ML13247A284

Browns Ferry Nuclear Plant, Units 1, 2, & 3 First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Orde

ML13247A284
Person / Time
Site:	Browns Ferry
Issue date:	08/28/2013
From:	Shea J W Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML13247A284 (11)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 August 28, 2013 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant

References:

1. NRC Order Number EA-1 2-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12054A735)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ML12229A174)

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" Revision 0, dated August 2012 (ML12242A378)

4. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) -Initial Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 29, 2012 (ML12307A104)

Printed on recycled paper U.S. Nuclear Regulatory Commission Page 2 August 28, 2013 5. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) -Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant," dated February 28, 2013 (ML13064A465)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1)to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directs TVA to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI)12-06, Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2.Reference 4 provided the TVA initial status report regarding mitigation strategies.

Reference 5 provided the TVA Browns Ferry Nuclear Plant, Units 1, 2, and 3 overall integrated plan.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 C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The enclosed report provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to the compliance method or schedule.The Enclosure describes the plans that TVA will use to meet the regulatory requirements outlined in Attachment 2 of Reference 1, but does not identify any additional actions to be taken by TVA. Therefore, this letter contains no regulatory commitments.

If you have any question regarding this submittal, please contact Kevin Casey at (423) 751-8523.I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of A gust 2013.Respe u ce President, Nuclear Licensing Enclosure cc: See Page 3 U.S. Nuclear Regulatory Commission Page 3 August 28, 2013

Enclosure:

Tennessee Valley Authority Browns Ferry Nuclear Plant's First Six Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc (Enclosure):

NRR Director -NRC Headquarters NRO Director -NRC Headquarters NRC Regional Administrator

-Region II NRC 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-12-049, ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ENCLOSURE 1 Introduction Browns Ferry Nuclear Plant (BFN) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference

2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method or schedule.2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1 in Section 8), and are current as of July 30, 2013.Unit 2 N-1 Walkdown 3 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.

The revised milestone target completion dates do not impact the order implementation date.Revised Activity Original Target Activity Target Date Status Completion Date Submit Overall Integrated Plan February 2013 Complete Submit 6 Month Updates: Update 1 August 2013 Complete Update 2 February 2014 Not Started Update 3 August 2014 Not Started Update 4 February 2015 Not Started Update 5 August 2015 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started FLEX Strategy Evaluation June 2013 On Track October 2013 Unit I -Validation of connection points for FLEX Phase 2 & 3 via November 20161 Not Started walkthrough or demonstration.(Graded approach)El -7 Revised Activity Original Target Activity Target Date Status Completion Date Unit 2 -Validation of connection points for FLEX Phase 2 & 3 via May 20151 Not Started walkthrough or demonstration.(Graded approach)Unit 3 -Validation of connection points for FLEX Phase 2 & 3 via April 20161 Not Started walkthrough or demonstration.(Graded approach)Perform Staffing Analysis October 2014 Not Started Modifications:

Modifications Evaluation June 2013 On Track October 2013 Unit 1 N-1 Walkdown October 2014 Not Started Unit 1 Design Engineering December 20141 On Track Unit 1 Implementation Outage November 2016 Not Started Unit 2 N-1 Walkdown March 2013 Complete Unit 2 Design Engineering December 20141 On Track Unit 2 Implementation Outage April 2015 Not Started May 2015 Unit 3 N-1 Walkdown February 2014 Not Started Unit 3 Design Engineering December 20141 On Track Unit 3 Implementation Outage April 2016 Not Started Storage: Storage Design Engineering March 20141 On Track Storage Implementation February 20151 Not Started FLEX Equipment:

Procure On-Site Equipment October 2013 On Track Develop Strategies with RRC December 2013 Not Started Install Off-Site Delivery Station May 20151 Not Started Procedures:

