ML061520488
| ML061520488 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/21/2006 |
| From: | Holden C F Plant Licensing Branch III-2 |
| To: | Singer K W Tennessee Valley Authority |
| Chernoff M H, NRR/DORL, 415-4041 | |
| References | |
| TAC MC8826 | |
| Download: ML061520488 (5) | |
Text
September 21, 2006Mr. Karl W. SingerChief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT, UNIT 1 - STATUS OF FIREPROTECTION PROGRAM (TAC NO. MC8826)Mr. Singer:
The purpose of this letter is to inform you of the results of our review of fire protection (FP)program issues at Browns Ferry Nuclear Plant (BFN) Unit 1 and to iterate actions necessary to bring the program into compliance with the U.S. Nuclear Regulatory Commission's (NRC's)applicable regulations.As background, by letter dated March 19, 1993, Tennessee Valley Authority (TVA) committedto bring the fire protection program at BFN Unit 1 into compliance with Title 10 to the Code ofFederal Regulations (10 CFR) Section 50.48 and 10 CFR Part 50, Appendix R, paragraphsIII.G, III.J, and III.L. By letter dated January 3, 2006, the NRC staff requested that TVA provideinformation regarding implementation of the fire protection program upon restart of Unit 1. TVA responded to the NRC staff request by letters dated February 3 and 28, 2006. In itsFebruary 28, 2006, letter, TVA also provided a draft version of the BFN Units 1, 2 and 3, Fire Protection Report (FPR), which integrates Unit 1 into the FPR. A meeting between the NRC and TVA staffs was held on April 5, 2006, to discuss NRC staff concerns regarding the draftFPR. During the discussion, TVA reiterated its goal to maintain operational fidelity among all three units. To this end, TVA indicated that the Unit 1 FP program analysis was performed using the same methodology as Units 2 and 3 (i.e., similar modifications, manual actions, and same shutdown paths). Subsequently, in its letter dated April 24, 2006, TVA provided various commitments regarding the FP program. On June 30, 2006, the NRC staff issued Regulatory Issue Summary (RIS) 2006-10, "RegulatoryExpectations with Appendix R Paragraph III.G.2 Operator Manual Actions." In this document,the NRC reiterated the 10 CFR Part 50, Appendix R, Paragraph III.G.2, complianceexpectations with respect to the use of operator manual actions. The RIS discussed the means to achieve compliance, and advised licensees of the date the NRC will terminate theenforcement discretion guidance in Enforcement Guide Memorandum (EGM) 98-02, "Enforcement Guidance Memorandum--Disposition of Violations of Appendix R, Sections III.G and III.L Regarding Circuit Failures," Revision 2, issued in February 2000 (incorporated intoEnforcement Manual section 8.1.7.1). The RIS also discussed potential exemption requests,compensatory measures and corrective actions pertaining to operator manual actions.
K. Singer- 2 -Consistent with 10 CFR 50.48, TVA must satisfactorily establish fire protection features whichsatisfy the requirements of paragraph III.G of Appendix R. The NRC staff notes that forcloseout of the Unit 1 Fire Protection Special Program in support of restart, several items must be satisfactorily addressed. These items include resolution of post-fire safe-shutdown circuit analysis spurious actuations, as well as any associated FP operator manual actions. To address these issues for Unit 1, TVA should address the following: (1)TVA should resolve issues arising from recent NRC FP generic communications,specifically, BFN Units 1, 2, and 3 must meet current regulatory requirements, including the treatment of FP operator manual actions. Operator manual actions that do not comply with the regulations and have not receivedapproval by exemption from the regulations should be considered noncompliances. As noted in RIS 2006-10, enforcement discretion was granted by the NRC for circuitanalysis issues, which include those using manual actions in lieu of paragraph III.G.2compliance. Consistent with other licensees, TVA, in its letter of April 24, 2006, committed to identify the Appendix R, Paragraph III.G.2, noncompliances involvingoperator manual actions, to place them into TVA's corrective action program, and to implement compensatory measures. Therefore, TVA should complete the commitments made in its April 24, 2006, letter, as well as any other restart related commitments made previously to the NRC regarding post-fire operator manual actions and notify the NRCstaff upon completion. (2)TVA should evaluate its licensing basis regarding multiple spurious post-firesafe-shutdown analyses. The NRC published a draft Generic Letter (GL) in theFederal Register for public comment on October 19, 2005 (70 FR 60859). The NRCstaff plans to issue the finalized letter in September 2006. Upon