ML12319A263

ME8899 Draft RAIs License Amendment Request to Adopt NFPA-805

ML12319A263
Person / Time
Site:	Nine Mile Point
Issue date:	11/13/2012
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Darling T, Dosa J, Vandeputte D Nine Mile Point
References
TAC ME8899
Download: ML12319A263 (32)

Text

Vaidya, Bhalchandra From:

Sent:

To:

Cc:

Subject:

Attachments:

Vaidya, Bhalchandra Tuesday, November 13, 2012 11:26 AM

'Dosa, John J'; 'Darling, Theresa H'; 'Vandeputte, Dennis E' Fields, Leslie; Robinson, Jay; Klein, Alex; Kolaczyk, Kenneth; Dentel, Glenn; Pickett, Douglas; Wilson, George; Hemphill, Khadijah; Hyslop, JS; Clemons-Webb, Candace; Elliott, Robert; Shoop, Undine; Beasley, Benjamin Nine Mile Point Unit 1, ME8899, Draft Request for Additional Information (RAIs) Re: License Amendment Request (LAR) to Adopt NFPA-805 Nine Mile Point Unit 1 NFPA 805 Audit RAIs.docx

Subject:

License Amendment Request (LAR) Re: Adoption of NFPA-805, Dated June 11, 2012, (ADAMS Package Accession No. ML121700986, including Transition Report ML12170A869 (Redacted) and ML12170A870(un-Redacted))

John, Theresa, and Dennis, By letter dated June 11, 2012, Nine Mile Point Unit 1 (NMP1) submitted a License Amendment Request (LAR) Pursuant to Title 10 of the Code of Federal Regulation (10 CFR) Section 50.90 to adopt a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and 10 CFR 50.48(c); the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, and National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition.

The NRC staff has reviewed the information provided by NMP1 and also participated in an audit from November 5 to November 9, 2012, and has determined that additional information is needed to complete its review. The attached file shows the Draft Request for Additional Information (RAIs).

Please contact me at 301-415-3308, bhalchandra.vaidya(nrc.gov, or George Wilson, Branch Chief, NRR/DORL/LPL1-1 at 301-415-1711, goerqe.wilsonnrc.qov as soon as possible to schedule a tele-conference in next 2 weeks, between NMP1 staff and the NRC staff to ensure that NMP1 Staff clearly understands the RAIs. During the tele-conference, the NRC staff expects that NMP1 would provide a firm commitment date within 60 days from the date of the teleconference to respond to these RAIs.

Please note that the NRC staffs review effort on this LAR is being continued and additional RAIs may be forthcoming.

Please contact me immediately, if you have any questions.

Thanks, Bhalchandra K. Vaidya Licensing Project Manager NRCINRRIDORLILPLI-1 (301)-415-3308 (0) bhalchandra.vaidyaenrc.gov 1

[DRAFT1 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS NINE MILE POINT NUCLEAR STATION UNIT 1 (TAC NO. ME8899)

Office of Nuclear Reactor Regulation Division of Risk Assessment Fire Protection Branch A

PRA Licensing Branch Monitoring Program RAI 01 NFPA 805, Section 2.6 "Monitoring" states that "A mi ensure that the availability and reliability of the fire maintained and to assess the performance of t performance criteria. Monitoring shall ensure th I

remain valid."

Specifically, NFPA 805, Section 2.6 s at (2.6.1 reliability, and performance shall be e:

"2.4 reliability, and performance shall be est h

experience and industry operating experi reliability, or performnance met, app iat levels shall be implemn]eng sh are effective."

to are analysis able levels of availability, Lds to monitor availability, consider the plant operating S

hed levels of availability,

/lois to return to the established Plsure that the corrective actions Section 4.6, "Mon program "will be ii programtr Report)

M We Transiti eport states that the NFPA 805 monitoring wva..y.

o-- on issuance as part of the fire protection Table W'hnentation Items, Item 9 of the Transition

'hed to comply with Frequently Asked Question (FAQ) 10-r n provided in Section 4.6, "Monitoring Program" of the the astaffto complete its review of the monitoring program, following additional information be provided.

Fu r~

Transiti and as (a) Desi ow "

aintenance Rule program and the NFPA 805 monitoring program will be integrated. The discussion should include a description of the process t ill be used to identify systems, structures, and components (SSCs) for inclusion in the NFPA 805 monitoring program, and include an explanation of how SSCs that are already within the scope of the Maintenance Rule program will be addressed with respect to the NFPA 805 monitoring program.

(b) Describe how the NFPA 805 monitoring program will address programmatic elements that fail to meet performance goals (examples include discrepancies in programmatic areas such as the combustibles control program).

1

(c) Describe how the guidance in EPRI Technical Report 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features," if used, will be integrated into the NFPA 805 monitoring program.

(d) Describe the process that is in place to avoid conflict or interference between NMP Unit 1 NFPA 805 monitoring program requirements and NMP Unit 2 fire protection program surveillance and preventative maintenance requirements.

Programmatic RAI 01 NFPA 805, Section 2.7.1.2, "Fire Protection Program Design Basi ment" states that "A fire protection program design basis document shall be establishe on those documents, analyses, engineering evaluations, calculations, and so forth e the fire protection design basis for the plant. As a minimum, this document s clu hazards identification and nuclear safety capability assessment, on a fire are sfor all i as that could affect the nuclear safety or radioactive release performanc ia defined in er 1."

NFPA 805, Section 2.7:1.3, Supporting Docum n states t at "Detailed i ation used to develop and support the principle document sha eferenc separate doc ts if not included in the principle document."

The staff noted that the information pr in Section "Compliance with Documentation Requirements in Section 2.7.1 of NFP e Transit eport is insufficient for the staff to complete its review of the program d e

nd as is requesting that the following additional information be provid (a) Describe the sp n016ts tha prise t st transition NFPA 805 fire protection pro censi*

sis.

(b) Describe th gs tha aticipate Nuclear Division Directive, Fire Protection Program, (ND a

F 5 transition process, including associated traie any such training necessary to support the Pr matic RAI 02 NFPA 8 ection 2.7.2.1, sign sis Document" states that "The design basis document shall be m ed up-to-d s a controlled document. Changes affecting the design, operation, or enance e plant shall be reviewed to determine if these changes impact the fire protectio ra umentation."

The staff noted that t ormation provided in Section 4.7.2, "Compliance with Configuration Control Requirements in Sections 2.7.2 and 2.2.9 of NFPA 805" of the Transition Report is insufficient for the staff to complete its review of the configuration control program, and as such, is requesting that the following additional information be provided.

(a) Describe the changes that are anticipated to configuration control processes to incorporate the requirements of the NFPA 805 fire protection program.

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(b) Describe the procedures and processes related to configuration management, change control, and training that will be implemented to accommodate the separate fire protection programs that will be employed by NMP Units 1 and 2.

Programmatic RAI 03 Describe how the training program will be revised to meet the requirements of NFPA 805, Section 2.7.3.4, "Qualification of Users".

Programmatic RAI 04 Describe the commitment to conduct future NFPA 805 analysew ordance with each of the requirements of NFPA 805 Section 2.7.3, "Quality".

3

Radioactive Release RAI 01 Describe the radiological criteria that were used to screen fire areas out of the review.

a. The LAR states that the screening was performed with Health Physics "input." Describe whether this was an expert panel or a limited number (one) of individuals and whether they are sufficiently experienced to make this determination.

b. Describe whether the screening evaluation includes buildings outside the protected area (e.g., warehouses, storage or administrative buildings) wher dioactive materials may be stored during specific plant operations.

X Radioactive Release RAI 02 For areas where containment/confinement is relied upon For Liquids:

a. LAR Attachment E indicates that liquids fire i Building would "drain through floor drains n

198' level. Describe whether there are above doors that may be open durn ower opera outside the building that were to accot the turbine building, the radast lidin waste disposal building.

b. Describe whethersment ap pumps, etc., a opri d cons the c that are cre containi he liqui uent.

indicates th Reactor ing, and t SSE gal capacity ea sp'bthe dr aciti e drain tems scribe whe s are specified (

porary meas drain rs, etc.)). If oper er they are s fically dressed in the Fir(

ma For Gases:

naj all areas of

actor s to floor drain Wmps at the nt features (e.g., door or roll-up that may divert the effluent flow to answer should also include building (RSSB), and the f sumps, tanks, transfer

)nseq ences of overflowing the sumps For example, LAR attachment E 3 floor drain sumps have a 58 and 700 r the likelihood of exceeding the during fire fighting activities was e.g., to direct effluent flow/overflow with ator actions are specified, describe e Pre-plans and in the fire team training

a. Describe whLgr~here are plant features that can bypass the planned filtered/monitored ventilation pathway that have not been accounted for.

