ML113540334

Supplement to License Amendment Request (LAR) 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

ML113540334
Person / Time
Site:	Fort Calhoun
Issue date:	12/19/2011
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LlC-11-0130, TAC ME7244
Download: ML113540334 (5)

Text

Omaha Public Power District 444 South 16'h Street Mall Omaha, NE 68102-2247 LlC-11-0130 December 19, 2011 u.s. Nuclear Regulatory Commission ATTN : Document Controll Desk Washington, D.C. 20555-0001

References:

1. Docket No. 50-285

2. Letter from OPPD (J. A. Reinhart) to NRC (Document Control Desk),

License Amendment Request 110-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated September 28, 2011 (LlC-11-0099)(ML11276A118)

3. Teleconference between NRC (L. E. Wilkins, et. a!.) and OPPD (J. L.

McManis, et. a!.), Request for Additional Information for Acceptance of License Amendment Request Re: Fort Calhoun Station NFPA 805 Transition, December 6, 2011

4. Letter from NRC (L. E. Wilkins) to OPPD (David J. Bannister), Fort Calhoun Station, Unit No. 1 - National Fire Protection Association Standard 805 License Amendment Application Onl'ine Reference Portal (TAC No.

ME7244), dated December 13, 2011 (NRC-11-0134)(ML113260423)

SUBJECT:

Supplement to License Amendment Request (LAR) 10-07, Proposed Changes to Adopt NIFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station In the Reference 2 license amendment request (LAR), the Omaha Public Power District (OPPD) requested an amendment to Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No.1, to adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition). Implementation of the regulatory actions presented in the attachments to Reference 2 wi" enable FCS to adopt a new fire protection licensing basis which complies wit'h the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide 1.205, Revision 1.

Employl/lem with Equ(/l Opporlllllirv

U. S. Nuclear Regulatory Commission LlC-11-0130 Page 2 During the conference call held with the Nuclear Regulatory Commission (NRC) staff on December 6, 2011 (Reference 3) , the staff provided OPPD with questions necessary for the NRC to complete its acceptance review of the NFPA 805 application (Reference 2). The NRC requested that OPPD submit a supplement to Reference 2 with the responses to the NRC's questions.

OPPD's responses to the NRC's questions are provided in the attachment to this LAR supplement. The documents necessary to support OPPD's responses to the NRC's questions are available on the FCS online reference portal. As described in Reference 4, this allows the NRC staff and its contractors limited read-only access to these documents.

In accordance with the terms and conditions of Reference 4, the online reference portal is password-protected and passwords will be assigned to NRC staff directly involved in the review on a need-to-know basis. The online reference portal will be sufficiently secure to prevent NRC staff from printing, saving, or downloading any documents; and conditions of use of the onl,ine reference portal will be displayed on the log-in screen and willi require concurrence by each user.

There are no regulatory commitments being made in this letter.

If you should have any questions regarding this letter, or require additiona ~ information, please contact Mr. Bill R. Hansher at 402-533-6894.

.rBa~er Vice President and Chief Nuclear Officer DJB/BJVS/dl l1

Attachment:

OPPD Supplement to License Amendment Request 10-07 c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

LlC-11-0130 Attachment Page 1 OPPD Supplement to License Amendment Request 10-07 As discussed in the December 6, 2011, teleconference, the Nuclear Regulatory Commission (NRC) staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its acceptance review of the National Fire Protection Association (NFPA) 805 transition license amendment request (LAR) (Reference 1).

NRC Request #1:

It is unclear when the last full peer review occurred on the Internal Events Probabilistic Risk Assessment (PRA) and the wording in the LAR and information is insufficient to determine what facts and observations (F&Os) were carried forward or submitted to the NRC.

Action 1: Provide the date of the last full peer review and the F&Os from that full scope peer review and subsequent focused peer reviews and their disposition.

OPPD's Response to Request #1 :

The last full peer review on the Internal Events PRA was completed in March 1999.

Attachment U, page U-2 of the OPPD NFPA 805 transition LAR dated September 28, 201' 1 (Reference 1), was revisited and it was determined that by today's standards, the October 2001 and August 2003 reviews would be characterized as an "independent review" in lieu of a "peer review." In addition, the February 2006 review would be characterized as a focused "deltas assessment" in lieu of a focused "peer review." The remaining "reviews" would remain as delineated in Reference 1, Attachment U, page U 2.