receipt of the GL, TVA should respond to the requests for information delineated in that GL. Like other licensees, TVA will then have 2-1/2 more years to complete the associated correctiveactions. In addition, 30 days after receiving the GL, TVA should inform the NRC aboutthe design assumptions that will be used to conduct its safe-shutdown analysis forUnit 1. (3)During the most recent fire protection inspection, TVA indicated that the Safe ShutdownInstructions used to direct those actions needed to bring the unit to safe shutdown in the event of a fire will not be complete until spring 2007. As these procedures containinterim compensatory measures to address safe shutdown analysis issues, the NRC staff requires that these procedures be completed by January 1, 2007.Therefore to support restart of Unit 1, TVA should (A) identify and document all Unit 1 fireprotection noncompliances in the corrective action program, (B) correct all safety significant items, (C) for the other items establish acceptable interim compensatory measures untilcorrective actions are completed, and (D) complete all hardware and administrative FP restart commitments. As indicated above, the NRC staff has requested that TVA provide notificationupon completion of necessary interim compensatory measures (Items 1 and 3) as well as inform the NRC staff concerning the Unit 1 safe-shutdown analysis design assumptions. TheNRC staff will use this information to make a determination regarding the ability of TVA to safely K. Singer- 3 -shutdown Unit 1 in the event of a fire consistent with 10 CFR 50.48, Appendix A, GeneralDesign Criteria 3, Fire Protection, and paragraphs III.G, III.J. and III.O of Appendix R.As indicated above, TVA provided various commitments regarding the FP program in its April2006 letter. It should be noted that certain commitments were identified to not be consistentwith NRC regulations, including the treatment of manual actions for Appendix R paragraphIII.G.2 areas. For example, the April 24, 2006, letter, states that the NRC staff has previouslyapproved post-fire manual actions in safety evaluations. Please be advised that any deviations from the requirements of Appendix R can only be made through a plant-specific exemption granted under the provisions of 10 CFR 50.12, not by safety evaluation. Inconsistencies in yourlicensing basis (e.g., safety evaluations cited by license condition 2.C(13)) should be identified in your corrective action program, appropriate interim compensatory measures established and then corrected by application for license amendment submitted for NRC approval under theprovisions of 10 CFR 50.90. Please note that the NRC is continuing its review process.
Should there be a need for additional actions, we will identify them in a prompt manner. If you have any questions concerning this matter, please contact me at 301-415-2429.Sincerely,/RA/Cornelius F. Holden, Deputy DirectorDivision of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-259 cc: See next page
ML061520488NRR-106 OFFICELPL2-2/PMLPL2-2/PMLPL2-2/LAAFPB/BCOGCNAMEEBrownMChernoffBClayton forCGoldsteinSWeerakkodyJMooreDATE 9 /19/069/19/06 9 /19/06 9 /19/06 8 /17/06 OFFICELPL2-2/BCDORL/DNAMELRaghavanCHoldenDATE9/21/069/21/06 Mr. Karl W. SingerBROWNS FERRY NUCLEAR PLANTTennessee Valley Authority
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Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, Vice PresidentNuclear Engineering & Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Brian O'Grady, Site Vice PresidentBrowns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Robert J. Beecken, Vice PresidentNuclear Support Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 General CounselTennessee Valley Authority ET 11A 400 West Summit Hill DriveKnoxville, TN 37902Mr. John C. Fornicola, ManagerNuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Mr. Bruce Aukland, Plant ManagerBrowns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Masoud Bajestani, Vice PresidentBrowns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Robert G. Jones, General ManagerBrowns Ferry Site Operations Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Larry S. MellenBrowns Ferry Unit 1 Project Engineer Division of Reactor Projects, Branch 6 U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW.
Suite 23T85 Atlanta, GA 30303-8931 Mr. Glenn W. Morris, Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801Mr. William D. Crouch, M anagerLicensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Senior Resident InspectorU.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970State Health OfficerAlabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017ChairmanLimestone County Commission 310 West Washington Street Athens, AL 35611