ML13008A350

Email, Request for Additional Information License Amendment Request to Adopt NFPA 805

ML13008A350
Person / Time
Site:	Callaway
Issue date:	01/08/2013
From:	Lyon C Plant Licensing Branch IV
To:	Wink R Union Electric Co, Ameren Corp
Lyon C
References
TAC ME7046
Download: ML13008A350 (4)

Text

Lent, Susan From: Lyon, Fred Sent: Tuesday, January 08,20136:40 AM To: Wink, Roger C Cc: Harris, Gregory A; Fletcher, Michael K; Hiller, Justin W; Elwood, Thomas B

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAts for Callaway Plant, LAR to Adopt NFPA 805 Roger; I'n check with the staff. Below is the revised that you should answer when you in RAi thIs emaiL The April 17, 2012, response to PRA RAI 07b. (ADAMS Accession No. ML121 OSA239, ML121 OSA240) provides justification of a value of 0.1 to represent the failure to reach safe shutdown using alternate means.

The justification largely consists of reporting that the seven feasibility assessment considerations identified in NUREG-1921, "EPRIINRC-RES Fire Human Reliability Analysis Guidelines - Final Report," have been performed. A comparison is made to human error probabilities (HEPs) associated with Station Blackout (SBO); however, although the number of actions associated with SBO may be of the same order of magnitude and may be executed at a similar level of urgency, it is not clear that the actions are of the same complexity.

For example, SBO has occurred at various plants and the sequencing of plant systems back to service after loss of power has been performed a number of times by most plants. The cognition element of SBO actions may be more straightforward than actions following a fire event in the main control room (MCR). Provide further justification for the 0.1 value by providing the results of the human failure event (HFE) quantification process described in Section 5 of NUREG-1921, including the following:

• The results of the process in Section 5.2.7 of NUREG-1921 for assigning scoping HEPs to actions associated with switch over of control to an alternate shutdown location, specifically addressing the basis for the answers to each of the questions asked in the Figure 5-4 flowchart.

• The results of the process in Section 5.2.S of NUREG-1921 for assigning scoping HEPs to actions associated with the use of alternate shutdown, specifically addressing the basis for the answers to each of the questions asked in the Figure 5-5 flowchart.

In addition, provide a sensitivity analysis that shows the impact on the PRA results (CDF, LERF, ilCDF.

ilLERF) of using the resultant scoping HEP for control room abandonment scenarios. Alternatively, provide the results of a detailed human reliability analysiS (HRA) quantification, per Section 5.3 of NUREG-1921, if the screening CCDP of 0.1 is determined to not be bounding.

From: Wink, Roger C (mailto:RWink@ameren.com]

Sent: Monday, January 07,20133:16 PM To: Lyon, Fred; Elwood, Thomas B Cc: Harris, Gregory A; Fletcher, Michael K; Hiller, Justin W

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAls for Callaway Plant, LAR to Adopt NFPA 805 Fn:~d: We had a project call with our team today and would like to have a phone cali regarding our latest NFPA 805 application RAI:; to discuss the following items. Note that we are unavailable this week Thursday/Friday. This could wait till next week if that works out best.

1

• Generai radiation release questions. Our intent is to respond to these qut'stions sirniiDf' to other have done and we just wish to discuss this to make sure it is okay with

~ Fire Modeling question 03-01b: We do not believe there is an error in the calculation and wish discuss this with the reviewer.

Thanks Wink :.. Supervising Engineer, Regulatory Initiatives T 314.225.1561 ,.

Amaran Missouri ,. PO Box 620. Fulton, MO 65251 From: Lyon, Fred [1]

Sent: Saturday, January OS, 2013 6:55 PM To: Wink, Roger C; Elwood, Thomas B

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 Roger I won't in the office Monday, but be in on Fred From: Wink, Roger C [2]

Sent: Friday, January 04,2013 1:07 PM To: Lyon, Fred; Elwood, Thomas B

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 With the information below we rnay not n!:'ed a cali at all. Let me check with our team to confirm and lwil! back with you at ieast noon CST 1/7/13.

Thanks Engineer. Regulatory Initiatives T 314.225.1561 620" Fulton, MO 65251 From: Lyon, Fred [maHto:Fred.Lyon@nrc.gov]

Sent: Thursday, January 03, 2013 9:42 AM To: Elwood, Thomas B

Subject:

FW: fvlE7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 FYi the reviewer DC Cook won't be back until Monday. Hopefully we can the issue thert We want DC Cook and Callaway RA!s to worded the same.

From: Lyon, Fred Sent: Thursday, January 03, 2013 8:36 AM To: 'Elwood, Thomas B'

Subject:

FW: ME7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 Tom, the staff provided following for consideration, Thanks, Fred 2

From: Robinson, Jay Sent: Thursday, January 03, 2013 8:08 AM To: Lyon, Fred Cc: Fields, Leslie

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 staff has provided some additional information for FM RA! 03,01 The contractor is in so a morning or after call would if needed, If the following can provided to the licensee maybe won't a need for a phone call on this Based on the staff's independent calculations, EPM overestimated the plume radius for scenario C-31.3618-8 because their calculations appear to be for thermoplastic cable targets. This is an error because the plant only has thermoset cable targets. The effect of the error, if any, is that the 201 estimates are more conservative.

The intent of the RAI is (1) to advise the licensee that there is an error in the plume radius calculations and (2) to have the licensee confirm on the docket that the error has no (adverse) effect on the results of the risk calculations.

In regards to PRA RAI 35. APLA (Ray Gallucci) agrees to defer the RAt until the wording is resolved for The RAI would resubmitted at a later date. there is no for a phone call.

, am foliowing up with the reviewers for DC Cook will see where that RAI is and try to facilitate If you have any questions, let me know. Thanks, Jay.

From: Lyon, Fred Sent: Wednesday, January 02,2013 7:34 AM To: Fields, Leslie; Robinson, Jay

Subject:

RE: ME7046 Additional AFPB, APLA, AND AHPB RAIs for Callaway Plant, LAR to Adopt NFPA 805 Callaway requests a clarification phoncon with the staff I can set one up using Outlook or you can provide me available times, email of 11/27, let me know.

Jay, the licensee had the following

• Clarification is requested for FM RAI 03.01 b. The RAI states that the independent calculations for fire scenario C-31.3618-8 determined that thermoplastic damage criteria was used to calculate the plume radius. We are having difficulty determining where the NRC is finding this problem and request more specific details about the issue so we can respond accurately.

• PRA RAI 35. We understand that the NRC is discussing a draft RAI for DC Cook that is nearly identical (to our RAI 35) but is being revised. We request the response to PRA RAI 35 on MCR Abandonment be deferred until after the specific RAI wording is resolved at DC Cook and at which time we would answer the revised RA\.

Thanks, Fred (x2296)

The information contained in this message may be privileged and/or confidential and protected from disclosure.

If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering 3

this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of Ameren. All e-mails are subject to monitoring and archival. Finally, the recipient should check this message and any attachments for the presence of viruses.

Ameren accepts no liability for any damage caused by any virus transmitted by this e-mail. If you have received this in error, please notify the sender immediately by replying to the message and deleting the material from any computer. Ameren Corporation The information contained in this message may be privileged and/or confidential and protected from disclosure.

If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of Ameren. All e-mails are subject to monitoring and archival. Finally, the recipient should check this message and any attachments for the presence of viruses.

Ameren accepts no liability for any damage caused by any virus transmitted by this e-mail. If you have received this in error, please notify the sender immediately by replying to the message and deleting the material from any computer. Ameren Corporation 4