Radioactive Release RAI 03 For areas where containment/confinement is not available, verify that containers of radioactive materials/waste (i.e., drums, HICs, C-vans) are not stored outside where fire fighting effluents are not contained.

4

Fire Protection Engineering RAI 01 Fir In an par strt sho Fir Fir

a. Table B-I, Section 3.7: The compliance bases refers to the 1975 edition of NFPA 10 but LAR Section 6.0 (reference 6.17) refers to the 1998 edition. Clarify the correct edition.

b. Table B-i, Section 3.8.1: The compliance bases refers to EIR 51-9077284-000 and the reference documents column refers to "Appendix K" of EIR 51-9077284-000. However, this does not appear to be the correct appendix reference. It appears to the staff that Appendix "J" and not "K" is the correct appendix to EIR 51-9077284-000 for this element.

Clarify.

c. Table B-i, Section 3.11.5: The compliance bases refers t lectrical raceway fire barrier system (ERFBS) engineering evaluation FPEE-

1. However, the reference column references FPEE-1-95-002. Clari t document number.

e Protection Engineering RAI 02

_AR Attachment I, Table I-1, Fire Area "YARD" een listed as part o ower block d includes a parenthetical list of YARD struct nd equip

t. Clarify tha renthetical listing for the "YARD" represents all appl' YARD compon s and ictures required for operations. For example, cla the bulk nitrogen storage tank

)uld be included in this parenthetic e g.

e Protection Engineering RAI 03

a. Table B-I, Section 3.,and Tabl T

es diesel fire pump is protected by a w-ression hue

-3, Fire Area 14, states a dry-pipe suppress stem I tailed.

y this discrepancy.

b. Table 4-3:

if Table 4 hould b ised to include detection systems, suppression is, an tection res that are required as a result of NFPA 805, Chapter 3.

'1d---lclude a way to clearly identify which sy eatu required by ter 3 (e.g. note, new column, etc). For pl 05 n 3.9.4, requires suppression protection for the diesel fire p (Fire Are Zon This suppression protection is triggered by a Chapter 3 uirement and n Chap requirement.

e Prote Engineerin Al 04

a. Table B-ctio (1): The LAR states that EPRI TR-1006756 (a performance-based met e used to adjust surveillance frequencies. To apply a performance-based metho a NFPA 805 Chapter 3 element, a 10CFR50.48(c)(2)(vii) request for NRC approval must be submitted.

b. Attachment L, Approval Request 1: During the audit, the staff noted a significant amount of exposed cables in the three cable trays above the Radwaste Control Room suspended ceiling. In addition, the audit discussions included whether any equipment credited for the nuclear safety performance criteria is located within Fire Area 15. The approval request should be modified to:

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Briefly describe the amount of exposed cables in the Radwaste Control Room (the current introduction paragraph could imply that there are no significant amounts of wiring/cabling).

ii.

Address whether or not there is any equipment credited for nuclear safety performance criteria located within the entire Fire Area 15 (expand past the room which is only a fire zone).

Fire Protection Engineering RAI 05

a. Provide a complete list of the codes and standards commi n order to satisfy the NFPA 805 Chapter 3 requirements. For those that have mitted specific edition(s),

include the edition(s). For those codes where NMPI itted to multiple editions, identify all of the committed editions and briefly des app flity to NMP1 (e.g.

certain system, certain building, etc).

b. For those Table B-1 sections or related impl ation items that "a specific edition...will be cited", it is not clear what' nt by "will be cited".

if the edition will be cited during the transition period e edition e cited a ti the code is invoked. Here are two examples from the her i be cited" was sed:

i.

Table B-i, Section 3.3.

nd Table m 11 state in the compliance bases and the impleme that a "s edition/year of NFPA 701 will be cited" ii.

Table B-I Se *on 3.3.3 an ble st in the compliance bases and the i on item ecific

/year of NFPA 101 will be cited" Fire Protection

a. Tý T)7TM1jMte basis states that "flammable liquids are NFPA 30."

M~ify that flammable liquids are also used in L

n addition, clarify that "combustible liquids" are stored and 30.

b.

e B-i, Section 7: Thfibmpliance basis states that "bulk gas storage is not p

within stru es housing safety-related equipment." However, the requi nt in NFP 5, Section 3.3.7 states "important to nuclear safety". There are differen the ing of "safety-related" and "important to nuclear safety." Clarify the use of afety-related" as opposed to the NFPA 805 language of "important to nuclear sa Otherwise, clarify that bulk gas storage is not permitted inside structures housing systems, equipment, or components important to nuclear safety.

(NOTE: Table B-i, Section 3.3.1.2(6) compliance bases only has similar language)

c. Table B-i, Section 3.3.8: The compliance basis states that "bulk storage of flammable and combustible liquids conforms to the applicable requirements of NFPA 30...". Clarify that the "use" of bulk flammable and combustible liquids also conforms to the applicable requirements of NFPA 30.

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Fire Protection Engineering RAI 07

a. Table B-i, Section 3.5.5: During the audit, the staff noted a potential lack of fire barrier separation between the NMP Unit 1 electric fire pump, including its controller and driver and the rest of the plant equipment located within the Screenhouse. Clarify that there is adequate fire barrier separation or that there is previous approval for the lack of fire barrier protection between the electric pump (including driver and controller) and the rest of the screenhouse equipment. If invoking previous approval, the compliance statement should be modified accordingly.

b. Table B-1, Section 3.5.5: During the audit, the staff discus fire pump controls including the remote start control capability, located ins' main control room, for both fire pumps. Clarify that the remote start control both fire pumps, are protected from the rest of the plant including withi cree

e. If there is no fire barrier separation for the remote start control then clarif these circuits will not prevent an auto start of the fire pumps ing faults and da

c. Table B-A, Section 3.5.13: NFPA 805 r "each sprinkler and sta e system shall be equipped with an outside screw ke (0 ate valve or o approved shutoff valve." LAR Table B-i, Section 3.5.

t these systems "are equipped with manually-operable supply *lation valves

&Y)." Using the term "e.g."

suggests other types of contro re being u Clarify if all sprinkler and standpipe systems shut-off valv r

valves, then the compliance bases should be modified to clearly con hat s us Y shut-off valves as required by NFP8 exampl PI

' it 'i.e.").

d. Table B-, Sec Sectio h co nce bases lists "periodic valve position verifi

'as an n to m he supervision requirements. However, this is not oneoft of ree accept method alve supervision within NFPA 805. The compliance b houl d to r remove the "periodic valve position verific *n"or p r

its use as an equivalent option.

Fire P onrn 08 Tab Section 3.8.1.

co ce statement and compliance bases do not appear to accoun portion of the rall pa nt requirements of Section 3.8.1 which is applicable to NMP1. P the appropr compliance statement, and any necessary compliance bases, for the follow PA 805 tion 3.8.1 requirement: "Alarm annunciation shall allow the proprietary alar e

nsmit fire-related alarms, supervisory signals, and trouble signals to the control room constantly attended location from which required notifications and response can be initia

. Personnel assigned to the proprietary alarm station shall be permitted to have other duties."

Fire Protection Engineering RAI 09 The Table B-I, Section 3.10.3, compliance bases discusses adequate sealing and discharge testing for Halon 1301 systems. However, the bases did not clearly state the same for CO 2 systems. Clarify the adequate sealing and discharge testing to demonstrate effective hold times and overpressure effects all CO 2 systems.

7

Fire Protection Engineering RAI 10

a. Table B-i, Section 3.11.2: The engineering evaluation (FPEE-1-95-002) referenced in Table B-i, Section 3.11.5 documents the evaluation of the Promat-H fire barrier enclosure within Fire Zone T3B (HVAC duct entering Aux Control Room). Clarify if this HVAC duct fire barrier is credited to meet NFPA 805. If so, clarify if this EEEE is required to meet NFPA 805, Section 3.11.2. Clarify if Table 4-3 should also identify this as a required feature.

b. Table B-i, Sections 3.11.3(1) & 3.11.3(2): The compliance s ments state "complies with use of EEEE" but no code review compliance engine*

valuation is referenced for NFPA 80 or NFPA 90A. Additionally, the complian s descriptions with references to NFPA 252 and ANSI/UL 555 is not cleFPA 80 and NFPA 90A are met. NFPA 252 is not equivalent to NFPA 80,1 NFP is a fire test standard and NFPA 80 is an installation, use, and main standard.

