ML110910464

Summary of Meeting with Tennessee Valley Authority to Discuss Watts Bar Nuclear Plant, Unit 2, Final Safety Analysis Report Related to Section 9.5.1 Fire Protection

ML110910464
Person / Time
Site:	Watts Bar
Issue date:	04/13/2011
From:	Justin Poole Watts Bar Special Projects Branch
To:	Tennessee Valley Authority
Poole Justin/DORL/ 301-415-2048
References
TAC ME3091
Download: ML110910464 (22)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Jipril 13, 2011 LICENSEE: Tennessee Valley Authority FACILITY: Watts Bar Nuclear Power Plant, Unit 2

SUMMARY

OF MARCH 29, 2011, MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING WATTS BAR NUCLEAR PLANT, UNIT 2, FINAL SAFETY ANALYSIS REPORT RELATED TO SECTION 9.5.1 FIRE PROTECTION On March 29, 2011, a Category I public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Tennessee Valley Authority (TVA) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the NRC staffs questions and comments on the Watts Bar Nuclear Plant (WBN) Unit 2 Final Safety Analysis Report (FSAR), Section 9.5.1 Fire Protection, in support of TVA's application for an operating license. A list of participants is included as. The meeting consisted of the NRC staff and TVA discussing the outstanding issues for the review of Section 9.5.1 to the FSAR. The NRC staff provided a draft request for additional information (RAI) that was discussed in detail to ensure the questions were fully understood by TVA. Based on this discussion, the NRC staff will make some minor changes to a few questions that will provide additional clarification for TVA. These changes will be incorporated into the final version to be issued. The draft RAI is included as Enclosure 2. The NRC staff and TVA also discussed TVA's RAI submittal and revision to the Fire Protection Report (FPR), both dated March 16, 2011. Due to the size of these documents and the relatively short timeframe, the NRC staff had not completed its review of these documents, but discussed what they had reviewed to this pOint. The NRC staff noted some administrative errors along with some changes that were mentioned in the RAI submittal but were not found in the FPR. TVA committed to correcting the FPR to ensure that all changes committed to in the RAI submittal will be found in the FPR. TVA mentioned to the NRC staff that they are in the process of designing plant modifications that would eliminate some of the current operator manual actions found in the FPR. The NRC staff encouraged this effort but warned that depending on the timing of completing these changes, it could affect the schedule of the FPR review. TVA agreed to keep the staff informed of the changes they intend to make and to have further dialog with the staff in future public meetings. There were two members of the public in attendance. Public Meeting Feedback forms were not received.

- 2 Please direct any inquiries to me at 301-415-2048 or stin.Poole@nrc.gov. Justin C. Poole, Project Manager Watts Bar Special Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-391

Enclosures:

1. List of Attendees

2. Draft RAI cc w/encls: Distribution via Listserv

LIST OF ATTENDEES MARCH 29, 2011, MEETING WITH TENNESSEE VALLEY AUTHORITY FINAL SAFETY ANALYSIS REPORT REVIEW SECTION 9.5.1 FIRE PROTECTION WATTS BAR NUCLEAR PLANT. UNIT 2 NAME TITLE ORGANIZATION Stephen Campbell Branch Chief NRR\\Division of Operating Reactor Licensing (DORL) Patrick Milano Sr. Project Manager NRR\\DORL Justin Poole Project Manager NRR\\DORL Robert Haag Branch Chief R-II\\Division of Construction Projects\\Branch 3 Alex Klein Branch Chief NRR\\Division of Risk Assessment (ORA) \\Fire Protection Branch (AFPB) Daniel Frumkin Sr. Fire Protection Engineer NRR\\DRA\\AFPB Charles Moulton Fire Protection Engineer NRR\\DRA \\AFPB Gary Cooper Fire Protection Engineer NRR\\DRA\\AFPB Scott Burnell Public Affairs Officer Office of Public Affairs

- 2 NAME TITLE ORGANIZATION William Crouch Manager, Licensing Watts Bar2 Tennessee Valley Authority (TVA) Steve Hilmes Manager, Electrical and Instrumentation TVA Charles Brush Contractor TVA David Savino Associate Producer NHK New York Hironobu Maeda Cameraman NHK New York

REQUEST FOR ADDITIONAL INFORMATION OPERATING LICENSE APPLICATION WATTS BAR. UNIT 2 DOCKET NO.: 50-391 TAC NO.: ME3091 Office of Nuclear Reactor Regulation Division of Risk Assessment Fire Protection Branch Note that while questions have been developed for anum parts of the Fire Protection Report (FPR), this is not an exhaustive list of The Fire Protection Branch expects that additional questions will be ae\\lelCUll progresses as well as following the as-yet undelivered complete as-,ae~

• A number of the information requests involve is indicated at the end of the specific requ that was submitted to luation Reports (SSERs) 18

process, pages of the FPR are so the individual pages in Revision 5 of sion 5".

n the submitted Revision 5 of the FPR i,...Hii:thj:, comment originates RAI FPR Genera A number of the pages in the supporting documents section of the "WBN Fire Protection Report Summary 6 thru 40" document are illegible. This document was submitted by TVA on December 20,2010 (ADAMS accession number ML110060493). One example is the section supporting FPR revision 39 on pages 390 through 408.