BWROG issues FSG guidelines January 2014 Not Started Create Browns Ferry FSGs March 2014 Not Started Create Maintenance Procedures June 2014 Not Started Training: Develop Training Plan January 2014 Not Started Implement Training March 2014 Not Started Unit 1 FLEX Implementation November 2016 Not Started Unit 2 FLEX Implementation April 2015 Not Started May 2015 Unit 3 FLEX Implementation April 2016 Not Started Full Site FLEX Implementation November 2016 Not Started Submit Completion Report December 2016 Not Started Notes: 1. These milestones were not included in the February 28, 2013, Overall Integrated Plan E2 -7 4 Changes to Compliance Method The following is a list of changes made to the information provided in the February 28, 2013, Overall Integrated Plan (Reference 1). These changes meet the NEI 12-06 compliance method.4.1 (Section 11, Section 14, Section 17 and Section 18, 3.b.ii, Note) was changed to read as follows: "Note: The B RHRSW inlet header can provide standby coolant to unit 2 and/or unit 3, if needed." 4.2 (Section 11, Section 14, Section 17 and Section 18, 3.b.iii, Note) was changed to read as follows: "Note: The D RHRSW inlet header can provide standby coolant to unit 1 and/or unit 2, if needed." 4.3 (Section lId Severe Storms with High Winds, Section 14d Severe Storms with High Winds, Section 20d Severe Storms with High Winds) changed to read as follows: "Portable equipment required to implement this FLEX strategy will be maintained in the FESB, which is designed to meet or exceed the licensing basis high wind hazard for BFNP, with the exception of the 480 V FLEX DGs. An extreme tornado could exceed the protection limits for more than one 480 V FLEX DG. (A beyond-design-basis tornado for BFNP would exceed 300MPH; protection for the FLEX DGs shall be designed to 230 MPH based on NRC region 1 tornado, missiles, and velocities defined in NRC Regulatory Guide 1.76 Revision 1). The 480 V FLEX DGs shall be protected from other beyond-design-basis events listed in Section 1." This change complies with the guidelines contained in Reference 3 in Section 8.4.4 (Section 13, last paragraph) changed to read as follows: "The containment vent system is not credited for Phase 1; however, modifications to the containment vent system are planned in response to NRC Order EA-1 3-109 (Ref.2). (Open Item, 01 11)" This change complies with the guidelines contained in Reference 3 in Section 8.4.5 (Section 13b) was changed to read as follows: "Hardened Containment Vent System (HCVS) (i.e., Reliable Hardened Vent) is currently installed but will be enhanced in accordance with NRC Order EA-1 3-109 (Ref. 2). (Open Item, 01 11)." This change complies with the guidelines contained in Reference 3 in Section 8.E3 -7 4.6 (Section 13 & 14 Reference Sections)

Changed reference from EA-12-050 to EA-13-109.This change reflects cancellation of NRC Order EA-12-050.

4.7 (Section 14, 2.c.i) was changed to read as follows: "DC power and pneumatic supply in accordance with NRC Order EA-13-109 (Ref. 5).(Open Item, 01 11), and" This change reflects cancellation of NRC Order EA-12-050.

4.8 (Section 14b, last bullet) changed to read as follows: "Install a Hardened Containment Vent System (HCVS) as required by NRC Order EA-1 3-109. Interim modifications may be made on Unit 2 and Unit 3 for FLEX usage, as guidance for compliance with NRC Order EA-13-109 is further developed. (Ref.5)".This change reflects cancellation of NRC Order EA-12-050.

4.9 (Section 17d, Severe Storms with High Winds) changed to read as follows: "The piping used to provide makeup flow to the SFP is contained within buildings that are protected from storms and high winds. Portable equipment required to implement this FLEX strategy will be maintained in the FESB, which is designed to meet or exceed the licensing basis high wind hazard for BFNP, with the exception of the 480 V FLEX DGs. An extreme tornado could exceed the protection limits for more than one 480 V FLEX DG. (A beyond-design-basis tornado for BFNP would exceed 300MPH; protection for the FLEX DGs shall be designed to 230 MPH based on NRC region 1 tornado, missiles, and velocities defined in NRC Regulatory Guide 1.76 Revision 1). The 480 V FLEX DGs shall be protected from other beyond-design-basis events listed in Section 1." This change complies with the guidelines contained in Reference 3 in Section 8.4.10 (Attachment 5, Open Item 11) changed to read as follows: "Design and install interim modifications to the containment vent system to support use of the system in support of FLEX strategies.

