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 37402August 28, 201310 CFR 2.20210 CFR 50.4ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3Facility Operating License Nos. DPR-33, DPR-52, and DPR-68NRC 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 forMitigation 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 withRegard 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 forMitigation 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 StatusReport 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 October29, 2012 (ML12307A104)

Printed on recycled paper U.S. Nuclear Regulatory Commission Page 2August 28, 20135. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) -OverallIntegrated Plan in Response to the March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049) for BrownsFerry 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 TVAto develop, implement, and maintain guidance and strategies to maintain or restore corecooling, 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 thefinal 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 5provided 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 ofthe overall integrated plan. Reference 3 provides direction regarding the content of the statusreports.

The purpose of this letter is to provide the first six-month status report pursuant toSection IV, Condition C.2, of Reference 1, that delineates progress made in implementing therequirements of Reference

1. The enclosed report provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to thecompliance 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 takenby 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 the28th day of A gust 2013.Respe uce President, Nuclear Licensing Enclosure cc: See Page 3 U.S. Nuclear Regulatory Commission Page 3August 28, 2013

Enclosure:

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

NRR Director

-NRC Headquarters NRO Director

-NRC Headquarters NRC Regional Administrator

-Region IINRC Project Manager -Browns Ferry Nuclear PlantNRC Senior Resident Inspector

-Browns Ferry Nuclear Plant ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT'S FIRST SIXMONTH 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 inSection 8), documenting the diverse and flexible strategies (FLEX), in response toReference

2. This attachment provides an update of milestone accomplishments sincesubmittal of the Overall Integrated Plan, including any changes to the compliance methodor schedule.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OverallIntegrated Plan (Reference 1 in Section 8), and are current as of July 30, 2013.Unit 2 N-1 Walkdown3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the Overall Integrated Plan. Itprovides the activity status of each item, and whether the expected completion date haschanged.

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.RevisedActivity Original Target Activity TargetDate Status Completion DateSubmit Overall Integrated Plan February 2013 CompleteSubmit 6 Month Updates:Update 1 August 2013 CompleteUpdate 2 February 2014 Not StartedUpdate 3 August 2014 Not StartedUpdate 4 February 2015 Not StartedUpdate 5 August 2015 Not StartedUpdate 6 February 2016 Not StartedUpdate 7 August 2016 Not StartedFLEX Strategy Evaluation June 2013 On Track October 2013Unit I -Validation of connection points for FLEX Phase 2 & 3 via November 20161 Not Startedwalkthrough or demonstration.

(Graded approach)

El -7 RevisedActivity Original Target Activity TargetDate Status Completion DateUnit 2 -Validation of connection points for FLEX Phase 2 & 3 via May 20151 Not Startedwalkthrough or demonstration.

(Graded approach)

Unit 3 -Validation of connection points for FLEX Phase 2 & 3 via April 20161 Not Startedwalkthrough or demonstration.

(Graded approach)

Perform Staffing Analysis October 2014 Not StartedModifications:

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

Procure On-Site Equipment October 2013 On TrackDevelop Strategies with RRC December 2013 Not StartedInstall Off-Site Delivery Station May 20151 Not StartedProcedures:

BWROG issues FSG guidelines January 2014 Not StartedCreate Browns Ferry FSGs March 2014 Not StartedCreate Maintenance Procedures June 2014 Not StartedTraining:

Develop Training Plan January 2014 Not StartedImplement Training March 2014 Not StartedUnit 1 FLEX Implementation November 2016 Not StartedUnit 2 FLEX Implementation April 2015 Not Started May 2015Unit 3 FLEX Implementation April 2016 Not StartedFull Site FLEX Implementation November 2016 Not StartedSubmit Completion Report December 2016 Not StartedNotes: 1. These milestones were not included in the February 28, 2013, Overall Integrated PlanE2 -7 4 Changes to Compliance MethodThe following is a list of changes made to the information provided in theFebruary 28, 2013, Overall Integrated Plan (Reference 1). These changes meet theNEI 12-06 compliance method.4.1 (Section 11, Section 14, Section 17 and Section 18, 3.b.ii, Note) was changed toread as follows:"Note: The B RHRSW inlet header can provide standby coolant to unit 2 and/or unit3, if needed."4.2 (Section 11, Section 14, Section 17 and Section 18, 3.b.iii, Note) was changed toread as follows:"Note: The D RHRSW inlet header can provide standby coolant to unit 1 and/or unit2, if needed."4.3 (Section lId Severe Storms with High Winds, Section 14d Severe Storms withHigh Winds, Section 20d Severe Storms with High Winds) changed to read asfollows:"Portable equipment required to implement this FLEX strategy will be maintained inthe FESB, which is designed to meet or exceed the licensing basis high wind hazardfor BFNP, with the exception of the 480 V FLEX DGs. An extreme tornado couldexceed 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 shallbe 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 beprotected 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 tothe 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) iscurrently 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 OrderEA-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 thatare protected from storms and high winds. Portable equipment required toimplement this FLEX strategy will be maintained in the FESB, which is designed tomeet or exceed the licensing basis high wind hazard for BFNP, with the exception ofthe 480 V FLEX DGs. An extreme tornado could exceed the protection limits formore than one 480 V FLEX DG. (A beyond-design-basis tornado for BFNP wouldexceed 300MPH; protection for the FLEX DGs shall be designed to 230 MPH basedon NRC region 1 tornado,