This term is not.;u~~ld'in the FPR. Discusstbe differences - 2 Ensure that an extent of condition review has been performed to ensure that other, similar instances have been identified and corrected. Provide legible versions for a/l pages of this document. RAI FPR 11-12 A change has been made to Part II, Section 12.10.S "Fire Dampers," of the as-designed FPR to delete a reference to electro-thermal links for fire dampers. TVA's December 18,2010 letter states that electro-thermal links are "not used in fire safe shutdown areas." It appears that this change was made between Revision 40 and~the;january 14, 2011 version of the FPR. The use of electro-thermal links for fire dampers was spec:ifically Define "fire safe shutdown areas". between "fire safe shutdown areas" and "safety~reiated areas". "?,<,,; <',<< "j'" <"'1: >.' t;~:\\:i~~~~}-' 'V,,;:;- _ '~~4~-:':'>: Provide the appropriate'Unit 2 inforr:pation. Ensure that an extent of condition review has been performed to ensureihat other similar instances are identified and corrected. This RAI may;~nvolve ~~;~~dattt~;'t~~F'PRt~'incorporate the response to the RAI. RAI'FPR 11-14 Changesnave been made to Part II, Table 14.10, "Fire Safe Shutdown Equipment," and to Part II, "Testing and Inspection Requirements (TIR)" table, element 14.10.e, of the as-designed FPR to eliminate the.entries for the Component Cooling System (CCS) Pump 2B-B. This piece of equipment is credited in numerous Analysis Volumes in Part VI. Examples include, but are not limited to: AV-023,AV-02i4, and AV-OSO. This change also affects Part II, Section B14.10.e. It appears that this change was made between Revision 40 and the January 14, 2011 version of the FPR. Resolve the conflict that equipment relied on in Part VI is not included in Table 14.10 and the TIR table. Ensure that an extent of condition review has been performed to ensure that other, similar instances have been identified and resolved.

v

~{;'

RAI FPR 11-13 >.:<~ 'r-< /_ c,', "/,<" Part II, Section 14.3.1.b.1 of the FPR descr.ibes UnItJl~,sp~cific operating requirements for water based suppression systems;;in;.tme Unit 1 reactor building,..,;No,U,nit 2 information is included, however. Section B.14..3:;1.;indicates that this*se.cti ..*.on should'beapplicable to both Units.

- 3 This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 11-15 A change has been made to Part II, Table 14.1 "Fire Detection Instrumentation" of the as designed FPR report that deletes the Auxiliary Building detection zone 147 entry. It appears that this change was made between Revision 40 and the January 14, 2011 version of the FPR.,~\\:~. Provide a summary evaluation and technical justification supporti~g';this change. ,:~,~,~~~~~;~~%~::~,1~*i:i1~~1~~'.:: This RAI may involve an update to the FPR to incorporate ttleiesponseto the RAI. \\~l:' " \\'~~,;r'L,"~.. RAI FPR 11-16 J>,,':', \\ v "'h A change has been made to Part II, Table 14.1 "Ff~Detection'tl\\lstrumentation" ofthe as designed FPR report that creates an entry for zone't4~3uUnitt2~Motor Driven AFW Pumps". While the other entries in the Table exhibit a remarkable.;Uoif-1/Unit 2" mirroring, in this case, there does not appear to be a corresponding Unit 1 zone'. It appears that this change was made between:Revision 40 andlhe January 14, 2011 version of the FPR. Confirm that the number:of:deteetors listed in Table 14.1 is "'f'\\,-rO/~t for zone 413, and discuss the possible discrepancy~ This RAI may invol~e~an update to,the FPR to incorporate the response to the RAI. A ct:lange has been mac:teto Partll,.Table 14.1 "Fire Detection Instrumentation" of the as designedFPR report that creates an entry for zone 153 "Add. Eqpt. Bldg., U2 EI763.5". In general,'theentries in Part fl,Table 14.1 "Fire Detection Instrumentation" of the as-designed FPR report exhibit a remarkable "Unit 1/Unit 2" mirroring. However, in this case, the added Unit 2 entry notes 4 smoke detectors, while the corresponding Unit 1 entry (zone 154) has 6. It appears that thischangewas made between Revision 40 and the January 14, 2011 version of the FPR. Confirm that the number of detectors listed in table 14.1 is correct for zones 153 and 154, and discuss the possible discrepancy. This RAI may involve an update to the FPR to incorporate the response to the RAI.

Ensure that an extent of condition review performed to ensure

~t(i'}~t'.

