ML14177A578

November 13, 2013, Summary of Meeting with Firstenergy Nuclear Operating Company to Discuss Delay in Submittal of Fire Risk Reduction Amendment Request

ML14177A578
Person / Time
Site:	Davis Besse
Issue date:	02/22/2016
From:	Blake Purnell Plant Licensing Branch III
To:
Purnell B, NRR/DORL 415-1380
References
Download: ML14177A578 (5)

Text

LICENSEE:

FACILITY:

SUBJECT:

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 R:brwry 22, 2016 FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station, Unit 1

SUMMARY

OF NOVEMBER 13, 2013, MEETING WITH FIRSTENERGY NUCLEAR OPERATING COMPANY TO DISCUSS DELAY IN SUBMITTAL OF FIRE RISK REDUCTION AMENDMENT REQUEST On November 13, 2013, the U.S. Nuclear Regulatory Commission (NRC or Commission) staff conducted a Category 1 public meeting with FirstEnergy Nuclear Operating Company (FENOC, the licensee) at NRC Headquarters, 11555 Rockville Pike, One White Flint North, Rockville, Maryland.

The purpose of the meeting was to discuss the submission of an amendment requesting to transition to the National Fire Protection Association (NFPA) Standard 805 "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generation Plants," 2001 Edition (NFPA 805), at the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS). The enclosure contains a list of attendees.

The licensee presented a slide presentation (see the Agencywide Documents Access and Management System (ADAMS) Accession No. ML13322B311).

BACKGROUND In a letter dated December 22, 2005 (ADAMS Accession No. ML060040259), FENOC notified the NRC of its intent to adopt NFPA 805. Consistent with the April 18, 2006, Federal Register notice (71 FR 19905), the NRC considered the discretion period for DBNPS to begin on December 31, 2005, and expire on December 31, 2008. Subsequently, by letter dated February 27, 2007 (ADAMS Accession No. ML070590517)

FENOC notified the NRC staff that transition activities would begin on March 1, 2007, thereby starting the initial 3-year period of enforcement discretion.

By letter dated May 1, 2007 (ADAMS Accession No. ML071000033), the NRC acknowledged the request and informed FENOC that the request to extend discretion until March 1, 2010, was granted. On September 10, 2008, the NRC published an Interim Enforcement Policy in the Federal Register (73 FR 52705). The interim policy indicated that if a licensee had made substantial progress in transition efforts to adopt NFPA 805, the period of extension would expire 6 months after NRC approval of the license amendment for the second of two pilot plants involved in the NFPA 805 transition initiative.

On December 29, 2010, an amendment was issued for the second pilot plant, thereby establishing June 29, 2011, as the expiration date for the current enforcement discretion period. On June 10, 2011, the Commission issued staff requirements memorandum (SRM) 11-0061, "A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR [Title 10 of the Code of Federal Regulations]

50.48(C) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach" (ADAMS Accession No. ML111610616), indicating that an extension would be allowed provided the licensee provided a suitable justification by June 29, 2011. The licensee submitted a letter on June 29, 2011 (ADAMS Accession No. ML111800765), acknowledging a new commitment date for their license amendment application of July 1, 2014. DISCUSSION The licensee discussed the proposed schedule extension request. The licensee proposed submittal of a voluntary request to adopt NFPA 805 after completion of risk beneficial modifications scheduled to be completed during the spring 2016 refueling outage. The proposal would include a request for continuation of enforcement discretion until the request was submitted.

The basis of the request centers on the significance of identified nonconformances being less than red and two major risk reducing modifications.

These modifications are the major contributors to reducing overall risk where the addition of a diesel-driven feedwater pump and a seismic and missile protected condensate storage tank. Both of these modifications are also being credited by the licensee to support DBNPS's response to the mitigating strategies order. The licensee discussed the status of the ongoing NFPA 805 transition activities at DBNPS. It was discussed that fire modeling had been completed.

The analysis was completed consistent with NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities" (ADAMS Accession No. ML050940214), and no unapproved analysis methods were used. The peer review was completed in June 2013, and fire risk evaluations (FREs) were underway to support resolution of any variations from deterministic requirement.

Completion of the FREs and the draft transition report were scheduled for December 2013. The status of existing nonconformances were discussed.

The NRC staff voiced concern that the licensee had indicated compensatory measures were only provided for the highest risk fire compartments related to multiple spurious operations.

One of the requirements for continued discretion was appropriate compensatory measures for identified nonconformances.

The NRC staff mentioned the ongoing misunderstanding by some licensees that the no prior NRC approval is required for operator manual actions to address fire induced circuit failures.

Single spurious actuations involve a single fire induced circuit fault that causes undesired operation of one or more systems or components.

The NRC staff suggested that the licensee verify that appropriate approvals were in place for those areas where no compensatory measures were in effect for identified nonconformances.

During the meeting, the licensee indicated their intent to submit the extension request by January 2014. By letter dated April 1, 2014 (ADAMS Accession No. ML14091A453), FENOC requested an extension of its enforcement discretion for DBNPS and committed to provide its NFPA 805 application by December 31, 2015. By confirmatory order dated June 30, 2014 (ADAMS Accession No.ML14164A179), the NRC approved the extension request for DBNPS. No members of the public were in attendance, and no feedback forms were received.

No commitments or regulatory decisions were made by the NRC staff during the meeting. Docket No. 50-346

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Participants Nuclear Regulatory Commission Public Meeting with FirstEnergy Nuclear Operating Company Regarding Delay in Fire Risk Reduction Amendment Request U. S. NUCLEAR REGULATORY COMMISSION John Monninger John Lubinski Travis Tate Alex Klein Paul Lain Dariusz Schwarz Garrett Newman Juan Uribe Elaine Keegan FIRSTENERGY NUCLEAR OPERATING COMPANY Tom Lentz Henry Hegrat Kendall Byrd Jonathan Hook Colin Keller Dennis Blakely Matthew Murtha Joshua Ross Nicholas Rochford Kathy Nesser Enclosure No members of the public were in attendance, and no feedback forms were received.

No commitments or regulatory decisions were made by the NRC staff during the meeting. Docket No. 50-346

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv DISTRIBUTION:

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RidsOpaMail Resource Sincerely, IRA/ Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrDorl Resource LPL3-2 R/F RidsNrrDraApla VMitlyng, Rlll/OPA RidsNrrDraAfpb GNewman Rlyengar, EDO Plain JS Hyslop THilsmeier ADAMS Accession No. ML14177A578 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC(A)

LPL3-2/PM NAME EBrown SRohrer JPoole BPurnell DATE 2/18/16 2/18/16 2/22/16 2/22/16 OFFICIAL RECORD COPY