missiles, and velocities defined in NRC Regulatory Guide1.76 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 supportuse of the system in support of FLEX strategies.

The interim modification is beingperformed 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 thanone 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 isrequired 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 OverallIntegrated Plan or the NRC Evaluation and the status of each item.Overall Integrated Plan Open Item Status01-1: Flood and seismic re-evaluations pursuant to the Not Started10 CFR 50.54(f) letter of March 12, 2012 are notcompleted and therefore not assumed in this submittal.

As the re-evaluations are completed, appropriate issueswill be entered into the corrective action system andaddressed.

01-2: Liquefaction of haul routed for FLEX will be Not Startedanalyzed.

01-3. TVA will confirm that they have enough fuel onsite Startedfor 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 startedpredicted containment response with FLEXimplementation to ensure there will be sufficient DC busvoltage and pneumatic pressure to operate the SRVsthroughout Phase 1 and Phase 2.01-5: An electrical load study will be performed to Not startedascertain the ability of the common Unit 1 & 2 chillers tobe placed into service powered by the FLEX DGs thatwould provide chilled water for the Unit 1 & 2 ControlBay and the Unit 1 & 2 Electric Board rooms.01-6: Formalize the preliminary Battery studies that were Not startedperformed to ensure appropriate battery life will beavailable with regards to the overall FLEX strategies.

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

01-8: Perform modifications, as necessary, to ensure Not startedthat RCIC is seismically robust.01-9: Develop and perform the design modifications Startedidentified in the FLEX Strategy document to permit thetimely and safe connection of the FLEX and RRCequipment during the adverse conditions encountered during these beyond design basis events.01-10: Design and construct a Flexible Equipment StartedStorage Building, located above the probable maximumflood level, which meets the plant's design basis for theSafe Shutdown Earthquake and the plant's design basisfor high wind hazards.

This storage facility will be usedto store support equipment and items, including the fourFLEX Pumping Systems and the three 4 kV FLEX DGs.E5- 7 Overall Integrated Plan Open Item Status01-11: Design and install the modifications required by StartedOrder EA-1 3-109 for the Hardened Containment VentSystem (HCVS). This will include modifying the HCVSsystem to permit controlled venting more than one unit atthe same time, if necessary.

01-12: Design and install the modifications required by StartedOrder EA-12-051 for enhancing the SFP.01-13: Determine the design specifications for FLEX Startedequipment yet to be ordered, such as the Six Portableventilation fans, the Mobil Water Purification Unit, debrisremoval equipment for the FLEX Equipment Haul pathand piping for the FLEX low pressure pumps.01-14: Deployment strategies and deployment routes will Startedbe assessed for impact due to identified hazards andguidance developed/provided to ensure that 1) sufficient area is available for deployment,

2) haul paths remainaccessible without interference from outage equipment during refueling outages and 3) deployment locations forthe pumps including ramps, winches or other transferassemblies as appropriate to deploy all pumps andhoses 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 startedprocedures/guidance developed.

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

01-17: BFNP will utilize the industry developed guidance Startedfrom the Owners Groups, EPRI and NEI Task team todevelop site specific procedures or guidelines to addressthe criteria in NEI 12-06. These procedures and/orguidelines will support the existing symptom basedcommand and control strategies in the current EOPs.01-18: New training of general station staff and EP will Not startedbe performed prior to the 1st BFNP unit designimplementation outage. These programs and controlswill be implemented in accordance with the Systematic Approach to Training.

01-19: TVA will establish a contract with the Strategic StartedAlliance for FLEX Emergency Response (SAFER) team.A local assembly area must also be established bySAFER and TVA for equipment moved from theRegional Response Center (RRC) to BFNP.E6 -7 Draft Safety Evaluation Open Item StatusNone received at his time N/A7 Potential NRC Evaluation ImpactsThere 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 inthis attachment.

1. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) -Overall Integrated Plan inResponse to the March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049) for Browns Ferry Nuclear Plant," dated February 28, 20132. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

datedMarch 12, 20123. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide"E7 -7