.,it; - 4 RAI FPR 11-18 A change has been made to Part II, Table 14.8.2 "Fire Dampers" in the as-designed FPR in the entry for damper 2-ISD-31-3872. The entry was changed to indicate that the damper lies between rooms 713.0-A29 and 737.0-A8 rather than 737.0-A9 and 737.0-AB. This is in conflict with the entry in Part VI, Section 3.19.4, of the as-designed version, which aligns with the unchanged description of the fire damper location. It appears that this change was made between Revision 40 and the January 14, 2011 version of the FPR. Resolve this conflict. that other, similar instances have been identified and reS,OI\\l'eo This RAI may involve an update to the FPR to incorporate RAI FPR 11-19 A change has been made to Part II, Table 14.B.2 "Fm:~Dampe~s" in the as-designed FPR in the entry for a 3 hour rated damper between rooms 772.0'-'A:1:and772.0-A7. The entry was changed to indicate that the damper is:tated for 1.5 hours.:'~Additionally, the damper identification number was changed frorri,~'~ISD:"'3J-2516 t01:':1SD-31-2561. This change is in conflict with the entries in Part VI [pp. VI-583 aridVl~626 of U"ie.:January 14, 2011 version] which aligns with the unchanged version. "::,;'r~~",. I". ~>'~),:, ~ \\: : -;;~~~~~~~- \\{';\\:~~'~\\;',> It appears that this change,wastmade between Revision 40 al1dthe January 14, 2011 version of the FPR. [~,!'.~ ~!" ;;.~~:~ Resolve this conflict..~~Ensure thatan?:extent of condition review has been performed to ensure that other, similar instances have*;*been;identified and,resolved. "'~'"' (, '{ ~7 +:--+:_ ',';-.,c:>'< '-"'-'~~';~>~;'o';~' _ f';" This RAlimay?fnvolve;an update to the FPR tO'lncorporate the response to the RAI. RAI FPRII-20 ReferencesA2.19 "WBPE-026-920B002 -Appendix R -High Pressure Fire Protection Cable Separation Analysis" and 4.2.21 "WBPE063201005 -Appendix R -Safety Injection Analysis" that were included in Revision 5 of the FPR appear to have been deleted from the FPR Part II reference list in Revision 10. Describe, at a high level, where the information that was formerly located in these documents currently resides. This RAI may involve an update to the FPR to incorporate the response to the RAI.

5 RAI FPR 11-21 A change was made to Part II of the FPR, after Revision 5, to add the following to the definition of "Operable-Operability": Equipment being tested does not need to be declared inoperable provided appropriate manual actions by the test performer, stationed at the test location, are addressed under written procedures. The written procedures must provide the ability to recognize input signals for action, ready recognition of setpoints, design nuances that may complicate subsequent manual operation such as auto reset, or other functions which are inherent to the fire protection system. >~.~~~~~~T' It appears that this change was made for Revision 7 of the FPR::H;c;\\~;;:;;: Provide a summary evaluation and technical examples of equipment where this would apply, and This RAI may involve an update to the FPR to Inrr.rr,r. RAI FPR 11-22 thiscbange. Also provide of equipmentwhere it would not. A change was made to Part II of the FPRt6delete the definition of "Regulatory Required." It appears that this change was made for Revislon7,":Qf*the FPR~The deleted text is as follows: ,; ;:i~ :--::' u, -- ---s'" ,v ":::~~:1;~~.~.;.'" ~~_:';:Z--__ Regulatory Required.i;:--(BEG) Refers.to;theJireprotectionsystems or features which are requir~d;t('):iQemor;lstrate c6mpli~;ince with NRC regulations. It also refers to those.,frreprotection systems()r.~features not required to demonstrate direct compliaflce with NRC regulations;.hqwever, specified commitments documented'1n',this FPR have-been made relative to the fire protection system or feature making1:~esystetll;o.-;feature r.equired to demonstrate compliance. [Emphasis.addedJ'tj>~,:*:;/ -i_ - -:z ,) ~;iii:V:,:: /:;';:.-

~'

b-;t::-:

Describe:what was meant by"those fire protection systems or features not required to demonstrate direct compliartce with NRC regulations" in this context. Describe, at a high level, the "specified commitments.cl0cumented in this FPR" This change'appears to remove a population of fire protection systems and features (those that had commitments documented in the FPR) from the list of fire protection systems and features required to demonstrate compliance. Provide a technical justification for this change. Also, provide a summary of the differences in maintenance, testing, surveillance, etc., for those fire protection systems and features that are required to demonstrate compliance versus those that are not required to demonstrate compliance. RAI FPR 11-23 A change was made to remove the following text from Part II, Section 7.1, "TVA Corporate Management," of the FPR, after Revision 5:

