ML051400375

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Request for Additional Information, Service Water Intake Structure Exemption from Fire Protection Requirements
ML051400375
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 05/23/2005
From: James Shea
NRC/NRR/DLPM/LPD2
To: Stinson L
Southern Nuclear Operating Co
SHea J, 415-1388, NRR/DLPM
References
TAC MC0627, TAC MC0628
Download: ML051400375 (5)


Text

May 23, 2005 Mr. L. M. Stinson Vice President - Farley Project Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RE: SERVICE WATER INTAKE STRUCTURE EXEMPTION FROM FIRE PROTECTION REQUIREMENTS (TAC NOS.

MC0627 AND MC0628)

Dear Mr. Stinson:

By letter dated August 28, 2003, and supplemented on December 28, 2004, Southern Nuclear Operating Company requested a revision to an existing exemption concerning the Service water Intake Structure for Farley Nuclear Plant (FNP), Units 1 and 2. Specifically, to eliminate the FNP reliance on Kaowool, the proposal would allow an alternate compliance strategy based on a combination of changes to the current FNP fire protection program and an application of the risk-informed, performance-based methods of NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. The Nuclear Regulatory Commission staff has reviewed the application and has determined that a request for additional information is required, as identified in the Enclosure.

We discussed these issues with your staff on May 12, 2005. Your staff indicated that you would attempt to provide your response within 30 days of the date you receive the questions.

Please contact me at (301) 415-1388, if you have any other questions on these issues.

Sincerely,

/RA/

James J. Shea, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

As stated cc w/encl: See next page

ML051400375 NRR-088 OFFICE PDII-1/PM PDII-1/LA DSSA-SPLB PDII-1/SC NAME JShea CHawes SWeerakkody EMarinos DATE 05/ 20 /05 05/ 20 /05 05/ 17 /05 05/23/05

REQUEST FOR ADDITIONAL INFORMATION (RAI)

SOUTHERN NUCLEAR OPERATING COMPANY (SNC), INC.

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364 The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal dated August 28, 2003, and as supplemented on December 28, 2004, regarding a proposed revision to an existing exemption concerning the Service Water Intake Structure (SWIS).

The NRC staff has identified the following information that is needed to enable the continuation of its review.

1. Followup on SNC Response to NRC Question #3 dated December 28, 2004:

Scenarios 1, 2, 6 and 7 are listed as one scenario per unit. Since each includes a fire initiating in either of two pumps, was the ignition frequency for each twice that for a single pump? If not, then there are two scenarios for each, one per pump, and the Core Damage Frequency (CDF) listed in the table for each (1.34E-7/yr) should be double, bringing the total CDF to 1.18E-6/yr. (Note, if the latter is true, this would impact the SNC Response to NRC Question #4, where it is stated that the CDF associated with the ten cases would be ~6.5E-7/yr per unit..., [which] placed the proposed change in Region III of the Regulatory Guide 1.174 acceptance criteria for CDF. There would also be an impact in the SNC Response to NRC Question #5 where the CDFs for the seven scenarios are compared.)

Please clarify the CDF values for these scenarios, are they based on a single pump fire ignition frequency or are they based on both pumps?

2. Followup on RAI Response to NRC Question #26 dated December 28, 2004:

The NRC Staff asked for the assumptions and basis for the conclusion of the deterministic re-analysis demonstrating that fire damage cannot result in spurious operation of the strainer inlet valves (total of 4 valves). The licensee responded that if the cables were subjected to hot shorts, open circuits, or shorts to ground it could not result in spurious closure of the valves.

a) Is this because power and control have been isolated?

b) If not, what was the basis for the conclusion? (Please provide a summary of your assumptions and methods, a detailed circuit analysis is not required)

Item 4, relating to four discharge valves to the wet pit and storage pond flume, conclusions were also based on a deterministic re-analysis as stated in your August 28, 2003, application and the same clarification is necessary.

c) Is this because power and control have been isolated?

d) If not, what was the basis for the conclusion? (Please provide a summary of your assumptions and methods, a detailed circuit analysis is not required) e) If a deterministic re-analysis was not performed for Item 4, please clarify and submit bases and conclusions.

3. SNC Response to NRC Questions on Fire Modeling dated December 28, 2004:

a) Scenario 1 fire modeling results discussed on NL-04-2326, Enclosure 2, page 29 of 95 do not appear to be consistent with Table A-9 results on page 53 of 95.

Which is the correct reference for the Scenario 1 fire modeling results?

b) Scenario 2 fire modeling results discussed on NL-04-2326, Enclosure 2, page 31 of 95 do not appear to be consistent with Table A-9 results on page 53 of 95.

Which is the correct reference for the Scenario 2 fire modeling results?

Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:

Mr. J. R. Johnson General Manager Southern Nuclear Operating Company, Inc.

P.O. Box 470 Ashford, AL 36312 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.

Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.

P.O. Box 470 Ashford, AL 36312