I/UL 555 is not equivalent to NFPA 90A for similar reasons ng the audit, NM ed they are committed to NFPA 80 and NFPA 90A a ired for NFPA 805, e

.11.3(1) and 3.11.3(2) respectively. The compliance should dified to clea ate compliance to NFPA 80, for Section 3.11.3(

d 90A, for Section 3.11.3(2).

c. Table B-i, Section 3.11.4(b): C liance Ba s that "conduit smaller than 2-in diameter do not require intern nd are con d satisfactory." Clarify the basis for this statement including appl ering e s.

d. Table B-i, Section 3.11.5: The tate cre RFBS at NMP1 is in Fire Area 18 was not te accorda i

pement 1; however, an EEEE (FPEE-1-95-00 the q n

t was performed to be adequate an ble of r ing the rds in the area for a 3-hour fire resistance rating.

i.

, Sma" r

upplement 1 non-conformances 1 ed i EEEE evalua I and summarize the bases for acceptance.

Sum the conformances between the installation and the tested confiqur addr in this EEEE evaluation and summarize the bases for 8

Probabilistic Risk Assessment RAI 01 Please describe how your evaluation includes the possible increase in heat release rate caused by the spread of a fire from the ignition source to other combustibles.

Please summarize how suppression is included in your evaluation. As a part of this response, provide the general event tree structure used to evaluate fires in transient zones, and fires which receive more refined treatment that those which damage the entire transient zone. Additionally, discuss suppression in light of these event trees.

Furthermore, discuss how targets outside of this event tree firescen ]&evolution in the refined fire scenarios are treated. For example, it does not appear that a tray horizontally displaced from the cable tray stack is considered potentially da in the detailed fire analysis (beyond the transient zone analysis) once the initi is ignited.

In other words, the HRR does not appear to be increased from cab ig when assessing damage beyond the cable tray stack in the ZOI as esta from th ion source. Should cable trays horizontally displaced from the stack be ed in the fire s io, adjust the PRA and its results to account for that damage.

Probabilistic Risk Assessment RAI 02 Transient fires should at a minimum be laced in loca in the plant PAUs where CCDPs are highest for that PAU, i.e., at "pinc

i.

Pinch po clude locations of redundant trains or the vicinity of other potentially risk-r ipment, i ing the cabling associated with each. Transient fires should be placed I a te loca in a PAU where they can threaten pinch points. Hot work should b ume r in I ns where hot work is a possibility, even if improb not imp I

in the same philosophy.

Describe how transient fires a ted wi PAUs at your plant. In particular, identify th ia lant w etermine where an ignition source is placed within the PAUs.

you have as within AU where no transient or hot work fires are located since those are co red inacce le, describe the criteria used to define "inaccessible." Note t in e same as a location where fire is simply unlikely, ev hl im Prob Ic Risk sm 1 03 Discu e calculation o frequ s of transient and hot work fires. Characterize your use of the in e factors for tenan e, occupancy, and storage, noting if the rating "3" is the most comet s it is inten to be representative of the "typical" weight for each influence factor. It is e ed that t fluence factor for each location bin associated with transient or hot work fires w

..ze e of influence factors about the rating "3," including the maximum 10 (or 50 for main nd, if appropriate, even the rating "0." Note that no PAU may have a combined weight o unless it is physically inaccessible, administrative controls notwithstanding. In assigning influence factor ratings, those factors for the Control/Auxiliary/Reactor Building are distinct from the Turbine Building; thus, the influence factor ratings for each location bin are to be viewed according to the bin itself.

Related to this question is F&O 5-2, IGN-A7. The peer review comment questions the influence factors assigned to particular areas. The disposition says that a review was performed with the plant to ensure consistent application of the influence factors. Indicate how the particular compartments identified in the peer review critique were addressed.

9

Probabilistic Risk Assessment RAI 04 If you have used any influence factors outside of the values identified in Table 6-3 of NUREG/CR-6850, please identify the values used, identify the PAUs that use these factors, and justify the assigned factor(s).

Probabilistic Risk Assessment RAI 05 Section 10 of NUREG/CR-6850 Supplement 1 states that a sensitivity analysis should be performed when using the fire ignition frequencies in the Supplemen tead of the fire ignition frequencies provided in Table 6-1 of NUREG/CR-6850. Provide t fsitivity analysis of the impact on using the Supplement 1 frequencies instead of the T r-1 frequencies on CDF, LERF, ACDF, and ALERF for all of those bins that are chara an alpha that is less than or equal to one. If the sensitivity analysis indicates th risk acceptance guidelines would be exceeded using the values in Tab 1 please ju ot meeting the guidelines.

Probabilistic Risk Assessment RAI 06 It was recently stated at the industry fire forum that he a Identification and Ranking Table Panel being conducted for the circuit failure tes e DESIREE-FIRE and CAROL-FIRE tests may be eliminating the cr Control Po nsformers (CPTs) (about a factor 2 reduction) currently allowed by TabI 10-3 of G/CR-6850, Vol. 2, as being invalid when estimating circuit failure pr ilI vide a J tivity analysis that removes this CPT credit from the PRA and provid res how limpact of this potential change on CDF, LERF, A d ALER th *l is indicates that the change in risk acceptance guid e exce r elimi gCPT credit, please justify not meeting the guideline Probabilistic Risk ssment 07 Identify if ace fr insi n (VFDRs) in the LAR involved performlua f wrappedeor bedded cables. If applicable, describe how wrap embed les modeled in the Fire PRA including assumptions and insights on e PRA mode the bles contributes to the VFDR delta-risk evaluations.

Proba Risk Asses t RAI 8 The transitio rt descri nd justifies an initial coping time of 24 (48, 72) hours, after which, actions a ces o maintain safe and stable beyond 24 (48, 72) hours. Provide a discussion of the aessary during and beyond 24 (48, 72) hours to maintain safe and stable conditions bey 4 (48, 72) hours such as refilling fluid tanks or re-aligning systems.

Evaluate quantitatively or qualitatively the risk associated with the failure of actions and equipment necessary to extend safe and stable beyond 24 (48, 72) hours given the post-fire scenarios during which they may be required.

Probabilistic Risk Assessment RAI 09 Did the peer reviews for both the internal events and fire PRAs consider the clarifications and qualifications from Regulatory Guide (RG) 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities,"

10

March 2009 (ADAMS Accession No. ML090410014) to the ASME/AMS PRA Standard? If not, provide a self-assessment of the PRA model for the RG 1.200 clarifications and qualifications and indicate how any identified gaps were dispositioned.

Probabilistic Risk Assessment RAI 10 Attachment W of the LAR provides the ACDF and ALERF for the variances from the deterministic requirements (VFDRs) for each of the fire areas, but the LAR does not describe either generically or specifically how ACDF and ALERF were calculated. Describe the method(s) used to determine the changes in risk reported in the Tab

• n Appendix W. The description should include:

a. A summary of PRA model additions or modification o determine the reported changes in risk. If any of these model additions dat ethods not included in the fire PRA Peer Review please describe the i ons.

b. Identification of new operator actions (not i g post MCR a nment which are addressed elsewhere) that have been cr in the change in ris mates. If such actions are credited, how is instrumen e address d in the HRA.

Probabilistic Risk Assessment RAI 11 Identify any plant modification (imple n item) in ment S of the LAR that have not been completed but which have been ctly or i tly in the change-in-risk estimates provided in Attachment W.

t s of a odification has been included in the PRA before the modificati as lete models and values used in the PRA are necessarily etsbased u

a -built facility after the modification is complet rent t ans.

e add an implementation item that, upon completio PRA c ed imp ntation items, verifies the validity of the reported change-i his item uld inclu our plan of action should the as-built change-in-risk exce e estima ported in R.

Probabil PI the internal events or fire PRA since the last full-scope kLels that are consistent with the definition of a "PRA W endorsed by Regulatory Guide 1.200. Also, please

a. If SLhanges

• haracterized as a PRA upgrade, please identify if a focused-sope r re as performed for these changes consistent with the guidance in ASME IWa-2009, as endorsed by Regulatory Guide 1.200, and describe any findings fr' at focused-scope peer review and the resolution of these findings for this application.

b. If a focused-scope peer review has not been performed for changes characterized as a PRA upgrade, please describe what actions will be implemented to address this review deficiency.

11

Probabilistic Risk Assessment RAI 13 According to 4.5.1.3 of the LAR, the fire PRA peer review identified 65 findings, 59 suggestions, and 4 best-practice F&Os. These are contained in Attachment V. Please clarify which of the F&Os in attachment V are findings and which are suggestions.

The discussion also indicates that 42 SRs were found to be "not met" or CCI by the peer review team. Please identify those SRs, and their associated F&Os. Furthermore, the LAR indicates that 65 findings needed to be addressed so that the PRA would meet the SRs or achieve CClI.

However, table V-2 contains only 10 F&Os related to SRs from the reviewers' judgments that rated a "CCI" or "not met." It is stated that these F&Os wdere d to meet CCI.