A change was made to remove the description d~:;t~e fire proteciion training nrr\\\\lIr,en as part of - 6 The General Manager, Operations Services, establishes fire protection programs and fire brigade training and qualification requirements and assesses their effectiveness. Agreements are maintained between the TVAN and TVA Fossil and Hydro Power organizations for providing training and qualification of fire brigade and Incident Commander personnel. It appears that this change was made in Revision 10 of the FPR. These elements were specifically approved by the NRC in SSER 1 Describe where these responsibilities currently reside. This RAI may involve an update to the FPR to incorporate tnE!~Te~SDOn~;e:1to RAI FPR 11-24 general employee training from Part II, Section 7.8;ii~;Site Personnel," of the FPR. It appears that this change was made)I1:Revision 10 of Provide a justification of this change and des2~ibewhere this illformation is maintained. This RAI may involve an u~d.l:lte.to the FPRto incorporate the{esponse to the RAI. ,;. /t~:,t'd~>-";:~~~; ~,i; :/ RAI FPR 11-25 ",{< ~~ >~I~:>."",<* Several changes wer~imade toe,art:II,Section 8.1,~Program Changes and Associated Review and Approval,,~;;.oft~e FPR. ~,<':{,'~~:t '~:'::;:;"f::~{':' ~;+T'

1. Reference to PlantQperations Review Committee review of changes to the FPR was removed from 8.1.a.

2. A reference to "10 CFR '50.59" was replaced with "plant specific procedures" in 8.1.b.

3. The following text was removed from 8.1.c:

WBN may alter specific features of the approved Fire Protection Report provided: (a) such changes do not otherwise involve a change in a license condition or the technical specification or result in an unreviewed safety question, and (b) such changes do not result in failure to complete the Fire Protection Program as approved by NRC. All of these changes affect elements that were specifically approved by the NRC in SSER 18. It appears that these changes were made in Revision 27 of the FPR. Provide a justification for each of these changes.

- 7 This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 11-26 A change was made to Part II, Section 8.3, "Audits/Inspections of the Fire Protection Program," of the FPR to remove a description of the "system of audits to be conducted to assess the WBN fire protection equipment and FPP implementation to verify continued compliance with NRC requirements and TVA commitments." ,~~~" The description matched that provided in NRC Generic Letter 82-;2~'":~echnical Specifications for Fire Protection Audits," and was specifically approved the,JrsJ;R.Cin SSER 18. \\~~~~~~'~A This description was replaced with the statement that "the,audit prograni.is(provided in the NQAP [Nuclear Quality Assurance Plan].",ji>;: '.~:::,:, A,'>'> ~~{ '~".' \\~~;:,~, It appears that this change was made in Revision~1'9;~f the FPR.i;~Jc;;i:'i '<" ;!:~~~l~;;~;'; /~;f':Y;~~l; ~~~~~,~:;:::: Confirm that the audit program described and maintair;:led il}*tt:le~NQAP document aligns with the program previously described in the FPR and approved..by'the NRC. Otherwise, justify any changes. RAI FPR 11-27 SSER 18 specifically refere~cesthe "Shift OperatloAs fire brigade. Howeve~ta:change was.made to~art II, Section 9.1 of the FPR to replace references to "Shift"Qperations Supervisor" with;"Shift Manager." in the evaluation of the WBN It appears that this ch*~i,gewasm~de.4n:RevisiontO.of the FPR. responsibilities, duties, etc., between the two positions. RAI FPRII-28 Part II, Section 12.1, "WaterSupply," of the FPR contains the following text: The water used in both the HPFP [High Pressure Fire Protection] and RCW [Raw Cooling Waterlsystem is chemically treated to address concerns resulting from the use of raw water. A three-year evaluation period is being implemented to monitor the performance of the HPFP System. Periodic testing of the HPFP distribution system will be performed once a year for the first three years of plant operation. The results of the monitoring program will evaluate the adequacy of the existing fire suppression systems for testing frequency or possibly replacement plans. SSER 18 describes a TVA commitment to continue this testing on a periodic basis.

- 8 Describe how the results of the initial testing period modified the testing frequency and replacement plans for the fire suppression systems. Describe the current monitoring and testing programs related to these topics (that is, the use of raw water and concern over microbiologically induced corrosion and other biological fouling). This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 11-29 A change was made to Part II, Section 12.10.4 "Fire Doors," of theFF>R to remove a discussion of the process in place to perform fire door modifications. It appears that this change was made in Revision 10 of Discuss the processes in place for fire door modificatiqn,!*.or justify the removal of this information from the FPR This RAI may involve an update to the FPR to incorporate the/response to the RAL RAI FPR 11-30 Are the time studies that support the continuousfirezwatch Part II, Section 13.0.A "Fire Watch - Continuous [Primary]," of the FPR!maintained aUhe WBN.s~te in an auditable form? If so, please provide the appropriate references. If not,!justify~why not This RAI may involve,amupdate to;the FPR to.incorporate the response to the RAI. RAI FPR 11-31 Part II, Section 13.0 ~Fire Protection System Impairments and Compensatory Actions," of the FPR states, in part: Impaired fire protection systems or features will be returned to operable condition in the time frame specified in the OR sections. Should this restoration not be done,a 10 CFR 50.72 and 10 CFR 50.73 review shall be performed and documented in accordance with site administrative procedures. Similar statements exist throughout Part II, Section 14 "Fire Protection Systems and Features Operating Requirements (OR)." A typical example is found in Section 14.9.2: Restore the inoperable emergency battery lighting unit to Operable status within 14 days. If not restored within 14 days, continue the compensatory actions AND perform 10 CFR 50.72 and/or 10 CFR 50.73 reviews per site administrative procedures. Describe how performing the 50.72 and 50.73 reviews and making an appropriate report, as needed, assists in returning a system or feature to operable status. Once any necessary report has been made, what is the path to operable status? What actions are to be taken for systems

