has not provided a technical basis for not making corrections to the diesel generator doors.

Does the brigade leader have ready access to all locked doors?

Is NFPA 30 complied with?

State specific exceptions and justification.

Why is this acceptable?

TVA's response does not address control valves.

Why are no self contained breathing apparatus stored in the containment area elevator-stairwell on Unit 2 for emergency use (simi lar to what is done on Unit No.1 and Unit No.3)?