Please F&Os~ ~~m weerIl Cl.Pes clarify the discrepancy, as the language related to the 65 findin*ms the same as the language for the 10 F&Os in table V-2.

As a result, please create a table for your fire PRA fr entries:

F&O number, SR(s) from Part 4 of the P 4

by the peer review team, whether the FI has implemented its disposition. Pleasero grouped according to PRA Standard technic, elements appear in the same s in the Probabilistic Risk Assessment RAI 1, For F&O DA-El-0l, descri~ hne procedure changes

m16, Re' in response to thisF shssment Probabilistic Risk Asesm en A

the following ig given

ýr NMP are analysis as a result of IS-001, Revision 01000 For F&O data in used cability of the plant-specific EDG recovery

ýnt Notebook to the generic industry data When will I 01, and QU.

committed to in the update to the

ýin Notebook be updated to address F&Os QU-Dla-01, QU-D5b-is unknown, will this update occur as part of the update Table S-2, Item 3? Describe what actions are planned as part of cation Notebook to address the above F&Os.

Probabilistic Risk Assessment RAI 17 For F&O PRM-A1-2-14, describe how the potential inconsistencies in the FRANX database have been addressed, including efforts to determine and address extent of condition.

12

Probabilistic Risk Assessment RAI 18 For F&O SY-A2-2-2, will system notebooks be updated as part of Attachment S commitments?

Probabilistic Risk Assessment RAI 19 For F&O SY-A3-2-3, what was the impact on the results when power dependencies for operator action indications were added to the model as discussed in Part D. Please describe the dependencies that were modeled.

Probabilistic Risk Assessment RAI 20 For F&O HR-G7-4-23, please describe how CDF and LERF ted in main control room (MCR) abandonment scenarios. Do any fires outside of th c

CR abandonment because of loss of control and/or loss of control room h ility? Are ening" values for post MCR abandonment used [e.g., conditional core ge probability P) of failure to successfully switch control to the Primary Control and achieve safe own of 0.1] or have detailed human error analyses been com or this acti ity. Please j any screening value used. If alternate shutdown op actions edited, pleas vide an example of how a specific human error probability w

dified considering a fire, including the resulting HEP. The justification should e results of the human failure event (HFE) quantification process, s that describ Section 5 of NUREG-1921, which would include the following, or an anal od:

a.

The results of the feasibilit sess e o r action(s) associated with the HFEss ikly addr g

ri discussed in Section 4.3 of NUREG I

b.

The re f the p ss in S 5.2.8 of NUREG-1921 for assigning scoping HEP cItions ass ted with use of alternate shutdown, specifically addr the ba r the ans to each of the questions asked in the Figure I5-5 Ow

c.

resuI ailed cation, per Section 5.3 of NUREG-1921, if nin P is determin to not be bounding.

Pr Istic Risk As en 21 What is atus of the im emen ideas listed on Page 1-1 of the PRA Handbook, Human Reliability sis, Decem 007?

Probabilistic sse nt RAI 22 ES-Al, ES-A5, FQ-A

-D6 - A conduct of the State-of-the-Art Fire PRA is a model which builds off the plant-specific internal events PRA. As indicated in NUREG-6850, the Fire PRA plant response model is intended to include at least all components that are credited in the internal events PRA. These findings indicate that only reactor and turbine trip initiators are modeled in the fire PRA. Provide an assessment that confirms that the reactor and turbine trip initiators bound all other fire induced transient initiators. In addition, the disposition to supporting requirement FQ-A2 does not address nontransient accident sequences such as inadvertent open relief valve. How does the licensee address fire induced initiators other than transients such as small LOCAs or SBOs. Supporting requirement ES-A5 indicates that a 13

sensitivity analyses was conducted for a select group of initiators other than turbine trip or reactor scram. Provide a summary of results from this analysis.

Probabilistic Risk Assessment RAI 23 CS-Al; F&O 4 The finding indicates that the peer review team found risk significant fire-induced component failures in the Fire PRA (FPRA) for which detailed circuit analysis was not performed. The team investigated components in the range of Fussel Vessely between 0.03 and 0.2. The licensee's disposition notes that circuit analysis was performed for those components identified by the peer review team and no additional co nents were identified for analysis. Provide the staff a more detailed description of the revi ormed to identify additional risk significant components for circuit analysis. In ad explain why analysis is not performed for those components whose fire-induced fail ruIute to fire scenarios with CCDP of 1.0 Probabilistic Risk Assessment R CS-A4; F&O 1 The finding ind and subcomponents creating a con subcomponents pertaining to trans affected. The disposition only addr explanation that addresses other ty subcomponents and primary comp Probabilistic Risk Assessment F SF-A4 - The dispositio*

the 1999 refueling When Probabilistic RiskU ssmentl Al 24 licates that C are mappe to both priml n

mponents iservative m model w was conducTon mitters and one of events were found to be esses transmitters, see should provide an n

bcomponen t map cable to both tAl 25' t the itches scheduled to be removed in this r ation completed?

vera ations to improve NMP1 's ability to combat any plan to a t on these recommendations? Provide a lations will be implemented by the licensee.

SF-A5 -

a seismi timelirnd FQ-D1 - 11 po, ratio of CDF currently as a upgrade as define review of the LERF

• finding notes that model refinements were made so that the

• from 1.5 at the time of the peer review to approximately 7 rovements. If refinements to the LERF model constitute a PRA IS/ASME Standard, provide a timeline for a focused scope peer Probabilistic Risk Assessment RAI 28 QU-B1 - This supporting requirement requires the licensee to identify method-specific limitations and features that could impact results. The peer review team was unable to review the limitations associated with FTRAX and FRANX. The disposition states that discussions of these limitations are now documented; however, does not provide an assessment for how the limitations of these programs impacts results.

14

Probabilistic Risk Assessment RAI 29 QU-B4 - The finding recommends using ACUBE in estimating exact solutions for cutset solutions instead of upper bound approximations. Provide a summary of results using ACUBE that describes the extent of conservatism applied in quantification.

Probabilistic Risk Assessment RAI 30 QU-D1 - Scenarios with CCDP = 1.0 were reviewed when they contributed significantly to fire CDF. To ensure correct logic and modeling consistency including a"&

te underlying assumptions, the review of significant accident sequences / cutse Iuld include a sample of scenarios with CCDP = 1.0. Provide the results of the cutset r at summarizes the remaining cut sets with CCDP=1.0; and those cut sets that Id and not categorized as CCDP=1.0.

o Probabilistic Risk Assessment RAI 31 SY-Al 1 - The disposition states that each loss different Emergency Diesel Generator (EDG) re realistic as-built as-operated plant, explain why ave instead of actual estimates. Provide additional inforn average EDG recovery time estimate fire Probabilistic Risk Assessment RAI t3 61h OSP) causelj has Oe the PRA sh odel the recovery times are used ing the impact of using is.

I ES-B2 - The finding indi(

reviewed for possible i Revision 3 was cond to MSOs were ideri are indicated in NE to suggest there isn't Pn the MS t c OU-01 Revision 3 should be PRA.

see st at a review of NEI 00-01 n

I ins guidan m NEI 00-01 Revision 2 and no gaps relative RAý 7d s

staff uires ad nal clarification verifying if additional MSOs sta e a in d

0 t

na a

s t

th la isi han those deled in the FPRA. The disposition seems neeeen NEI 00-01 Revision 2 and 3.

RAI 33

th is t

Pg om N -

i j r

s sr that the reported CDF and LERF values in the Fire PRA i

S c I on r disagrees with the combined cutest file. Several run w re set to true, followed by cutest subsuming which ed6ction in risk values. The licensee notes that Qrecover file

ýresults are free of nonminimal cut sets. Provide the staff an d on the use of QRecover commands.

events, c

resulted in input files en updated risk a, Probabilistic Risk I

ýsment RAI 34 w

LE-F1 - The finding indicates that LERF contribution to fire scenarios and compartments is presented by SSC contribution; however, information was not documented on the relative contribution to LERF by plant damage state or containment failure modes. The staff found documentation confirming that LERF contribution by plant damage state is listed; however, was unable to locate LERF contribution by differing containment failure modes. Provide the staff the results of the analysis listing LERF contribution by differing containment failure modes.

15

Probabilistic Risk Assessment RAI 35 F&O 3-8, FSS-G4. This plant disposition refers to a screening process for multi-compartment scenarios. Please describe the methodology for calculating multi-compartment scenarios.

Indicate those fire pathways modeled in the analysis, and how they were incorporated into the methodology to calculate the probability of multi-compartment failure. Ensure that penetration seals are discussed as they relate to your methodology.

Also, indicate the threshold for removing multi-compartment scenarios from the PRA analysis.