status? - 9 or features that are not in operable status for extended periods beyond those outlined in Part II, Section 14? What actions are to be taken to restore the system or feature to operable status if the 10 CFR 50.72 and/or 10 CFR 50.73 review determines that no report is necessary? RAI FPR 11-32 A change was made to Part II, Section 14.2 "Water Supply," of the FPR to add Section 14.2.7 which deals with not as-designed loads or inhibited automatic isolation capability on the water supply system. ,gI ..~.,~;::':;;/:.. It appears that this change was made for Revision 7 of the FPRard>expanded in Revision 10. Provide a technical justification supporting this change.

Also, What is the timeframe for providing isolation;capability (14.2.7.a)? What action is to be taken if this cannot be accomplished?'<"\\;

<{' /~C{';,; A);;,~~~~:,L;

• • ' ",J t:

What is the timeframe for completing 14.2.7.b actiohsr(controlling the inhibited automatic isolation by procedure)? What actionisto be taken ifthis cannot be accomplished? ',J~..,. ' Identify and discuss the long term compensatory'measurestobe put in place if the operability time period in 14.2.7.c is missed. In this scenario, onceany"necessary report'hasbeen made, what is the path to operable FPR to incorporate the response to the RAI. A change was made to Partll, Section 14.2 "Water Supply," of the FPR to add Section 14.2.8 which'deals with fire pumpautomatlc'start impairments. Section B.14.2.8 appears to indicate that this section is intendedtocover maintenance and testing. A 30 day period of allowed inoperabilityisinconsistent with maintenance and testing. It appears that this c~a,nge'was made for Revision 27 of the FPR. Provide a technical justification supporting this change, including the duration of the allowed non-operability.

Also,

• What is the timeframe for 14.2.8.a (controlling the inhibited automatic start circuitry by procedure)?

- 10 Describe the long term compensatory measures to be put in place if the operability time period in 14.2.8.b is missed. In this scenario, once any necessary report has been made, what is the path to operable status? This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 11-34 There are a number of conflicts and inconsistencies between Part'll;Section 14.2 "Water Supply" and the "Fire Pump Inoperability and CompensatoryeJf.ctions~Table of the January 14, 2011 version of the FPR. "\\~11'~

• What is the time period for implementing the actions;*in the "Planned VU'LCl"'I~

Table? Also, the "planned outage" concept isnotreflected in the text '~~f"~'i~: " \\::i:',;;s

• The "14.2.1.c" column in the Table does not alignwith the actions described ihthe text of 14.2.1.c.

<n:'

• The "14.2.4.a" column in the Table does not align with the actions described in the text of 14.2.4.a.

14.2.5.b.

• There is no discus~i&rl~in thL.f~jctonb~.removing backup steps identified in columns "14.2.5.a"and*"14. 3.5J5":of.the Table.

--{":~:;I\\'~' ~ <~i'5ts':", ""Y~' '\\,:-':~:; Resolvethese conflict~. This RAlmay involve an update to theFPR to incorporate the response to the RAI. RAI FPR 11-35' Part II, Section 14.8.'1 ofthe as-designed FPR states: If suppression (as listed in Section 14.3 and 14.4) and fire detection (as listed in Table 14.1) is designed to protect both sides of the inoperable barrier, then no compensatory actions are required. Part II, Section 14.8.2 states: Restore the inoperable fire-rated assembly/fire barrier to Operable status within 30 days. If not restored within 30 days, continue the compensatory actions AND The "14.2.5.a" column in the Table does,not the acfions described in the text of 14.2.5.a. The "14.2.5.b" cohimnin the does ndfalign with the actions described in the text of

