ML100600987

Discussion of Clarification Questions Related to the License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance - Based Standard for Fire Protection for Light ...

ML100600987
Person / Time
Site:	Harris
Issue date:	03/09/2010
From:	Vaaler M Plant Licensing Branch II
To:	Burton C Carolina Power & Light Co
Vaaler, Marlayna, NRR/DORL 415-3178
References
TAC MD8807
Download: ML100600987 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 9, 2010 Christopher L. Burton, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 SUB~IECT: SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - DISCUSSION OF CLARIFICATION QUESTIONS RELATED TO THE LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS" (TAC NO. MD8807)

Dear Mr. Burton:

By letter dated May 29, 2008, as supplemented by letters dated November 14, 2008, December 11, 2008, August 13, 2009, August 28, 2009, October 9, 2009, and February 4,2010, Carolina Power & Light Company (the licensee), now doing business as Progress Energy Carolinas, Inc. (PEC), submitted a proposed amendment for the Shearon Harris Nuclear Power Plant, Unit 1.

The proposed amendment would transition the fire protection program to a performance-based, risk-informed one based on the National Fire Protection Association Standard 805 (NFPA 805),

"Performance-Based Standard for Fire Protection For Light Water Reactor Generating Plants,"

2001 Edition, in accordance with Title 10 of the Code of Federal Regulations, Section 50.48(c).

NFPA 805 allows the use of performance-based methods, such as fire modeling, and risk-informed methods, such as Fire Probabilistic Risk Assessment, to demonstrate compliance with the nuclear safety performance criteria.

By letter dated January 14, 2010, the U.S. Nuclear Regulatory Commission (NRC) staff transmitted a second set of requests for additional information (RAls) in order to facilitate continuing review of HNP's application to transition to NFPA 805. However, during subsequent teleconferences between the NRC staff and licensee personnel to ensure a clear understanding of the RAls, several clarifying points were communicated to the licensee regarding the scope and type of information necessary to ensure a complete and satisfactory RAI response.

Although these clarifications were adequately incorporated by the licensee into the formal RAI response letter dated February 4, 2010, it is the NRC staff's responsibility to ensure that all communication relevant to the safety finding for a licensing action be retained on the associated docket. Accordingly, this letter serves solely to inform PEC of the clarification questions raised by the NRC staff during discussions with licensee personnel on the second set of RAls associated with HNP's request to transition to NFPA 805. Again, these issues have already been appropriately addressed in HNP's formal RAI response letter and no further action is required on the part of the licensee.

C.Burton -2 The enclosure to this letter contains the clarification questions communicated to the licensee via electronic mail (e-mails) dated January 25, 2010, January 27, 2010, and January 29, 2010, as a result of the ongoing discussions described above.

Please contact me at 301-415-3178, if you have any questions regarding this issue.

U arlayna Vaaler, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

As stated cc w/enclosure: Distribution via Listserv

CLARIFICATION QUESTIONS RELATED TO THE SECOND REQUEST FOR ADDITIONAL INFORMATION SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS" DOCKET NO. 50-400 By letter dated May 29,2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081560639), as supplemented by letters dated November 14, 2008 (ADAMS Accession No. ML083240593). December 11, 2008 (ADAMS Accession No. ML083510191), August 13, 2009 (ADAMS Accession No. ML092320120), August 28, 2009 (ADAMS Accession No. ML092580661), October 9, 2009 (ADAMS Accession No. ML092940499), and February 4, 2010 (ADAMS Accession No. ML100500543) Carolina Power & Light Company (the licensee), now doing business as Progress Energy Carolinas, Inc.,

submitted a proposed amendment for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

The proposed amendment would transition the fire protection program to a performance-based, risk-informed one based on the National Fire Protection Association Standard 805 (NFPA 805),

"Performance-Based Standard for Fire Protection For Light Water Reactor Generating Plants,"

2001 Edition, in accordance with Title 10 of the Code of Federal RegUlations, Section 50.48(c)

(10 CFR 50.48(c)). NFPA 805 allows the use of performance-based methods, such as fire modeling, and risk-informed methods, such as Fire Probabilistic Risk Assessment, to demonstrate compliance with the nuclear safety performance criteria.

By letter dated January 14, 2010 (ADAMS Accession No. ML100130254), the U.S. Nuclear Regulatory Commission (NRC) staff transmitted a second set of requests for additional information (RAls) in order to facilitate continuing review of HNP's application to transition to NFPA 805. However, during subsequent teleconferences between the NRC staff and licensee personnel to ensure a clear understanding of the RAls, several clarifying points were communicated to the licensee regarding the scope and type of information necessary to ensure a complete and satisfactory RAI response. Below are the clarification questions communicated to the licensee via electronic mail (e-mails) dated January 25,2010, January 27,2010, and January 29, 2010, as a result of these ongoing discussions.