Justify this threshold. Your justification should address the impact o se multicompartment scenarios on the ACDF/ALERF and CDF/LERF. In particular, give self approval after the transition is allowed for cases where ACDF is less than 1 E-7, e ou're your justification shows that none of these sequences could contribute to a value.

Finally, if penetration seals are not quantified as the pe v ew com dicates, to what extent is the multi-compartment CDF underestimate Probabilistic Risk Assessment RAI 36 F&O 5-4 PP-B 1. The peer review comment indica t t iewer cannot determine which fire barrier elements are credited for the plant specific partment analysis. The plant disposition indicates that the noteboo een update ce the reviewer was not able to assess the plant configuration analyze discussi the range of fire barriers treated in the analysis and the reliability

d.

cular in the types of barriers credited for the examples in the peer revi omm rovi e overall reliability.

Probabilistic Risk Ass37 F&O 2-23 FSS-A6 descriptio the pee iew comment and disposition is too brief to understand the issu e peer r indicates t certain sequences in the event tree of question add up to the g

co for these sequences in the event tree.

Discuss sej, 5 an ons and the percentage to which these sequent~

!I%

Pr istic Risk As en 38 F&O 1-N-A7: In res e to h peer review comment, the disposition does not indicate the techni ution for co g of battery banks for the purposes of calculating fire frequency.

It only indica t the ba banks were treated correctly. Were the two battery banks calculated as o o

sets for purposes of ignition source frequency?

Probabilistic Risk A sment RAI 39 F&O 1-4, IGN-A7: The peer review comment indicates that space heaters are not counted as ignition sources. The plant disposition says that they are less than 5 hp and should not be treated as ignition sources. Provide a justification for your conclusion. The peer review comment also says that a space heater fire occurred at NMP. Provide a discussion that indicates how the space heater fire was determined to be non-challenging.

16

Probabilistic Risk Assessment RAI 40 F&O 5-9, IGN-A7 - The peer review comment indicates that the bus duct lengths were not counted correctly, and suggests that the frequency may be incorrectly determined. Provide a discussion of the process applied to estimate lengths of bus ducts and how the frequencies for bus duct fires were calculated.

Probabilistic Risk Assessment RAI 41 F&O 5-1 IGN-A4: The plant disposition to the peer review comment cates that no update is necessary for the 1999-2008 NMP event data since no unusual p of fires in terms of number of events and types of ignition source have occurred.

e a quantitative determination of whether those fires affect the generic frequ he frequency of the 1999-2008 period for a bin is greater than the generic freq

, pe a sensitivity study of the impact via a Bayesian Update. Furthermore, the p e iew com

.ndicates that no review of data prior to 2000 was done to ensure that neric data wa esentative of NMPs experience. As a result, perform a review 1's pre-2000 fire d or that pre-2000 data that is still representative of the plant annot be c nfirmed to b rt of the fire events database, perform a sensitivity study whi lects th 0tett the gen ata with the pre-2000 data. Justify if the pre-2000 data is n er entative at the plant (i.e. if the cause of the data no longer applies).

Probabilistic Risk Assessment RAI F&O 5-10, IGN-A4: The peer review co t re eeni plant specific fire events from frequency, and indica t

this scr g

EG/CR-6850 criteria.

However, the peer rev aicate nge ant events considered for this screening is not iden e p ispositi dicates that the documentation was updated, yet does not indica period of over w events were considered. Provide the period of time over which events considere a plant update to frequency.

ProbabiliS A*ss F&O T

r re omment indicates that exclusion of areas within the licensee con areas is not ical ressed. The plant disposition indicates that justification for e n of facilities i vide ever, that technical justification is not included.

Provide stification for usion facilities from the PRA. In particular, address those locations t not meet P 1 (see pg 13 of the PP portal notebook), yet are still removed from the ana Probabilistic Ris ent RAI 44 F&O 5-3 PP-B5. The plant disposition indicates that water curtains are not active fire barriers.

However, a water curtain does not become operable until actuated by detections. Explain why you view water curtains as not active, and explain the impact of this assumption upon your analysis. Also, the peer review comment suggests that for fire barriers and dampers, there is no justification that they are adequate for the hazard. Provide a justification in this regard, and if necessary, adjust your PRA 17

Probabilistic Risk Assessment RAI 45 F&O 5-5, 5-6: PP-Al: The peer review comment on this issue indicates confusion of the global analysis boundary and particular the treatment of EXT. Provide a discussion of those compartments included and excluded in your global analysis boundary. Be sure to define EXT in this discussion.

Probabilistic Risk Assessment RAI 46 F&O 1-14, IGN-A10: The peer review identified a concern with the particular scenarios. In particular, the peer review comment quest" factor for ignition sources and the entire scenario, and cited sc example of the problem. As a result, first describe the overaJd uncertainty of a fire scenario. Provide the basis for your c a io summary discussion of your factorization applied in the, e pmei provide a discussion of the implementation of the un

• ty appro discussion of your development of the variance of ample of a for this scenario. Indicate why the scenario you hosenjis your uncertainty approach.

Factor associated with a deviation in the error 1"-Cmpt-10 as an applied to develop the Icertainty. Provide a specific scenario, provide a

'or in DF equation eSetat mple of nt.

ach fact epr(

Probabilistic Risk Assessment RAI F&O 5-35: The peer review commentU review team found items installed in thel disposition indicates that the fire ignition statement of your intent tJOlLthe fire indicate the date on whiý lýe will plant ins conducted by the peer he fire PRA. The plant f Dec 2011. Provide a of your final fire PRA, and Probabilistic F&O 1-22, CF-Al:

based on other thz AMd etermination to assign CF values was trisp6'S'at you looked for potential CF assignments identified 4 ad*itional components for CF likelihood analysis.

iLlikelihood (other than 1) to circuit failure.

Pi F&O 1-21 1r w identifies several events that could be caused by a hot short, which werep sly set t rue in the analysis. The disposition is that NMP considered assigning circui' e pr ilities to these events. Were circuit failure probabilities added to the PRA? If so,, e this assignment of a circuit failure probability affects the quantification of the modeil. Was the fire PRA non-conservative prior to the identification of these events as potentially being caused by hot shorts?

Probabilistic Risk Assessment RAI 50 F&O 1-23, CF-Bl: The peer review comment indicates that the implementation of CF probabilities is difficult to trace since there is no single location or approach for including them in the PRA model. Provide a summary of the process by which CF probabilities are added into the PRA model.

18

Probabilistic Risk Assessment RAI 51 N1-FSS-F001 Rev 1: FSS-C8 on the use of fire wraps is listed as N/A. Please confirm that this SR is an N/A.

Probabilistic Risk Assessment RAI 52 N1-FSS-F001 Rev 1: On pg B-6, it is stated that a 6 min growth time is assumed for the HRR for electrical motor fires. It is also stated that no experimental evidence exists for this assumption other that the growth time for electrical motors is expected to be qui than for electrical cabinets. Provide a sensitivity study evaluating this assumption o analysis results. If this assumption has no impact on the PRA, provide that justificatio Probabilistic Risk Assessment RAI 53 N1-FSS-F001 Rev 1: On pg E-l, it is stated that only able tray will b aged from a hot work fire since the average prompt suppression ti ignificantly less tha time it takes for a cable tray fire to propagate. It is my under ng that onl a single cab is damaged also for junction box fires and self md able fir rify if this ass tion is made for junction box fires and self induced cable r

quantitative justi ication for this assumption for all three cases.

Probabilistic Risk Assessment RAI N1-FSS-F001 Rev 1: On pg G-6, it is sta hat mne sed structural steel element must be exposed*

om zone fo ce e

ed. However, FSS-F1 indicates that any expo steel e xpose high hazard fire source requires the develop f a fire ario fo ctural collapse. Please discuss and justify your assumption t re than on posed s ral steel element must be exposed for a fire scenario of collaps propos Probabilis*I "s

N1-F 3 Rev g

ur document, you indicate that credit for fixed suppression in the ed compartm Pro stification that the fixed suppression system is effective in the e d compartmen en t fire has grown and propagated from the exposing compa In particular, ure th t you address any gaseous suppression systems in your answer on ting fixed su ssion in the exposed compartment. Adjust your PRA accordingly Probabilistic Ris ent RAI 56 N1-FSS-F002 Rev 1: On pg 6, it is stated that 0.04 is used as the credit for CO2 system for EDG and turbine generator scenarios with the potential to fail structural steel. Explain how a C02 system can be effective in suppressing fires that could evolve to the size to fail structural steel. Also, it is noted that the CO2 system in the EDG room is manually actuated; however, the 0.04 is the credit to apply to an automatically actuated system. As a result, also justify the credit that you've taken for this manually actuated system. Also on pg 7, it is indicated that 0.001 is the credit generally allowed for manual suppression. Justify this credit as well.