inoperable barrier, provide a justification of why suppression alone would be - 11 perform 10CFR50.72 and/or 10CFR50.73 reviews per site administrative procedures. Also determine if any continuous fire watch routes are to be augmented as specified in Section 13.0.A. The following questions relate to a scenario concerning an inoperable fire rated assembly falling under 14.8.1.c which enters 14.8.2. Describe the long term compensatory measures to be put in place if the operability time period in 14.8.2 is missed based on entry from 14.8.1.c. If no additional compensatory measures would be needed beyond suppression and detection sides of the sufficient for an extended period (beyond 30 days). In this scenario, once any necessary report has been status? This RAI may involve an update to the FPR to RAI FPR 11-36 Is it TVA's position that one hour fire rated~~lectrical racewayJire barrier systems (ERFBS) (which normally require suppression and detection systems to also be installed) fall under Section 14.8.1.c? If not, describe which'sectiol1of14:.8.1 would:apply. If so, justify the equivalence of the two configurations: detection plu~s~ppression'fpll:ls a one hour rated ERFBS vs. detection and suppression;only in terms of mairitainingctefense in depth and safety margins. <',',', c"-':>-';,',; This RAI may involvean.update ta'the FPR to.incorporate the response to the RAI. RAI FPR 11-37 A change'was;madeto Part 11,' Section 14.1.2 onhe FPR to change the applicability of this section~from inaccessibJeareastocontainment. Section B.14.1.2 supports the original version. It appears;that this change.was made in Revision 10 of the FPR. Resolve this conflict If the change is correct, provide appropriate sections that provide the requirementsfor*inaccessible*areas outside of containment and the associated bases. This RAI may involve.an update to the FPR to incorporate the response to the RAI. RAI FPR 11-38 Part II, Section 14.2 "Water Supply," Note 2, of the FPR states, in part: "Section 14.5 is not applicable to the diesel driven pump control panel (e.g., 0-PNL-26-3150A)." Describe the requirements that apply to this panel in lieu of Section 14.5. This RAI may involve an update to the FPR to incorporate the response to the RAI.

- 12 RAI FPR 11-39 A change was made to add Part II, Section 14.10.2, to the FPR: With one or more of the breakers and/or valves specified in design output documents not in the noted position or condition, return the breakers and/or valve to the required position within 30 days. It appears that this change was made for Revision 7 of the FPR and clarified in Revision 15. Describe the compensatory actions to be taken in the 30 days between the discovery of the condition and the return to operability. "1""i,;. This RAI may involve an update to the FPR to incorporat~the response to t~e RAI. RAI FPR 11-40

~ i Discuss the interaction and interface between the OperabilityHequirements and action statements in Part II, Section 14 "Fire,ProtE~ction Systems.and Features Operating Requirements (OR)," of the FPR and the

Corrective Action Program (CAP) at WBN. Include in the discussion the point at which an item

~lNould be<Cidded to the CAP.

,,<{" <): 1(' ' This RAI may involve an updat~:to the FPRt() incorpo~;t~.the response to the RAI. RAI FPR 111-5 Part III, Section 1.1, "Design Basis E",Clluation," ofthe FPR states: "Loss of offsite power has been assumed*for controlbuildingfires;"forwhich alternative shutdown is provided." The FPR, Part I, Section 2.0, "pur:pose", states "The FPR documents WBN's Appendix R evaluation which ensures that safe shutdown capability can be maintained during and after a fire in accordance with Sections JlI.G,dII.J, JlI.L and 111.0 of 10 CFR 50, Appendix R." 1 0 CFR 50, Appendix R (Appendix R), Section III.L.3, states: The shutdown capability for specific fire areas may be unique for each such area, or it may beone;unique combination of systems for all such areas. In either case, the alternative shutdown capability shall be independent of the specific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours. Procedures shall be in effect to implement this capability. Confirm that the safe shutdown analysis, for alternate shutdown, addresses conditions where offsite power is available and where offsite power is not available for 72 hours. Also, confirm that procedures are in effect to implement this capability.

- 13 Provide a summary evaluation and technical justification for any fire areas that affect Unit 2 post-fire safe shutdown equipment and do not meet the above Appendix R criteria. This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 111-6 Part III, Section 3.4.2, "Reactor Coolant Make-up Control," of the FPR states: "Reactor coolant make-up is available immediately post-reactor trip, except for a few fireAocations where it is available within 75 minutes post reactor trip." ~,~;,~: Identify the Unit 2 safe shutdown fire areas where reactor cool~~£make-up is not available immediately, but is available within 75 minutes post reactoptrip. Confirm that the statement in Section 3.4.2 remains valid for Unit 2 and confirm that not,having reactor"coolant make-up available immediately will not have an adverse affecLorhtJnit 2 post-fire safe$hutdown. This RAI may involve an update to the FPR to incorporate the response to the'RAI. "'7,' RAI FPR 111-7 "{ r:~~;~ >,.-~ Part III, Section 3.4.3, "Reactor CoolanfPressure Control, ';~~ f::~'~ '-'. ~j~--7'~i1>: ~ Establishing and maintaining a sufficient s'ub:"coOling marginwithin the RCS is required to prevent void/formation in;the cor.eandtoensure the ability to maintain natural circulatior:liKif;theiRC,Ps are nofoperable) through the steam generators (SG). This is essential to acFiieving and,{'llaintaining safe shutdown. [emphasis added] FPR Part III, Section 2.'3f.fJ~eactor:COolal1tPressureControl," states, in part: "Reactor coolant pressure control*is requir~(ltito;'~ssure'thaftheRCSis operated: [... ] (3) With a sufficient sub cooling margin'tominimize void formation within the reactor vessel." [emphasis added] Provide a technical justification that resolves the apparent conflict between the statements "prevent void formation in'the core" and "minimize void formation within the reactor vessel". This RAI may.involve an update to the FPR to incorporate the response to the RAI. RAI FPR 111-8 Part III, Section 4.10.4, "125V DC Power System," of the FPR states: During normal operation, the 125V dc loads are fed from the battery chargers, with the batteries being supplied a 'trickle' charge floating on the system. Upon loss of ac power, the entire dc load is drawn from the batteries. The batteries are credited for two hours of operation after a loss of charging, predicated upon the continued operation of dc emergency equipment. However, the battery chargers can be manually aligned to alternate power sources to take over the load and recharge their associated battery.

