L-16-079, Supplemental Information for License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805

Supplemental Information for License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805

ML16067A195
Person / Time
Site:	Davis Besse
Issue date:	03/07/2016
From:	Byrd K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF7190, L-16-079
Download: ML16067A195 (4)

Text

FENOC Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 N. State Route 2 Oak Harbor. Ohio 43449 March 7, 2016 L-16-079 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Supplemental Information for License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 (CAC No. MF7190)

By letter dated December 16, 2015 (Accession No. ML15350A314), FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request to adopt NFPA Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)." By letter dated February 22, 2016 (Accession No. ML16047A145), the Nuclear Regulatory Commission (NRC) requested information enabling the staff to begin the detailed technical review. As clarified in the attachment, the requested information was provided in the December 16, 2015 submittal.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March _z_, 2016.

Sincerely, l<tu8.A_A __ Cl Kendall W. By;§;/'--~ ~

Director, Site Engineering

Attachment:

Response to February 22, 2016 Supplemental Information Request cc: NRC Regional Administrator - Region Ill NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Attachment L-16-079 Response to February 22, 2016 Supplemental Information Request Page 1of3 The Nuclear Regulatory Commission staff requested information to begin detailed technical review of a FENOC license amendment request (LAR) for Davis-Besse Nuclear Power Station (DBNPS). The LAR would change the current fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. The NRC staff's request is provided below in bold text followed by the corresponding FENOC response.

Request Provide the facts and observations (F&Os) from the last full-scope peer review of the internal events probabilistic risk assessment (IEPRA) and their resolutions.

LAR Attachment U provides the results of a gap assessment of the IEPRA, the F&Os from a focused-scope peer review of the large early release frequency (LERF) element of the IEPRA, and the F&Os from a focused-scope peer review of the internal flooding probabilistic risk assessment (PRA). LAR Attachment U does not provide the F&Os from the last full-scope peer review or their resolutions. The full text of these F&Os, and the licensee's resolution to each, are required to facilitate review of the technical adequacy of the IEPRA from which the fire PRA is constructed.

Basis Section 4.3, "Fire Probabilistic Risk Assessment," of NRC Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1 (ADAMS Accession No. ML092730314) states:

The fire PRA used to perform the risk assessments in NFPA 805, Section 2.4.4 (plant change evaluation), and Section 4.2.4.2 (fire risk evaluation),

must be of sufficient technical adequacy to support the application. In accordance with Section 2.4.3.3 of NFPA 805, the NRC must find the PRA approach, methods, and data acceptable. There are two aspects to assessing ,the technical adequacy of the PRA results. First, the underlying PRA (i.e., the baseline model) should be technically adequate. Second, the analyses, assumptions, and approximations to map the cause-effect relationship associated with the application must be technically adequate.

Attachment L-16-079 Page 2 of 3 The licensee may address the first aspect for risk-informed applications by conforming to the peer review and self-assessment processes in Regulatory Guide 1.200 [RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2 (ADAMS Accession No. ML090410014)].

This regulatory guide provides one approach acceptable to the NRC for determining the technical adequacy of the baseline PRA model. Regulatory Guide 1.200 endorses, with certain clarifications and qualifications, Addendum A to the American Society of Mechanical Engineers/American Nuclear Society (ASME/ANS) RA-Sa 2009, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications" ("PRA Standard")

(Ref. 15).

RG 1.205, Section 4.3, further states: "The licensee should submit the documentation described in Section 4.2 of Regulatory Guide 1.200 to address the baseline PRA and application-specific analyses." Section 4.2 of RG 1.200 states, in part, that the application should discuss the resolution of the peer review F&Os that are applicable to the parts of the PRA required for the application. This should include (1) a discussion of how the PRA model has been changed, and (2) justification in the form of a sensitivity study that demonstrates the accident sequences or contributors significant to the application decision were not adversely impacted (remained the same) by the particular issue.

Response

The 2008 gap assessment for the DBNPS PRA model, first discussed in the December 16, 2015 NFPA 805 license amendment request (Attachment U, page U-1), is the most recent full-scope peer review and includes F&Os against the ASME RA-Sb-2005, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," and RG 1.200, Revision 1. Typically, a gap assessment is performed to review the differences between two versions of the PRA ASME standard.

However, the purpose of the gap assessment described in the December 16, 2015 submittal was to assess the current status of the PRA with regard to the supporting requirements (SRs), assign an indication of the significance of the gaps and F&Os identified (levels A-D), describe the scope of effort needed to close the gap and F&O to capability category (CC) II, and estimate the resources necessary to accomplish closure of the gap and F&O. Thus, this gap assessment is far more encompassing than a typical peer review of the PRA model. All requirements for conducting a peer review were met. The review team consisted of five independent reviewers qualified per NEI 05-04, "Process for Performing Follow-on PRA Peer Reviewers Using the ASME PRA Standard," January 2005, and they evaluated the current status of the PRA against the requirements in ASME RA-Sb-2005 and RG 1.200, Revision 1.

Attachment L-16-079 Page 3 of 3 The review was a full scope internal events Level 1 and LERF review covering ini~iating events, accident sequences, success criteria, system analysis, human reliability analysis, data analysis, quantification and results, and the maintenance and update technical areas of the ASME RA-Sb-2005 PRA standard. If the PRA model and documentation did not meet CC II of ASME RA-Sb-2005, an F&O was identified. The complete set of F&Os, including the significance of the finding, the review team's recommendation on how to resolve the F&O to achieve CC II for the identified SR(s),

the resolution of the F&O, and its impact on the fire PRA, were provided in Table U-1 of the December 16, 2015 submittal. One result of the review was classifying large early release and internal flooding as not reviewed, as they did not meet the requirements of the current analysis standards. Later, these two technical areas had separate focused-scope reviews against the relevant portions of the ASME/ANS-RA-Sa-2009 standard, and the F&Os are reported in Table U-2 (large early release) and Table U-3 (internal flooding). All F&Os originating from these reviews have been addressed using FENOC's PRA program to disposition the individual F&O, thus ensuring the model satisfies the PRA standard requirements.

Therefore, Attachment U of the December 16, 2015 submittal contains the latest full-scope peer review.