19

Probabilistic Risk Assessment RAI 57 NI-CF-F001 Rev 1: On pg 10, it is indicated that for detailed circuit failure analysis, a set of assumptions are maintained in the general case. Those maintained assumptions are assumption 1 that the cables are not armored or shielded, assumption 4 that the source cables for intercable shorts are multiconductor cables, and assumption 5 that the cables are located in trays. Other information is case specific. Justify that assumption 4 is acceptable and that the impact on the risk results of this assumption are insignificant.

Probabilistic Risk Assessment RAI 58 Ni-CF-F001 Rev 1: According to Table 15 on pg 31, three pha per polarity hot shorts are assumed to occur with a probability of 1 E-6. Provide a justifi this assignment Probabilistic Risk Assessment RAI 59 In the early stages of the analysis, fire damage is ed to occur for all e ent in a transient zone. Combustibles and cables at the ins of the ordereven I in the adjacent transient zone, are assumed to be dam by fire

11. Yet, there i allowance for fires to propagate beyond the margins of the tra t z o a neighboring zone. It should be noted that no multicompartment analysis is account for the possibility that a fire will propagate from one transient another.

NMP should investigate if additional fire a

d th nt zone and its margins can occur. If the CCDP is inadequately repre ed fr vest n, the PRA analysis should be revised to account for t

• tional da e

t the PRA.

Also should a more r analys yond a sient zone analysis be performed (refined fire scenarios beyond ure of the ire transi one), then the fire scenario should be allowed to progress end an artificially iled at the transient zone or its margin.

Provide a revised ana sh e

nario be limited solely by the boundaries or margins ansie Finall

-FSS-v 0, it is indicated that the ignition source cannot be closer tha et to the edge tra zone. This implies that fire propagation or flame spread will n ttinue beyond Ju is assumption. If this assumption is wrong, provide an ass<ess f the effecto incorr tassumption.

20

Safe Shutdown I Circuit Analysis RAI 01 The description in LAR Section 4.2.1.2 of safe and stable is defined as, "the ability to maintain Keff < 0.99 with a reactor coolant temperature at or below the requirement for hot shutdown and then subsequently cool down and maintain NMP1 in a cold shutdown condition." The nuclear safety capability assessment (NSCA) methodology review (LAR Attachment B) includes discussion of CSD methodology as appropriate and the methods for meeting performance goals in the fire area assessments (LAR Attachment C) include CSD components and systems.

Additional information is needed regarding the timing, systems, acti nd any repairs, necessary to achieve and maintain CSD. There is no discussion risk associated with actions to achieve and maintain CSD.

Variance from Deterministic Requirements (VFDRs) are id d in Attachment C for performance criteria related to CSD. In some cases, th DRs ar ositioned on the basis that the risk, defense-in-depth, and safety ma eet the accep criteria of NFPA 805 with a recovery action (RA) credited. The VF position further sta RA has been evaluated for feasibility and reliability within the robabilisticRisk Assess FPRA) using human reliability analysis (HRA) methods Attach

, pg. 64, VF

-025).

Additional information is needed to address the folioic issues:

a. Provide the timing assumed fo hot shut (once achieved) and then transitioning from hot shutdown n

ng CS

b. Describe how cold shutdown was ele RA ding the risk of RAs credited for disposition of VF sociate h

ent.

c. System or co ta not s lly described for each applicable pe ce g rovide cription of capacity limitations, need to replenish s

, and tim tical acti for other systems needed to maintain safe and stable c g

(e.

ogen sup r valve operations, water supplies, boron supply, DC ba ow

d. De more resou

) requirements, timing, and feasibility of operator ger equipment to a ieve and sustain safe and stable conditions.

e.

hment rib ions involving repairs to valve and pump wiring for shutdown oling. Descri ore il the resource (staffing) requirements, timing, and sibility of actio repai A equipment to achieve and maintain CSD safe and qconditions.

f.

Pr a more detai description of the risk of failure of operator actions and equip necessa sustain safe and stable conditions.

g. Describ cti at are planned for multiple spurious operations (MSO) for Shutdown any time the need to restore decay heat removal is short based on time to boil.

Safe Shutdown I Circuit Analysis RAI 02 LAR Attachment A states the electrical raceway fire barrier systems (ERFBS) (Eternit, Inc.

Promat-H) is credited in Fire Area 18, "Emergency Diesel Generator 102 Missile Enclosure,"

only (page A-66). The ERFBS was not tested in accordance with GL 86-10, Supplement 1.

The acceptability of ERFBS testing and adequacy for the hazard is documented in Engineering Equivalency Evaluation FPEE-1-95-002; however, the ERFBS is not listed as a credited feature in LAR Table 4-3 or the Fire Area Assessment in LAR Attachment C.

21

The ERFBS should be identified as a credited fire protection feature in Table 4-3 and the Fire Area Assessment for Fire Area 18.

Safe Shutdown I Circuit Analysis RAI 03 LAR Section 4.3 and Attachment D describe the methods and results of the non-power operations (NPO) evaluation, including references to the applicable outage programs, procedures, and NPO analyses. Additional information is requested as follows:

a. Provide "Appendix B: NMP1 NPO Pinch Point Assessmen e NPO fire area reviews including a summary level identification of unavailable p each fire area and the resolution for each pinch point.

b. During NPO modes, spurious actuation of valves c e a ficant impact on the ability to maintain decay heat removal and inve ontrol.

a description of any actions being credited to minimize the im fire-induced us actuations on power operated valves (e.g., air operated (AOVs) and motor ted valves (MOVs)) during NPO either as pre-fire c ning or as equired duri fire response recovery (e.g., pre-fire rack-ou, Ily pinni valves, and i n of air supplies).

For example, it appears to the NRC staff that chnical Specifications (TS) allow the shutdown cooling isolatio 38-01 and to be inoperable in the open position for greater than 4 hou amn spec nditions. During higher risk evolutions such as a short time t il, ng the

• ous closure of any of these valves would be advantageous.

ide jfor voking the TS allowed flexibility for mainta ese valv e

ri evolutions (HREs).

c. Identify location afety f SFs) chieved via RAs or for which instrumentatio' alread lUded i t-power analysis is needed to support RAs required to ain safe a table co ns. Identify those RAs and instrumentation relied upon i 0 and d e how RA sibility is evaluated. Include in the description wh the or will be factored into operator pro ppaLuy P

Sring e conditions wen there is a short time to boil, describe the ator re to ious closure of one of the shutdown cooling system motor erated isolati Ives or 38-13. Describe how any RAs are feasible (e.g., can eliably accom ed in vailable time frame).

Safe Shut I Circuit A sis RAI 04 LAR Attachme scu of fire suppression effects only addresses installed systems and does not address ial effects of manual suppression activities by the fire brigade.

Provide additional infomation on the effects of manual suppression activities on nuclear safety performance criteria.

Safe Shutdown I Circuit Analysis RAI 05 Fire Area EXT is "External to Plant" and is included in the Power Block (Attachment I) under "Yard". The NFPA 805 compliance strategy for Fire Area EXT is the deterministic approach per Section 4.2.3.1. Describe how the performance criteria and how the fire suppression effects 22 I

meet (see also RAI 4 above) the nuclear safety performance criteria in this fire area. Update the Fire Area Assessment in Attachment C accordingly.

Safe Shutdown I Circuit Analysis RAI 06 The modifications required to comply with NFPA 805 are described in Attachment S, Table S-1.

The LAR states that completion of the required modifications will occur no later than the end of the first NMP1 refueling outage following issuance of the license amendment.

The LAR states no compensatory measures are required relative to odifications listed in Attachment S.

Include a description, a schematic diagram, and a schedule difications, including compensatory measures necessary to implement the risk-i ed, rmance-based (RI/PB) fire protection program (FPP) until the modifications ar leted.

Safe Shutdown I Circuit Analysis RAI 07 Based on a review of the UFSAR, switchgear ot an mot rol centers use 125 VDC power for control of the electrically-operated br so the breakers may be operated if AC power is lost. Dual feeds are provided control bus on each power board for added reliability, one each f er battery or 14.

A generic concern in regards to the Fo n h

hat occ on June 7, 2011 (NRC Special Inspection Report, March 12, 20 DA sion L12072A128) involves 125 VDC circuits from bot ses insi e s

r.

oth DC buses were impacted with "soft" gro ained ire ha n isolated by removing power.

With respect to the alhoun e

,it appe hat the power boards at NMP1 have dual control power feeds.

cribe if t ue has b considered at NMP1. Describe if there are any proposed plans to rm p

dure changes to address this issue.

Safe Sh it is RAI 08 Th er coordinati dy breaker un-coordination for several 600 VAC, 208-120

VAC, 40 VAC powe plies.