Please note that the LAR language comes from CFTC-11-95 (Reference 2); and the purpose of CFTC-11-95 was to document the ASME/ANS RA-Sa-2009 roadmap and peer review history for the Internal Events PRA and the Fire PRA of FCS. OPPD understands the NRC is requesting that the review terminologies used in the LAR (page U-2) be further explained. CFTC-11-95, which provides the explanation of the review terminologies used in Reference 1, contains the history of the reviews, F&Os, and their resolution . CFTC-11-95 is available for NRC review on the FCS online reference portal, which has been established for the NFPA 805 transition LAR review process, in accordance with the terms and conditions delineated in Reference 4.

-~- - -- - - -

U C-11-0130 Attachment Page 2 NRC Request #2:

What is the estimate of the seismic core damage frequency (CDF) for total CDF and large early release frequency (LERF)?

Action 2: Provide an estimate of the seismic CDF and LERF and the basis for the estimate (e.g., PRA, estimate based on seismic margins, etc.).

OPPD's Response to Request #2:

As documented in Section 3.1.4.3.1 of the Individual Plant Examination of External Events (IPEEE) for Fort Calhoun Station (Reference 3, page 3-91) , the overall plant High Confidence Low Probability of Failure (HCLPF) capacity is reported as 0.25g. This capacity is governed by the potential for soil liquefaction outside the area of Category I structures.

NRC Request #3:

In Attachment W, for the compressor room 19, Fire Area [fire compartment] FC32, credi,t ing the use of an administrative procedure restriction for transient combustibles in the overhead using a factor of .01 is an unreviewed alternate PRA method per the NRC. The factor .01 is already incorporated into the fire database and this would be double counting. It appears the factor should be 1 for no procedure.

Action 3: Perform/Incorporate the use of this factor into the sensitivity analysis.

OPPD's Response to Request #3:

A sensitivity study was performed and is documented in Reference 5. The results of this sensitivity study indicate that if the hot work procedural compliance factor of 0.01, which was applied to the FC32 (Compressor Area Room 19) cable fire caused by welding and cutting scenario, were removed (i .e., set to 1.0), the overall conclusions of the 10 CFR 50.48(c) LAR (Reference 1) would not be changed ; and the variance from deterministic requirements (VFDR) assessment results would still remain within the acceptance criteria of Regulatory Guide 1.174.

Reference 5 provides additional background on the use of the 0.01 factor as well as the requested sensitivity study as related to the overall conclusions of the LAR.

NUREG/CR-6850 does not currently provide any specific guidance for crediting hot work procedural restrictions. In order to credit this procedural enhancement, the OPPD fire PRA currently assumes that Room 19 hot work fires wiU only be initiated if the plant

LlC-11-0130 Attachment Page 3 fails to comply with the revised standing order SO-M-9, "Hot Work Operations," and the probability of failing to comply with this procedure is assumed to be 0.01.

The NRC has questioned whether the 0.01 probability of failing to comply with this new procedure revision is independent of the fire frequency, which includes events where hot work controls fail. Reference 5 provides the sensitivity study of hot work procedure compliance unreviewed alternate method (UAM) and the sensitivity study of hot work procedure compliance UAM aggregated with all other UAM sensitivity studies.

Reflecting no credit for the 0.01 procedU'ral compliance factor, the total plant CDF and LERF values are less than 1.00E-04/yr for CDF and 1.00E-05/yr for LERF per the Region II acceptance criteria of Regulatory Guide 1.174.

Reference 5 is available for NRC review on the FCS online reference portal in accordance with the terms and conditions delineated in Reference 4.

References:

1. Letter from OPPD (J . A. Reinhart) to NRC (Document Control Desk), License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805 , Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated September 28, 2011 (LlC-11-0099)

(ML11276A118)

2. Letter from Westinghouse Electric Company (C. M. Burton) to OPPD (J. McManis),

"Omaha Public Power District, Fort Calhoun Station, NFPA 805 Fire PRA, NFPA 805 - Task 7.17 PRA Peer Review History," dated April 1, 2011 (CFTC-11-95)

(Proprietary)

3. Letter from OPPD (T. L. Patterson) to NRC (Document Control Desk) , "Phase II Response to Generic Letter 88-20, Supplement 4 Individual Plant Examination of External Events (IPEEE)," dated June 30, 1995 (LlC-95-0130)

4. Letter from NRC (L . E. Wilkins) to OPPD (David J. Bannister), Fort Calhoun Station ,

Unit No . 1 - National Fire Protection Association Standard 805 License Amendment Application Online Reference Portal (TAC No. ME7244), dated December 13, 2011 (NRC-11-0134)(ML113260423)

5. LTR-RAM-II-11-133, "Assessment of the Fort Calhoun Station Fire PRA Modeling of Improved Hot Work Controls in the Compressor Area (Room 19)," dated December 8, 2011, Westinghouse Letter from Clarence Worrell and Ashley Mossa to Mehran Golbabai (Proprietary)