- 14 Confirm that the basis used for crediting the batteries for two hours of operation after a loss of charging, considered potential fire induced faults on cables and equipment connected to the battery. This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 111-9 Part III, Section 4.14, "Auxiliary Control Air System - Key 13," of theRPR states, in part: The ACAS air dryers operate continuously during norm£t:?ii~tation. The dryers are dual stage regenerative types which operate autd~atically,'~at"ld independently of their respective compressors. [... ] The electricalcircuit is deslgnE;d with interlocks that prevent a purge exhaust valve~nd~an inlet switchin@~¥~lve on the same side of the dryer to be open at the sameitime. This precludes iosslof air from the system through the purge valve,<~{c;," "r Y-r_~ '-_~V_:}~;-" ,>-:5~~::-:~_ Confirm that fire damage to the electrical interlockeircuits forc'tbekACAS air dryers will not prevent the equipment from performing its safe shutdown~fl.Jnction in fire areas where it is c required.. } ,::)~, nC()rDIDrale th'~'TE!SPOnSe to the RAI. RAI FPR 111-10 Part III, Section 6.0.~ldentification ofSafe Shutdown Circuits and Cables," of the FPR states: "However, for some equipment, e,ither a subset ofcables or no cables were identified. For example, cables were notselected 'forvalves where'local manual operation is required during cooldown and,'nitrogen bottle:control stations are used for AFW flow controL" _t?"~::;t~:~i.t([:-~;l-~~;~{:;~t>j!-;;~:-!J:-._-, _ Define'theterm "cooldown". Also,. categorize the above identified manual operator actions as hot or.cold shutdown. This RAtrilay involve an update to the FPR to incorporate the response to the RAI. RAI FPR 111-11 Part III, Section 7.3, "Associated Circuits by Spurious Operation," of the FPR states: The evaluation of Appendix R events ensures that any failure of associated circuits of concern by spurious operation (Type II) will not prevent safe shutdown. Credible electrical faults considered in the analysis included open circuit, short circuit (conductor-to-conductor), short to ground, and cable-to-cable (hot-short) including 3*phase hot shorts for high/low pressure interface valves. [emphasis added] Appendix R, Section III.G.2, states:

- 15 Except as provided for in paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided: [emphasis added] Appendix R addresses hot shorts, open circuits and shorts to ground,(cbut the FPR addresses these items in the singular tense as open circuit, short circuit (condLictor-to-conductor), and short to ground. Confirm that the fire induced circuit analysis methods in meet"the requirements of Appendix R, Section III.G.2 for fire areas containing Unit2 safe shutdowrvequipment. This includes circuits (plural) that could prevent operation oncause maloperaticmdue to hot shorts, open circuits, or shorts to ground. Provide a summary i8valuation and technicaldustification for any circuit analysis methods that do not meet these"criteria. This RAI may involve an update to the FPR to incorporate the1response to the RAI. RAI FPR 111-12 A change has been made to Part III, Section 10.1, "Overview of Evaluation Methodology," from revision 5 of the FPR to thecasid~signed FPR*thaLchangesthe,text from: The resolutions:may con;i~t.'of modifications, use of alternate equipment, manual operator actions, fire barrienil1stallation:'~pre-fire actions, post-fire repairs, engineering' evaluations pr:epared in accordance with the guidance of Generic Letter 86-10, ordeviationlrequests.;[emphasis added] ~. ~';'::"t'At::<:>(' ~:~;,:;,~~::::,:,,: i-"-,, ",'I",~,;:' to: The resolutions may consisiof modifications, use of alternate equipment, manual operator actions, fire*.barrierand radiant energy shield installation, post-fire repairs, engineering.evaluations prepared in accordance with the guidance of Generic Letter 86-10, or deviation requests. [emphasis added] Provide a technical justification for the change from "pre-fire actions" to "radiant energy shield installation. " This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR 111-13 Part III, Section 4.7 "Component Cooling System (CCS) - Key 1 S," of the as-designed FPR contains the following sentence: "The CCS system provides cooling for the following safe shutdown equipment in Unit 1:".

