ML12171A363

02/29/12 - Summary of Meeting with Tennessee Valley Authority to Discuss the National Fire Protection Association - 805 Transition for Browns Ferry Nuclear Plant, Units 1, 2, and 3

ML12171A363
Person / Time
Site:	Browns Ferry
Issue date:	06/28/2012
From:	Ellen Brown Plant Licensing Branch II
To:
Billoch-Colon, Araceli
Shared Package
ML12171A360	List: ML12171A363
References
TAC ME7841, TAC ME7842, TAC ME7843
Download: ML12171A363 (5)

Text

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LICENSEE: Tennessee Valley Authority FACILITIES: Browns Ferry Nuclear Plant, Units 1, 2, and 3

SUMMARY

OF THE FEBRUARY 29, 2012, TELECONFERENCE WITH THE TENNESSEE VALLEY AUTHORITY TO DISCUSS THE NFPA-805 TRANSITION FOR BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 (TAC NO. ME7841, ME7842, AND ME7843)

On February 29, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a Category 1 public teleconference with the Tennessee Valley Authority (TVA, the licensee) at NRC Headquarters, 11555 Rockville Pike, One White Flint North, Rockville, Maryland. The purpose of the meeting was to discuss the fire risk reduction and transition status to the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standards for Fire Protection for Light Water Reactor Electric Generating Plants" for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3.

BACKGROUND On March 4, 2009, the TVA notified the NRC staff of its intent to transition the BFN, Units 1, 2, and 3 to the NFPA 805 fire protection program in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(c). NFPA 805 was adopted in 10 CFR 50.48(c) as an alternative fire protection rule, which is one path to resolving longstanding fire protection issues.

Under this initiative, the NRC has exercised enforcement discretion for most fire protection noncompliances that are identified during the licensee's transition to NFPA 805, and for certain existing identified non compliances that reasonably may be resolved at the completion of transition. To receive enforcement discretion for these noncompliances, the licensee must meet the specific criteria as stated in Section 9.1, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," of the NRC Enforcement Policy, dated July 12, 2011.

In a public meeting held on December 8, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11353A319), between the NRC and the TVA, the licensee described a transition strategy intended to address the corrective actions for previously cited fire protection violations, along with other noncompliances identified during the transition period. This strategy encompasses a parallel effort that wilt add recovery actions based on the potential fire damage to the affected areas. This will necessitate (1) significant changes in safe shutdown procedures and modifications to systems and components, and (2) the development of a license amendment request (LAR) necessary for transition to NFPA 805.

- 2 In a letter dated January 13,2012 (ADAMS Accession No. ML12017A186), TVA reiterated the current transition strategy and notified the NRC that TVA will be revising the BFN Units 1, 2, and 3 submittal schedule date and will submit an LAR no later than March 29, 2013. The newly proposed submittal date is beyond the 3-year allotted timeframe and enforcement discretion granted to BFN Units 1, 2, and 3 for certain noncompliances, which ended on March 4, 2012.

However, if provided adequate justification, the NRC may choose to accept the proposed submittal date through the use of a confirmatory order (CO), thereby continuing the enforcement discretion provided in Section 9.1.

DISCUSSION During the the February 29, 2012, teleconference, the licensee and the NRC staff discussed the status of the BFN Units 1, 2, and 3 fire probabilistic risk assessment (PRA) peer review in support of the NRC decision-making process. The discussion focused on plant modifications, the licensee's fire risk general reduction strategy, and the licensee's schedule to meet the requirements of 10 CFR 50.48 and NFPA 805.

The plant's modifications discussions between the NRC staff and the licensee included the installation of cable tray covers, the local control stations, and the incipient detection system.

The licensee indicated that the purpose of installing the cable tray covers in BFN Units 1, 2, and 3 is to delay fire damage in case of a fire. The licensee also indicated that the local control stations will be used to create separation between the electrical circuits. The licensee also described the installation process of the incipient detection system in the compartments and panels of the auxiliary instrumentation room.

The licensee and the NRC staff also discussed plant modifications to BFN Units 1, 2, and 3 related to the cable qualifications, isolation relays, cable routing, cable walkdowns, operator manual actions, and the completed modifications to the site.

During the meeting, the licensee discussed the status of the fire PRA analysis and the strategy to improve the plant fire safety in BFN Units 1, 2, and 3. The licensee indicated that the fire PRA analysis is undergoing peer review. The licensee explained that the current fire protection model is being refined according to the NRC regulations and the guidance in NUREG-0800 "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR [Light-Water Reactor] Edition." The licensee indicated that the results of the fire PRA would reduce the core dame frequency from 1OE-4 to 1OF5 for BFN Units 1, 2, and 3. The licensee also indicated that the plant modifications and the refined operator actions will be included in the fire PRA transition.

In terms of scheduling, during the teleconference, the TVA expressed a desire to continue the enforcement discretion due to the delays in the revision of the BFN Units 1, 2, and 3 fire PRA review. Also, TVA indicated willingness to sign a CO, and commit to the proposed March 29, 2013, LAR submittal date. No commitments or regulatory decisions were made by the NRC staff during the meeting.

- 3 Members of the public were in attendance, but no public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-2315.

Sincerely,

~ G'.~~y Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, 50-296

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES FEBRUARY 29.2012. MEETING WITH TENNESSEE VALEEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1. 2. AND 3 NFPA-805 TRANSITION NRC Tennessee Valley Authority Joe Giitter Joe Shea Allen Howe Ching Guey Douglas Broaddus James Emen Alex Klein James Nesbitt Gerry Weisman Rudy Bramhord Roger Hannah Jeff Hamman Terry Ross Kenny McKenzy John S. Hyslop Craig Konty David Stroup Roger Hannch Robert Daley Gabriel Taylor Platts (Nucleonics Week)

William Jones Bill Freelavin Daniel Frumkin Harold Barrett Excel Charles Stancil Amy Hayelhoff Mark Salley Eva Brown GAO Araceli T, Billoch Stephen Carter Stephanie Goins Enrnie Hoyera ENCLOSURE

- 3 Members of the public were in attendance, but no public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-2315.

Sincerely, IRA by Siva Lingam forI Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, 50-296

Enclosure:

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

PUBLIC Lp12-2 R/F RidsNrrDorlLpl2-2 RidsNrrPMBrownsFerry RidsNrrLABClayton RidsAcrsAcnw_MailCTR RidsNrrDraAfpb RidsNrrDraApla RidsNrrDra RidsOgcRp RidsRgn2MailCenter TWertz, NRR MKotzaras, EDO SDinsmore, NRR EGuthrie, RII RidsNrrDorl TRoss, RII DHarrison, NRR ABilioch, NRR GWeisman, NRR RHannah, RII JHyslop, NRR DStroup, RES RDaley. Rill MSalley, RES GTaylor, RES WJones, RII DFrumkin, NRR HBarrett, NRR CStancil, RII ADAMS A ccesslon Nos.: Package ML12171A360 N' otlce ML12055A063 Summary ML12171A363 OFFICE LPL2-2/PM LPL2-2/PM LPL2-21LA LPL2-21BC LPL2-21PM NAME EBrown ABillochCol6n BClayton DBroaddus EBrown (SLingam for)

DATE 06119/12 06/19/12 06/28/12 06/28112 06/28/12 OFFICIAL RECORD COpy