Please note that the RAI numbering reflects that used in the original RAI letter dated August 6, 2009 (ADAMS Accession No. ML092170715), as carried forward through the January 14, 2010, RAI letter. In addition, all references to draft information or RAI responses reflect documents placed on a SharePoint electronic portal controlled by the licensee as a means of facilitating communication in relation to the more substantial aspects of the NFPA 805 application (Le., the extensive tables, fire area reviews, etc.). This information was used by the NRC staff during the clarification discussions but will not form the basis of the safety finding.

Enclosure

-2 CLARIFICATIONS Concerning the B-1 Table, "Transition of Fundamental Fire Protection Program and Design Elements," of the HNP NFPA 805 Transition Report

1. It appears that in many cases the licensee plans to merely remove the Final Safety Analysis Report (FSAR) information from the elements of the B-1 Table whose compliance statement is "Complies via Previous NRC Approval" without evaluating the impact on the documentation requirements for compliance. In addition, this appears to contradict the process described in Section 4.1, "Fundamental Fire Protection Program Elements and Minimum Design Requirements," of the HNP Transition Report, since there are now no submittal excerpts in the B-1 Table. Accordingly, please ensure that the formal RAI response corrects these issues in the B-1 Table. The NRC staff has identified the following affected B-1 Table elements:

3.3.5.1 No longer addresses the requirement for minimizing wiring above suspended ceilings.

3.3.5.3 Removed detail of and conclusion regarding UL 910 rated cables.

3.3.7 No longer addresses storage of gas cylinders in buildings.

3.3.7.1 No longer addresses storage of gas cylinders in buildings.

3.3.8 No longer addresses the diesel day tank.

3.3.12.(3) Flame arrestor detail now missing.

3.3.12.(4) Leakage point detail now missing.

3.3.12.(5) Drain line sizing detail now missing.

3.5.5 Fire pumps are not correctly identified as outdoors. The element now conflicts with a previous RAI response.

3.5.13 The details of the header arrangement and construction are now missing.

3.6.1 The details of standpipe classification are now missing.

3.9.4 The fire pump arrangement details have been removed.

2. The licensee seems to have erroneously changed the compliance strategy for part of B-1 Table element 3.11.3 from "Complies Via Previous NRC Approval" to "Complies."

Additionally, the NRC staff notes that the information related to prior approval remains in the element. Please ensure that the compliance strategy for this element is correct in the formal RAI response.

3. The NRC staff noted that the draft B-1 Table had not been updated to reflect the draft response to RAI 2-17(b). Therefore, the current versions of the following two B-1 Table

-3 elements are insufficient: 3.5.16 and 3.6.5. Please ensure that these elements accurately reflect all applicable RAI responses in the formal RAI response.

4. The NRC staff noted that the B-1 Table entries for elements 3.8.2, 3.9.1.(1), and 3.9.1.(2) have not been updated to reflect the response to RAI 2-2 and the draft response to RAI 3-70. Please ensure that these elements accurately reflect all applicable RAI responses in the formal RAI response.

5. B-1 Table element 3.3.8 references a submittal document from element C.5.a.(4). This appears to be incorrect, in that the text cited appears to come from element C.5.d.(4).

Please ensure that this discrepancy is resolved in the formal RAI response.

6. During its review of B-1 Table element 3.3.8, the NRC staff noted that the previous NRC Safety Evaluation Report (SER) explicitly approves the size of the diesel fuel oil day tanks on page 5-55 of the SER. It may be to HNP's advantage to reference this approval in B-1 Table element 3.3.8 as a part of the formal RAI response.

7. In B-1 Table element 3.3.5.1, the licensee provides submittal excerpts from the Branch Technical Position (BTP) comparison for BTP requirements C.5.a (11) [general plant areas] and C.7.b [control room], but only an SER approval section for the C.5.a (11) requirement. However, the NRC staff notes that there is an approval of the control room arrangement on page 9-53 of the same SER. If the licensee intended to include this approval in the element, the B-1 Table should be updated accordingly.

CLARIFICATION of HNP RAI 3-72 regarding Control Room Delta Risk The issue identified in RAI 3-72 deals with fire areas that previously utilized alternative shutdown strategies to comply with NRC requirements. The RAI focused on the Control Room since there are 10 recovery actions required when the Control Room is evacuated. Subsequent to the request, the NRC staff noticed that fire area 12-A-CRC1 also credits alternative shutdown and has 7 recovery actions required to be performed in the plant. The same issue and approach proposed for the Control Room appears to be applicable to the CRC1 fire area.