The tie bre (R1 042/RI

) that connect powerboard 16A section with 16B section and 17A section 7B secti e not co-ordinated with the breakers that supply Powerboards I d

e supply breakers for Powerboards 167 and 1671 are co-ordinated with the supply breaker to Powerboards 16 and 17 but are not co-ordinated with the tie breakers een the A and B sections of Powerboards 16 and 17.

The LAR states since the tie breakers are normally open and are controlled administratively by operating procedure N1-OP-30; 4.16 KV 600 V and 480 V House Service, there is no reason to replace the breakers to improve tie breaker coordination. However, this condition only remains valid if the tie breakers remain open.

Provide electrical lineups and descriptions of the procedures that describe when the tie breakers would be closed and the tie breaker un-coordination issue would exist. For instance, following a loss of offsite power (LOOP), the tie breaker needs to be closed in order to supply power to one 23

or more instrument air compressors and one of the spent fuel pool cooling pumps. Describe the effects of closing the tie-breakers following a LOOP since doing so results in loss of breaker coordination. Indicate how often the tie breakers are closed. Describe any compensatory actions taken when the tie breakers are closed. Describe how the Institute of Electrical and Electronics Engineers (IEEE) Standard 242, "Recommended Practice for Protection and Coordination of Industrial and Commercial Power Systems" is satisfied when the tie breakers are closed. Provide a summary of the breaker coordination study for when the tie-breakers are closed and describe how the results of the breaker coordination study tie into the PRA.

Safe Shutdown I Circuit Analysis RAI 09 Describe the methodology that was used to evaluate defense-i (DID) and the methodology that was used to evaluate safety margins. T"he n should include what was evaluated, how the evaluations were performed, and f a tions or changes to the plant or procedures were taken to maintain the philosogf'ptefense-'1pth or sufficient safety margins.

AV 24

Fire Modeling RAI 01 Section 4.5.1.2, "Fire PRA" of the Transition Report states that fire modeling was performed as part of the Fire Probabilistic Risk Assessment (Fire PRA) development (NFPA 805 Section 4.2.4.2). Reference is made to Attachment J, "Fire Modeling V&V," for a discussion of the acceptability of the fire models that were used.

Regarding the acceptability of the PRA approach, methods, and data:

1. The Fire PRA Detailed Fire Modeling Notebook, NI-ESS-F describes the technical approach for detailed fire modeling of fire compa support of the fire probabilistic fire risk assessment (FPRA) for the Nine Mile P luclear Station, Unit 1 NFPA 805 Transition Project. During the onsite audit the identified the following errors in this notebook:

a. Section 5 states that Fire Dynamics Simu DS) was use in the individual compartment-specific calculations. In a

, reference is mad ection D.3 for a brief discussion of FDS. However, d e onsite dit the staff med that FDS was not used at NMP and there descrip f FDS in App D.

b. The numbering of the sections headings in ices B-Y is inconsistent with the letters of the Appendices.

mple, Appe contains sections A. 1, A. 1.1, A.1.2, etc.

c. Section D.5 of Appendix-E de es t ent sient fires and transient fires due to ho this sec it is c ses where cable trays or other FPRA a

r the presen e relatively low fire intensity of 15 kW is ed as itical fi to damage targets in close proximity to the postula "This st ent app to be in error.

d. Section D.

p s t eatment of fixed ignition source fires.

r e

ons ing treatment is applied to cable fires due to is s nt is incorrec.

Section G.6 pen discusses the time to damage in auxiliary control room scenarios. Th ulati es a HRR profile of 1 MW, which has a ramp time of 12 nutes. Table shows e time to reach an HRR of 72 kW is approximately 7 tes. Howev the peak HRR is 1 MW, the time is expected to be between 3-4 m

,assum t2-profile.

Revise NI-1, Rev-1 to correct the above errors. In addition, revise N1-FSS-F001 per f., g.,

h., below.

f.

Include a list of all areas, zones, transient zones and scenarios for which algebraic models were used to calculate flame height, plume temperature and point source radiation. Specify for each use whether the model was used within its range of applicability, or, justify why the model was used outside the range.

g. Include a list of areas, zones and scenarios for which CFAST was used to confirm hot gas layer development.

25

h.

Include a list of areas, zones and scenarios for which algebraic models were used to calculate sprinkler, heat detector and smoke detector activation. Specify for each use whether the model was used with its range of applicability, or, justify why the model was used outside the range.

2. LAR Attachment J (page J-2) refers to the draft Regulatory Guide DG-1218 published in March 2009 for the acceptability of the fire models that were used in the application. Draft RG DG-1218 is the preliminary draft to RG 1.205 and therefore is not the approved guidance. Clarify that the models used in the application are in accordance with the approved guidance.

3. Of particular concern are fires in the proximity of a wall or a

r. The entrainment of air into the flame of these types of fires is restricted compar of the same size in the open. The reduced air entrainment results in higher plu nd gaslayer temperatures.

a. What are the criteria (i.e., distance fro I or corner) that we d during the walk-downs to determine whether w orner effe s have to be nted for in the fire modeling analyses?

b. Explain how wall and corner effects are ac or in the flame height, plume temperature and ceiling je rature calc s.

c. Explain how wall and corner ct ounte the CFAST hot gas layer calculations.

4. In the MCR abando

eport, 005 R Iit is assumed that the fire is located in the cen he ro above loor. Explain why the 3' elevation was chosen and why tis isi

rative, tmption.

5. Section 2.3.3 of th a

dy rt, N1-FSS-FOO5 Rev-1, discusses how the hori atunra nflow etermined. Explain the procedure that was use:e effective flow a a to door cross sectional area.

6.

n 2.3.5 of the ab ment study report, N1-FSS-F005 Rev-I, describes the fi narios that we dele the main control room.

section 3.3

• s explained that the large fixed ignition source (fire in vertical nets wIt ualified cables, fire in more than one cable bundle, open doors)

Sou scenario and that the smaller transient fires will result in longer aba times. While this is valid if the growth time for the fixed and transi es were the same, according to FAQ-52 the average growth time for transient fires could be 0, 2 or 8 minutes, which is shorter than the 12 minute growth time for the fixed ignition source. Provide additional justification for the assumption that fixed ignition sources will be bounding transient fires.

b. The CFAST MCR abandonment time analysis does not consider fire spread from one cabinet to adjacent cabinets. For the purpose of the Fire PRA, however, it appears that a cabinet fire is assumed to propagate to adjacent cabinets in 10 minutes. In the MCR walk-down during the onsite audit staff noted that there are no fire barriers between different sections of the Main Control Board (MCB).

26

Hence, based on the observed field conditions, the assumptions concerning fire propagation between cabinets in the analyses do not appear to be valid. Justify the assumptions concerning fire propagation in the MCB. Perform a sensitivity analysis to assess the effect of more rapid propagation between sections of the Main Control Board. Quantify the impact on CDF, ACDF, LERF and ALERF.

c. During the onsite audit staff performed independent MCR abandonment time calculations with CFAST input files provided by the licensee for the Bin 15 fire and the case without mechanical ventilation. According to Table 6 in N1-FSS-F005 Rev-1 the abandonment time is 6.50 min, while taff obtained an abandonment time of 5.25 min. Figure C-2 in Ni-F 05 Rev-1 implies that the ceiling height is approximately 7 m, but the eight according to Table B-2 is 12 ft or approximately 3.6 m. The differ iling height appears to explain the discrepancy between the report and nt time and that calculated by the staff. Repeat the MCR,n onment alculations with the correct input files and quantify the im CDF, ACDF, and ALERF.

7. Section 2.4.2 of the MCR abandonment stu ort, N1-FS -FO05 Rev-i, s that abandonment will result when the temperatu he hot yer is equal to reater than 930C when the hot gas layer height is belo fr floor. However, according to Section 11.5.2.11 of NUREG/CR-6 50 the temper erion corresponds to a heat flux M2 3heple layer height is above 6 ft. In of 1 kW/m2. Hence, the temperat ion applies if te layerhih saoe6f.I fact, when the layer height is 6 ft o aximum ble temperature is lower than 95°C as a significant component of e

r is co ve. Confirm that the statement in Section 2.4.2 of N1-FSS 5 e rror the temperature criterion was used independent height.

8. Table B-2 of App in th R aban ment study report, NI-FSS-F005 Rev-1, provides the c ment geo param T. he appendix does not specify the dimensions of th e cabin nd enclos structions that can substantially reduce the volume of the MC es t

es structions considered in the effective volume o n. I am w

structions will not affect the calculated abar i

9.

