ML12353A054

Unacceptable with Opportunity to Supplement, Email, License Amendment Request to Revise TS 3.8.1, AC Sources - Operation, for Two 14-Day Completions for Offsite Circuits

ML12353A054
Person / Time
Site:	Comanche Peak
Issue date:	11/19/2012
From:	Kalyanam N Plant Licensing Branch IV
To:	Ervin-Walker T Luminant Generation Co
Singal B
References
TAC ME9724, TAC ME9725
Download: ML12353A054 (1)

Text

Burkhardt, Janet From: Kalyanam, Kaly Sent: Monday, November 19, 2012 2:46 PM To: Ervin-Walker, Tamera Cc: Singal, Balwant

Subject:

Acceptance Review Result : Unacceptable with an Opportunity to Supplement

Tamera, The NRC staff has reviewed your application and concluded that the information delineated below is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirements and the protection of public health and safety and the environment.

We request that Luminant review the information requested and let the NRC staff know if it can be sent within 10 days from the receipt of the formal email/letter from the NRC staff. Subsequent to that the formal email/letter will be sent.

Thanks Kaly N. Kalyanam Backup PM, Comanche Peak ACCEPTANCE REVIEW RECOMMENDATION: UNACCEPTABLE WITH OPPORTUNITY TO SUPPLEMENT The staff has performed an acceptance review using the guidance of LIC-109, Revision 1, Acceptance Review Procedures. The licensees reliance on fire risk analysis approaches of 1994 and earlier does not reflect current fire risk analyses approaches, and consequently fire risk issues from the latest methods. Based on applications using the latest fire PRA methods, fire risk is a significant contributor to plant total CDF and can have a significant impact on the electrical distribution system. The licensee has not demonstrated that fire risk is an insignificant contributor for this application. Thus, the staff concludes that the analyses performed to support this LAR is inadequate to justify that fire risks are insignificant to the application, either in total risk or change in risk. In particular, the fire risk model applied by CPNPP can lead to incorrect quantification of those fire scenarios identified as important to the analysis, as well as omission of important fire scenarios. In order to address this shortcoming, the licensee must provide an analysis consistent with current fire risk analysis methods, meeting the necessary quality for the application and peer review expectations as identified by RG 1.200 Revision 2, and the endorsed ASME/ANS PRA Standard, RA-Sa-2009.

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