- 16 Is this sentence correct, or is the text intended to cover both units? If it is correct, provide the Unit 2 information. If it is not correct, correct the text. Ensure that an extent of condition review has been performed to ensure that other, similar instances have been identified and corrected. This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR IV-1 Part IV, Section 3.0, "Alternate Control Room Capabilities," of tpe:FPR states "The instruments and controls located in the ACR are separated from, or can be;ele'cit~~cally isolated from, the corresponding instrumentation and controls located in the MeR" ":ti~i~:> ,,-l:? ~;~~,;'~':A\\~) Describe the specific methods used to analyze and l11it1gate fire damage~fQ~Cir:cuits that could prevent operation or cause maloperation due to ha~slmrts, open circuits or shorts to ground, prior to the transfer of control to the auxiliary contr:oHroom (ACR). This includesFfire induced spurious operation of equipment, including spuriou$.~perationslhat can cause equipment damage, system actuations such as ESFAS and greUQd faultslon circuits of equipment to be controlled at the ACR. Also, describe the method used~o,ebsure the safe shutdown capability will not be adversely affected by the oneworst case spurious actuation or signal, resulting from . the fire, before control is transferred tothe;ACFt '; ~~{l;;h"{;,;~P(':l" This RAI may involVe an update to the FPRto incorporate the response to the RAI. ,vi:~t;~:;}~> <~v,v" RAI FPR IV-2 Part IV, Section 3.3,£~*lnstrumentsand Controls Required for Alternative Shutdown not in the ACR," of the FPR states: /.>:~~X ~,, ;'j,'~ _wi'" J::J:L','>;/<! ,J,) ThEfabbve'instrumentBtlon and controls 'are well in excess of that detailed in IE

• lnformationNotice 84-09:/T:here are also numerous local indications and controls

.... available to the operators:outside the ACR which provide additional information and control which were not included in the above listing. Confirm that the indications and controls outside the ACR are independent of the control building. If notindependentofthe control building, describe how the operators ensure that the instruments are providing accurate information and that the controls will function properly and not cause additional problems that may not be covered by procedure. This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR IV-3 Part IV, Section 3.3 "Instruments and Controls Required for Alternative Shutdown Not in the ACR," of the as-designed FPR contains the following sentence: "The number in () is the number available for Unit 1 shutdown."

performing manual actions are dispatched from,the main control roomJor fires in - 17 Is this sentence correct, or is the text intended to cover both units? If it iscorrect, provide the Unit 2 information. If it is not correct, correct the text. Ensure that an extent of condition review has been performed to ensure that other, similar instances have been identified and corrected. This RAI may involve an update to the FPR to incorporate the response to the RAI. RAI FPR V-11 ,I ~'".',',J,' Part V, Section 2.1.2, "Operator Locations Prior to Initiating Manual';Actions and t=O Definition," of the FPR states: For the purposes of developing the safe shutdowlJrProcedures, most plant locations, or from the Auxiliary Control Room for Control B~ilding fires. The basis for dispatch locations is that the;,operators must obtain the operator-specific safe shutdown procedures from these locations;~~~,* This section also states: "The time requirements for completion of manual operator actions are based on defining the initiating time t =D:as the time when"the reactor is tripped from the Main Control Room (MCR)." Confirm that using this definition of t=O for,fire areas:containing Unit2 safe shutdown equipment will ensure that safe shutdown capability can be maintained during and after a fire in accordance with Appendix;~RfSections 111.G,and.illl:L. This RAI may involve. an update to the FPR to incorporate the response to the RAI. RAI FPR VII.,2~ Part VU,'Section 6 "General Engineering Evaluations," was added to the FPR after the WBN FireProtection Program was approved by the NRC in SSER 18. Probabilistic risk assessment (PRA) information is utilized throughout this section of the FPR as one element supporting the safety conclusions of the engineering evaluations the section contains and in some casesappears to be an important justification. It is the NRC's positionthatlicensees with a deterministic fire protection licensing basis cannot rely on risk information for their safety conclusions. Risk information may only be relied upon as part of a risk-informed licensing action request, not as part of the traditional fire protection self approved engineering evaluation process. Provide updated versions of the engineering evaluations in this section of the FPR that do not rely on or reference PRA information. Otherwise, provide further justification regarding the acceptability of this use of PRA information. This RAI may involve an update to the FPR to incorporate the response to the RAI.

' ML110910464 OFFICE LPWB\\PM LPWB\\LA NRR\\AFPB\\BC LPWB\\BC NAME ,IPoole BClayton AKlein SCampbell DATE 04/04/11 04104111 04/12111 04/13/11}}