T has been u r ca ing hot gas layer characteristics in several compartments, a

ribed in the Fi D

Fire Modeling Notebook, N1-FSS-F001 Rev-1. Was the ce of enclos structions considered in the effective volume estimation? If not, explain the presenc obstructions that reduce the net effective volume will not affect the result eCFS lyses.

10. Where DETAC ed to determine sprinkler activation, provide justification for the response time in TI) value chosen for these analyses and describe how that value compares with the RTI of the actual sprinklers in the fire zone.

11. It appears from the methodology described in the Fire PRA Detailed Fire Modeling Notebook, N1-FSS-FOO1 Rev 1, that the effect of the heat release rate from secondary/intervening combustibles on the ZOI is not accounted for. Provide a justification for ignoring this effect.

12. Figure A-8 of Appendix B in the Fire PRA Detailed Fire Modeling Notebook, N1-FSS-FOO1 Rev-1, indicates that the lowest tray in a stack above a cabinet ignites at 5 minutes. An 27

ignition time of 5 minutes is also used in CFAST calculations; see for example Section L.6 in Appendix M. However, Section R.4.2.2 of NUREG/CR-6850 states that the first tray is assumed to ignite at time to damage/ignition using the plume temperature correlation.

Explain which of the two approaches were followed.

13. Section G.2 of Appendix H in the Fire PRA Detailed Fire Modeling Notebook, N1-FSS-FO01 Rev-1, discusses assumptions related to fire modeling hand calculations.

a. A fire dimension of 2' has been assumed for all postulated fires. Explain why this generic assumption is valid for all ignition sources across plant.

b. Section R.4.2.1 of NUREG/CR-6850 prescribes taki characteristic length of the fire as equal to the cabinet's length for the purpo lation fire propagation through cable trays. Justify the use of a charact le f 2' as this may not satisfy the NUREG/CR-6850 criterion.

14. Section G.7 of Appendix-H in the Fire PRA De ire Modeling Not N1-FSS-FOO1 Rev-1, discusses damage to cable trays in 2C and D. Table G-

• ch shows the model input parameters and result for th t source, el calculation s a radiative fraction of 0.3. However, previously in lon is mentioned that for all the calculations the radiation fraction is assumed to b n 30-40%, where the 40%

radiative fraction will be assumed t source ra n model. Confirm which value for the radiative fraction was used in t Fire Modeling RAI 02 Section 4.5.1.2, "Fire P nsition tates t e modeling was performed as part of the Fire PRA pment PA 805, tion 4.2.4.2). Reference is made to Attachment J, "Fir ling V&V, a discu of the verification and validation (V&V) of the fire models that used. F more Sec 4.7.3 "Compliance with Quality Requirements in Sect

.3

" f th ansition Report states that "Calculational models and

&calI m ed inl ompliance with10 CFR 50.48(c) were verified s re by Section 2...2 of NFPA 805. "

1.

able J-1 lists ctio ation Model (Heat and Smoke Detection), which is not v

d in NUREG-(as t er referenced models in Table J-1). Table J-1 has a foot at states tha mo s the prevailing model for estimating activation times."

This st nt does not vide sufficient basis to determine the adequacy of the V&V.

Provide a nal infor n and documentation to determine the acceptability of the model.

2. The licensee stat page J-4 of the LAR that "The dimensionless parameters for the CFAST files were not evaluated against the available V&V criteria in NUREG-1824. It should be noted that in some calculations, particularly those associated with the reactor and turbine buildings, there are relatively complex configurations not explicitly covered by the V&V criteria in NUREG-1824." This statement does not provide sufficient basis to determine the adequacy of the V&V. Provide additional information and documentation to determine the acceptability of the model.

3. LAR Table V-1 (page V-24), FSS-C3 supporting requirement indicates the use of the FLASH-CAT model described in NUREG-7010. This was used to model cable tray fires and 28

fire spread. This model is not described in Attachment J as a part of the Fire Modeling scope and V&V. Provide evidence of the validation of the FLASH-CAT model as implemented at NMP, Unit 1.

4. Section A.8 of Appendix B of the Fire PRA Detailed Fire Modeling Notebook, N1-FSS-FOO1 Rev-1, discusses cable fires and in this subsection, it is mentioned that the FLASH-CAT method is coded into an Excel macro. Explain the verification process that was undertaken to ensure that the macro generated correct output.

5. Has any of the fire modeling algebraic correlations available in F or FIVE-Revi been recoded for use in plant specific analysis? If this is the case, p documentation showing that the recoded correlations have been verified.

6. Provide evidence of verification of the processes to tra he s from fire modeling calculations into spreadsheets and/or databases for h r analysi Fire Modeling RAI 03 Section 4.7.3, "Compliance with Quality Require in Sec

.7.3 of NFPA "of the Transition Report states that "Engineering method nu I models used in support of compliance with 10 CFR 50.48(c) are used and were equired by Section 2.7.3.3 of NFPA 805."

Regarding the limitations of use:

1. Algebraic models cann ed outsi he tio s covered by the experiments on whi is base e-180 e Dynamics Tools (FDTs),"

has a section on ptions limitati at provides guidance to the user in terms of proper and imP use for ea DT. Ap ix H of the Fire PRA Detailed Fire Modeling Notebook, N1-001 Rev-scusses t neral limitations of use for the algebraic equations that has uti r

alc

n. It is not clear, however, how these eif in i eas or for the multi-compartment analysis.

Prov' n o the limit of a ability was determined for each fire area.

2.

n G-1 of App H in ire PRA Detailed Fire Modeling Notebook, N1-FSS-FOO1 R

discusses the tions e for algebraic equations. The range of the Froude num the analyses the pla t ranges from 0.7 to 3.1, whereas the range of validation is be

.4 and 2.4.

ce, for larger heat release rates, the Froude number will exceed the valida nge. Ex why it is acceptable to exceed the validation range.

3. Zone models-itable for compartments with a high length-to-width or height-to-width aspect ratio.

ddition, the hot gas layer temperature close to the fire might be significantly higher than the hot gas layer temperature calculated by a zone model. Verify that the CFAST model was always used within the range of acceptable room length-to-width and height-to-width aspect ratio, or, if not, explain why it was acceptable to use CFAST.

Fire Modeling RAI 04 Section 4.5.1.2, "Fire PRA" of the Transition Report states that fire modeling was performed as part of the Fire PRA development (NFPA 805, Section 4.2.4.2). This requires that qualified fire modeling and PRA personnel work together. Furthermore, Section 4.7.3, "Compliance with 29

Quality Requirements in Section 2.7.3 of NFPA 805," of the Transition Report states that "Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805."

Regarding qualifications of users of engineering analyses and numerical models (i.e., fire modeling techniques):

1. What are the licensee's requirements to qualify personnel for performing fire modeling calculations in the NFPA 805 transition?

2. What is the process for ensuring that the fire modeling pers meet those qualifications, not only before the transition but also during and followin ition?

3. When fire modeling is performed in support of Fire P ow is pr ommunication between the fire modeling and Fire PRA personn ured?

Fire Modeling RAI 05 Section 4.7.3, "Compliance with Quality Requirem S

2.7.3 of NFPA 80 "of the Transition Report states that "Uncertainty analyses w med as required by 2.7.3.5 of NFPA 805 and the results were consi n the conte e application. This is of particular interest in fire modeling and Fire PRA Regarding the uncertainty analysis for fir delin

1. NFPA 805, Section

that, rfor ased approach is used, an uncertainty analy 11 be p med to iereasonable assurance that the performance c ave been Accor to NUREG-1855, Volume 1, "Guidance on the Treatment o ertaintie ociated w s in Risk-Informed Decision Making,"

there are three typ un t

fire modeling calculations:

er ainty: Input pa meters are often chosen from statistical distri or ated from generic reference data. In either case, the uncertai the ut parameters affects the uncertainty of the results of the fire modeli alys plain how the parameter uncertainty was addressed in the detailed,

odeli 'g analyses.

b.

el Unce y: Idealizations of physical phenomena lead to simplifying a

pti the formulation of the model equations. In addition, the numerical sol uations that have no analytical solution can lead to inexact results.

Explai the model uncertainty was addressed in the detailed fire modeling analyses.

c. Completeness Uncertainty: This refers to the fact that a model is not a complete description of the phenomena it is designed to simulate. Some consider this a form of model uncertainty because most fire models neglect certain physical phenomena that are not considered important for a given application. Explain how the completeness uncertainty was addressed in the detailed fire modeling analyses.

30

2. The MCR abandonment study report, N1-FSS-F005 Rev-1, describes a sensitivity study to understand the effect of fire brigade arrival on the abandonment probability. However, the abandonment time could be sensitive to a number of parameters such as fire location, soot yield, obstructions, ambient conditions etc. Describe how uncertainties in these inputs were addressed.

31