Accordingly, it would appear appropriate to add the 12-A-CRC1 fire area risk to the delta risk summary, as was done with the Control Room abandonment delta risk proposed in the RAI response. Please consider adding a discussion of this issue to the formal RAI response.

CLARIFICATION of HNP RAI 5-14.1 regarding Sensitivity to Cutting and Welding Fires Perhaps the supplemental request was unclear, but the proposed response to RAI 5-14.1 still does not give the specific values of nonsuppression probability for cutting and welding that were employed, only that the values were taken from the non-suppression curves for cutting and welding. These probabilities vary significantly based on the amount of available time, as indicated in the original RAI (nonsuppression probabilities for welding range from 0.38 with only 5 minutes available to 0.001 with 35 or more minutes available).

In the formal RAI response, please identify specifically which probability values were assumed, as the validity of the sensitivity analysis hinges on the validity of these values much more so than the bin ignition frequencies. Also, please re-perform the sensitivity analysis using either:

- 4 (1) a non-suppression value taken directly from NUREG/CR-6850, "EPRI/NRC-RES [Research]

Fire PRA Methodology for Nuclear Power Facilities" (i.e., without any relaxations); or (2) a nonsuppression probability 10x greater than what was assumed as the base case. If the results indicate significant variation, please provide the plant-specific basis for the relaxations.

CLARIFICATION of HNP RAI 5-33.1 regarding the Incipient Detection System From the original response to RAI 5-33, it appears that the sensitivity calculation applied the changes in the Very Early Warning Fire Detection Systems (VEWFDS) fault tree numbers to the Fire Probabilistic Risk Assessment (Fire PRA), substituting the numbers calculated for overall VEWFDS performance in place of the assumed numbers originally applied in the Fire PRA.

In the formal RAI response, please also address the following:

1. Was the same process (resolving the whole Fire PRA) conducted for the additional sensitivities performed for RAI 5 33.1?

2. That is, were there additional contributions to core damage frequency (CDF) arising from fire scenarios not involving VEWFDS that remained unaffected in both the original and follow-on sensitivity calculation such that the effect of the variation on the overall CDF and variance from deterministic (VFD)-delta-CDF would be less than that on just those scenarios involving VEWFDS, for which the effect would appear to be a doubling of their CDFs (and VFD-delta-CDFs)?

3. Is there any VFD where this doubling effect would affect the decision for the transition involving this VFD?

CLARIFICATION of HNP RAI 5-44 regarding Justification of Supporting Requirements (SRs) that Are Either Met or Capability Category (CC)-I The draft RAJ response for HNP RAI 5-44.a. states, in part, that "fire suppression and detection systems provided at the HNP facility have been installed in accordance with applicable NFPA Codes and Standards.... Fire protection and suppression systems are described and controlled, including compensatory actions when applicable, under procedure FPP-013, Fire Protection - Minimum Requirements, Mitigating Actions and Surveillance Requirements, thereby ensuring credited systems are operable during plant operations. Finally, the system availability is monitored as part of the NFPA 805 Monitoring Program ...."

In the formal RAI response, please also address the following:

1. When developing the HNP Fire PRA, what availability assumptions were used to model suppression and detection systems?

2. Did HNP use the generic availability values provided in NUREG/CR-6850, plant unique data, or a combination of both (e.g., Bayesian analysis)?

3. If HNP used generic values, is there plant operational experience that would suggest the use of lower availability values for any particular component or system?

C. Burton -2 The enclosure to this letter contains the clarification questions communicated to the licensee via electronic mail (e-mails) dated January 25, 2010, January 27, 2010, and January 29, 2010, as a result of the ongoing discussions described above.

Please contact me at 301-415-3178, if you have any questions regarding this issue.

Sincerely, IRAI Marlayna Vaaler, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

As stated cc w/enclosure: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrPMShearonHarris RidsNrrDraAfpb HBarrett, NRR LPL2-2 R/F RidsAcrsAcnw_MailCTR RidsNrrDorlDpr PLain, NRR RidsN rrDorlLpl2-2 RidsRgn2MailCenter RidsNrrDraApla SWeerakkody, NRR RidsNrrLACSola RidsOgcRp ADAMS Accession Number' ML100600987 NRR-106 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DORL/LPL2-2/BC(A)

NAME MVaaler CSoia SBailey for DBroaddus DATE 03/09/10 03/05/10 03/09/10 OFFICIAL RECORD COpy