ML13014A549

Request for Additional Information on the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805

ML13014A549
Person / Time
Site:	Cook
Issue date:	02/01/2013
From:	Thomas Wengert Plant Licensing Branch III
To:	Weber L Indiana Michigan Power Co
Wengert T
References
TAC ME6629, TAC ME6630
Download: ML13014A549 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555"()001 February 1, 2013 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION ON THE APPLICATION FOR AMENDMENT TO TRANSITION THE FIRE PROTECTION PROGRAM TO NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NOS. ME6629 AND ME6630)

Dear Mr. Weber:

By letter dated July 1, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11188A145), as supplemented by letters dated September 2, 2011, April 27, 2012, June 29,2012, August 9,2012, October 15,2012, November 9,2012, and January 14, 2013, Indiana Michigan Power Company (I&M) submitted an application for a license amendment to transition the Donald C. Cook Nuclear Plant, Units 1 and 2, fire protection program, from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), National Fire Protection Association Standard (NFPA) 805. Some portions of the supplemental information contain security related information and are therefore withheld from public disclosure.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject submittals and determined that additional information is needed to complete the review, as described in the enclosed request for additional information (RAI). The NRC staff had discussed the RAI in draft form with your staff on January 9, 2013. During that discussion, the NRC staff agreed to revise certain draft questions. Following the discussion, your staff agreed to formally submit your response within 90 days from the date of this letter.

L. Weber

- 2 Please feel free to contact me at (301) 415-4037 if you need any further clarification of the questions in the enclosure.

Sincerely,

~~~-Y-£~

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

Request for Additional Information cc: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION (RAI)

LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 RAI 29.01 Probabilistic Risk Assessment The August 9, 2012, response to RAI-29 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12242A246) provides justification of a value of 0.1 to represent the failure to reach safe shutdown using alternate means. The justification largely consists of a qualitative argument that the seven feasibility assessment and considerations identified in NUREG-1921 are addressed by the Donald C. Cook Nuclear Plant (CNP) for alternate shutdown. A quantitative assessment of the failure of alternate shutdown is not presented. A comparison is made to human error probabilities (HEPs) associated with Station Blackout (SBO); however, it is not clear that the actions are of the same complexity. The cognition element of SBO actions may be more straightforward than actions following a fire event in the Main Control Room. Also, it appears that alternative shutdown consists of about 20 separate Recovery Actions involving approximately 50 different components. Given this level of complexity and potential number of actions, provide further justification for the 0.1 HEP by providing the results of the human failure event (HFE) quantification process described in Section 5 of NUREG-1921, considering the following:

a. The results of the process in Section 5.2.7 of NUREG-1921 for assigning scoping HEPs to actions associated with switchover 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.

b. The results of the process in Section 5.2.8 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.

Provide a sensitivity analysis that shows the impact on the PRA results (CDF, LERF, ~CDF,

~LERF) of using the NUREG-1921 Section 5.2 HEP(s} 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 conditional core damage probability (CCDP) of 0.1 and the NUREG-1921 Section 5.2 scoping HEPs are determined to not be representative.

Enclosure

- 2 RAI-61 Probabilistic Risk Assessment The responses to the following RAls provided sensitivity analyses to show the impact on fire risk of the indicated PRA modeling, and this included PRA upgrades to meet Capability Category II (CC-II) requirements:

RAI 20 regarding compliance with LERF-related supporting requirements in the PRA standard RAI 29.01 regarding the use of a CCDP of 0.1 RAI 38 regarding credit for control power transformers RAI 31 regarding propagation of parametric uncertainty RAls 34.e and 34.01 regarding transient fire frequency apportionment RAI 40.b, Sensitivity Case 8, regarding treatment of transient fires near pinch points in inaccessible locations The Nuclear Regulatory Commission staff's position is that each of these sensitivity analyses:

1) has a potentially significant impact on the delta risk for the plant based on the results of the individual sensitivity analysis, and 2) if they are in the post-transition plant base case, must be evaluated collectively to assure a comprehensive treatment of the CNP transition fire risk.

Provide the results of a composite sensitivity analysis that shows the integrated impact on the fire risk (Core Damage Frequency (CDF), Large Early Release Frequency (LERF), llCDF, llLERF) of all of the above sensitivity analyses in the post-transition plant base case. In this composite analYSiS, for those cases where the individual issues have a synergistic impact on the results, a simultaneous analysis must be performed. For those cases where no synergy exists, a one-at-a-time analysis may be done. In the response, provide justification of how the Regulatory Guide (RG) 1.174 risk acceptance guidelines are satisfied for the composite sensitivity analysis of all the issues identified in this RAI and, if applicable, a description of any new modifications or operator actions being credited to reduce delta risk and the associated impacts to the fire protection program. If the licensee elects to exclude any of the above sensitivity analyses in the composite analysis, provide justification for exclusion. In addition, the licensee may provide an additional composite sensitivity analysis that includes only the sensitivity analyses that it believes appropriate. Again, provide justification of how the RG 1.174 risk acceptance guidelines are satisfied.

ML13014A549 OFFICE LPL3-1/PM LPL3-1/LAit LPL3-2/LA DRAIAPlAIBC LPL3-1/BC LPL3-1/PM NAME TWengert ELee SRohrer DHarrison IMSnodderly for RCarlson TWengert DATE 01/28/13 01/24/13 01/28/13 01/29/13 01/31/13 02/01/13