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11/8/12 Summary of Meeting with Tennessee Valley Authority to Discuss the NFPA-805 Transition for Browns Ferry Nuclear Plant, Units 1, 2, and 3
	ML12324A332
Person / Time
Site:	Browns Ferry
Issue date:	11/30/2012
From:	Ellen Brown; Plant Licensing Branch II
To:	;
	Brown, Eva A.
Shared Package
ML12324A330	List: ML12324A332; ML12324A335;
References
	TAC ME7841, TAC ME7842, TAC ME7843
	Download: ML12324A332 (5)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 30, 2012 LICENSEE: Tennessee Valley Authority FACILITIES: Browns Ferry Nuclear Plant, Units 1, 2, and 3

SUBJECT:

SUMMARY

OF THE NOVEMBER 8,2012, MEETING WITH THE TENNESSEE VALLEY AUTHORITY TO DISCUSS THE NFPA-805 TRANSITION FOR BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 (TAC NOS. ME7841, ME7842, AND ME7843)

On November 8,2012, 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. To facilitate discussion, the licensee provided a slide presentation (see Agencywide Documents Access and Management System (ADAMS) Accession No. ML12324A335).

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), Part 50, 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 noncompliances 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.

The TVA was scheduled to submit a license amendment request for BFN to transition to NFPA 805 on March 4,2012. In a public meeting held on December 8, 2011, TVA explained the transition strategy implemented at BFN. In addition to completing the actions necessary to transition to the NFPA-805 guidelines, BFN is making modifications to address fire protection noncompliances that were not covered under NFPA 805 enforcement discretion. Subsequently, in a letter dated January 13, 2012, TVA stated the development of a high-quality application will require more time than originally anticipated and TVA would submit its application no later than March 29, 2013.

- 2 A public teleconference was held on February 29, 2012 (ADAMS Accession No. ML12171A360), between the NRC and the TVA, 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.

Subsequently, by letter dated March 20, 2012 (ADAMS Accession No. ML12083A198), the licensee provided the status and completion schedule for the remaining key activities and major milestones for completing the NFPA-805 submittal. The NRC staff reviewed the proposed compensatory measures, additional modifications, and submittal schedule, and, consistent with SECY 12-0031, on May 18, 2012 (ADAMS Accession No. ML12053A190) issued a confirmatory order (CO) accepting the revised date.

DISCUSSION The licensee provided a status of the February 17, 2012, modifications, which are part of the May 18, 2012, CO. TVA indicated that the modifications identified in that submittal had been completed either on time or early. The NRC staff questioned whether the Browns Ferry units were still crediting the self-induced blackout. The licensee indicated that after completion of the modifications they would have a different starting point. The NRC staff indicated that the licensee explicitly define the proposed starting point for the review.

The licensee continued to describe the progress in completing the PRA. An initial peer review was conducted in January 2012 with a focused follow-up review in June 2012. The reviews identified143 findings and observations (F&Os) with 77 F&Os left to be resolved. The NRC staff indicated a desire for the licensee to include all F&Os identified in the submittal, regardless of whether the items had been resolved.

During the meeting the licensee discussed fire modeling and some issues discussed in the February 2012, meeting including area wide incipient detection, transient heat release rates (HRRs), 1-hour fire wrap, the definition of "safe and stable" and seismically induced fires.

The licensee described the use of incipient detection in the control room, auxiliary instrument room and the cable spreading rooms. The NRC staff indicated that the use of area wide incipient detection in the control room may represent an unreviewed analyses method and may need a much more detailed justification. In the Auxiliary Instrument room, the licensee discussed both its use in panels and area wide. TVA indicated that incipient detection was used to support faster detection to support the manual suppression being credited for fire mitigation.

The NRC staff indicated the desire to see a sensitivity study comparing the change in core damage frequency [~CDF] from regular detection to this enhanced strategy in the submittal.

For the cable spreading room, the incipient detection system would also be used. To support personnel safety concerns, there was a 4-minute lockout. The NRC staff questioned how the lockout was modeled and indicated the desire to see a sensitivity study on the use of the lockout, and those actions taken after the lockout is initiated. Additionally, the NRC staff mentioned the need to include the environmental effect the release or leakage of the gaseous system would have in the environmental review.

-3 The licensee indicated that the crediting of the administrative controls in support of the use of a lower heat release rate (HRR) than typically recommended in some areas. The NRC staff indicated that there would likely be questions regarding that approach, that a sensitivity study may be warranted to support the lower HRR, and that Frequently Asked Questions (FAQ) 11-0064 (ADAMS Accession No. ML121780013) had recently been issued that discussed the crediting of administrative controls.

During the discussion on detailed fire modeling, the licensee indicated that in some cases they would be crediting Thermo-lag as a 1-hour fire wrap. The NRC staff indicated that adequate justification should be provided for the duration of the credit assumed in the model.

The presentation included a status of the current post-transition risk values. The NRC staff indicated that typically the fire large early release frequency (LERF) for a fire PRA was typically higher than the non-fire LERF. The NRC staff questioned why this was the case for the BFN units.

TVA has identified 74 design changes for transition. The NRC staff recommended that the licensee ensure that none of the design changes need prior NRC approval before submittal of the NFPA-805 submittal.

The NRC staff questioned how the licensee has defined their "safe and stable" condition. TVA indicated that it should be hot shutdown. Further questions were asked regarding whether the submittal would identify any long term recovery actions; qualitatively address any long term maintenance and why risk is negligible upon reaching the "safe and stable" condition.

The meeting concluded with a request for the licensee to ensure that recent operating experience and recently identified operational issues would be reviewed to ensure they are properly addressed in the submittal, if necessary.

No members of the public were in attendance, and one feedback form was received. No commitments or regulatory decisions were made by the NRC staff during the meeting.

Please direct any inquires to me at 301-415-2315 or Eva.Brown@nrc.gov.

IRA!

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, and 50-296

Enclosure:

List of Meeting Attendees cc wI encl: Distribution via Listserv

LIST OF ATTENDEES NUCLEAR REGULATORY COMMISSION PUBLIC MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING PROPOSED FIRE PROTECTION SUBMITTAL NOVEMBER 8. 2012 U. S. NUCLEAR REGULATORY COMMISSION Eugene Guthrie* Donnie Harrison Craig Kontz* Stephen Dinsmore Paul Lain See-Meng Wong Ray Gallucci Dan O'Neal Eva Brown TENNESSEE VALLEY AUTHORITY Joe Shea Brenda Simril Todd Stafford Joe Williams Ching Guey James Emens JD Wolcott Robert Whalen Jerry Jones John Osbourne Brian Sweeney*

Engineering Planning and Management Mark Schairer*

By phone Enclosure