The interim modification is being performed as the industry develops guidance to comply with NRC Order EA-1 3-109.This will include modifying the HCVS system to permit controlled venting more than one unit at the same time, if necessary." This change reflects cancellation of NRC Order EA-12-050.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation TVA expects to comply with the order implementation date and no relief/relaxation is required at this time.E4 -7 6 Open Items from Overall Integrated Plan and NRC Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the NRC Evaluation and the status of each item.Overall Integrated Plan Open Item Status 01-1: Flood and seismic re-evaluations pursuant to the Not Started 10 CFR 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal.

As the re-evaluations are completed, appropriate issues will be entered into the corrective action system and addressed.

01-2: Liquefaction of haul routed for FLEX will be Not Started analyzed.01-3. TVA will confirm that they have enough fuel onsite Started for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A diesel fuel storage and refueling plan also has to be developed.

01-4: BFNP will evaluate SRV qualification against the Not started predicted containment response with FLEX implementation to ensure there will be sufficient DC bus voltage and pneumatic pressure to operate the SRVs throughout Phase 1 and Phase 2.01-5: An electrical load study will be performed to Not started ascertain the ability of the common Unit 1 & 2 chillers to be placed into service powered by the FLEX DGs that would provide chilled water for the Unit 1 & 2 Control Bay and the Unit 1 & 2 Electric Board rooms.01-6: Formalize the preliminary Battery studies that were Not started performed to ensure appropriate battery life will be available with regards to the overall FLEX strategies.

01-7: BFNP will take actions as necessary to assure Started RCIC can operate at elevated temperatures.

01-8: Perform modifications, as necessary, to ensure Not started that RCIC is seismically robust.01-9: Develop and perform the design modifications Started identified in the FLEX Strategy document to permit the timely and safe connection of the FLEX and RRC equipment during the adverse conditions encountered during these beyond design basis events.01-10: Design and construct a Flexible Equipment Started Storage Building, located above the probable maximum flood level, which meets the plant's design basis for the Safe Shutdown Earthquake and the plant's design basis for high wind hazards. This storage facility will be used to store support equipment and items, including the four FLEX Pumping Systems and the three 4 kV FLEX DGs.E5- 7 Overall Integrated Plan Open Item Status 01-11: Design and install the modifications required by Started Order EA-1 3-109 for the Hardened Containment Vent System (HCVS). This will include modifying the HCVS system to permit controlled venting more than one unit at the same time, if necessary.

01-12: Design and install the modifications required by Started Order EA-12-051 for enhancing the SFP.01-13: Determine the design specifications for FLEX Started equipment yet to be ordered, such as the Six Portable ventilation fans, the Mobil Water Purification Unit, debris removal equipment for the FLEX Equipment Haul path and piping for the FLEX low pressure pumps.01-14: Deployment strategies and deployment routes will Started be assessed for impact due to identified hazards and guidance developed/provided to ensure that 1) sufficient area is available for deployment, 2) haul paths remain accessible without interference from outage equipment during refueling outages and 3) deployment locations for the pumps including ramps, winches or other transfer assemblies as appropriate to deploy all pumps and hoses within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Phase 1 coping interval.01-15: Detailed staffing studies based on the Not started procedures/guidance developed.

01-16. Validation of the time lines for the various Not started strategies.

01-17: BFNP will utilize the industry developed guidance Started from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.01-18: New training of general station staff and EP will Not started be performed prior to the 1st BFNP unit design implementation outage. These programs and controls will be implemented in accordance with the Systematic Approach to Training.01-19: TVA will establish a contract with the Strategic Started Alliance for FLEX Emergency Response (SAFER) team.A local assembly area must also be established by SAFER and TVA for equipment moved from the Regional Response Center (RRC) to BFNP.E6 -7 Draft Safety Evaluation Open Item Status None received at his time N/A 7 Potential NRC Evaluation Impacts There are no potential impacts to the NRC Evaluation identified at this time.8 References The following references support the updates to the Overall Integrated Plan described in this attachment.

1. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) -Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant," dated February 28, 2013 2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" E7 -7