ML13072A063

Request for Additional Information, Round 2, License Amendment Request to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition

ML13072A063
Person / Time
Site:	Waterford
Issue date:	03/22/2013
From:	Kalyanam N Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N
References
TAC ME7602
Download: ML13072A063 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 22, 2013 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING ADOPTION OF NATIONAL FIRE PROTECTION ASSOCIATION STANDARD NFPA 805 (TAC NO. ME7602)

Dear Sir or Madam:

By letter dated November 17, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113220230), as supplemented by letters dated January 26, September 27, and October 16,2012 (ADAMS Accession Nos. ML12027A049, ML12272A099, and ML12290A215, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to transition its fire protection licensing basis at the Waterford Steam Electric Station, Unit 3, from paragraph 50.48(b) of Title 10 of the Code of Federal Regulations (10 CFR) to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805). Portions of the letter dated November 17, 2011, contain sensitive unclassified non-safeguards information and, accordingly, have been withheld from public disclosure.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the application and the supplements, and determined that additional information is needed to complete its review.

Enclosed is a request for additional information (RAI) for your consideration and response.

Please note that review efforts on this task (TAC No. ME7602) are continuing, and additional RAls may be needed.

Please review the attached items for clarification and contact me if a conference call if needed.

Though identified as draft items subject to the need for clarification, they are firm relative to the information being requested. Please respond to the RAI within 60 calendar days from the date of this letter.

- 2 If you have any questions, please contact me at (301) 415-1480 or bye-mail at kaly.kalyanam@nrc.gov.

Sincerely.

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N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 Enclosure cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NFPA-805 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 By letter dated November 17, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113220230), as supplemented by letters dated January 26, September 27, and October 16,2012 (ADAMS Accession Nos. ML12027A049, ML12272A099, and ML12290A215, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to transition its fire protection licensing basis at the Waterford Steam Electric Station, Unit 3 (Waterford 3), from paragraph 50.48(b) of Title 10 of the Code of Federal Regulations (10 CFR) to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805). Portions of the letter dated November 17, 2011, contain sensitive unclassified non-safeguards information and, accordingly, have been withheld from public disclosure.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the application and the supplements, and determined that the following requests for additional information (RAls) are needed to complete its review.

Fire Modeling RAI 01.01 By letter dated October 16, 2012, the licensee responded to Fire Modeling (FM) RAI 01.n and described the purpose of the three supplements to the Generic Fire Modeling Treatments that were used in the Fire Probabilistic Risk Assessment (FPRA). The NRC staff has determined it is unclear whether secondary combustibles or panel fire propagation were considered in all of them. For example, the responses discuss whether secondary combustibles were considered in Supplement 2, but not for Supplement 5.

Please state whether detailed fire modeling was required or performed at Waterford 3 to account for secondary combustibles or panel fire propagation and provide the results of such additional analysis. If such detailed fire modeling was not performed, provide a technical justification for why it was not necessary.

Fire Modeling RAI 02.01 By letter dated October 16, 2012, the licensee responded to FM RAI 02.e and stated that "Holes in closed/sealed raceways were not considered in the FPRA."

Enclosure

-2 Please state whether there are no closed or sealed raceways with holes or the effect of holes in closed/sealed raceways on thermal exposure of cables was ignored and provide justification if such holes were not considered in the FPRA.

Fire Modeling RAI 06 By letter dated September 27,2012, the licensee responded to Programmatic RAI 03. In the response, the discussion regarding the qualifications of users of engineering analyses and numerical models was insufficient regarding to fire modeling analyses that were performed during transition.

NFPA 805 Section 2.7.3.4, "Qualification of Users," states: "Cognizant personnel who use and apply engineering analysis and numerical models (e.g., fire modeling techniques) shall be competent in that field and experienced in the application of these methods as they relate to nuclear power plants, nuclear power plant fire protection, and power plant operations."

Please describe what constitutes appropriate qualifications for your staff and consulting engineers that performed the fire modeling analyses during transition and the processes for ensuring their adequate qualification. In addition, please describe how the exchange of information between fire modeling analysts and FPRA personnel was accomplished (e.g.,

whether the engineers and personnel who performed the fire modeling analyses walked down the fire areas that they analyzed).

Fire Modeling RAI 07 Several of the first round FM RAI responses make reference to 'forthcoming work.' For this reason, a final review of these RAI responses to determine their adequacy for use by reference in the safety evaluation is not possible. A list of FM RAls that are affected by this reference to

'forthcoming work' is provided below.

• Re-analysis of hot gas layer (HGL) assessments for areas where secondary ignition is deemed plausible (RAI 01.m and FM RAI 01.n)

• Use of 317 kiloWatts (kW) instead of 69 kW for the heat release rate (HRR) of transient fires (FM RAI 01.0)

• Refinement of the probabilistic risk assessment (PRA) to include scenarios with non-cable intervening combustibles that were overlooked (FM RAI 01.p)

• Additional analysis to identify thermoplastic cable targets (FM RAI 02.b)

• Additional analysis to assess the effect on the ZOI from increased HRR and flame spread of thermoplastic cables (FM RAI 02.c)

• Impact of self-ignited cables in the turbine building, cable spreading room, and RAB 27 (FM RAI 02.d)

• Risk impact of thermoplastic cables (FM RAI 02.f)

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• Re-analysis of solid state equipment in vented cabinets (FM RAI 02.g)

Most of these topics also pertain to FM RAI 04, Limitations of Use, as well as several PRA RAls.

Please provide the results of this 'forthcoming work' to the NRC staff for final review and describe if any of the final conclusions regarding core damage frequency (CDF), delta (.~) CDF, large early release frequency (LERF), and ~LERF are changed.

Fire Protection Engineering RAI 01.01 By letter dated September 27, 2012, the license responded to Fire Protection Engineering (FPE)

RAI 01. In that response, the licensee committed to Section 3.3.4 of NFPA Standard 220, "Standard on Types of Building Construction," 1999 edition. However, Section 3.3.4 does not exist in the 1999 edition of this standard. Please discuss the apparent error regarding the reference to this section and correct as applicable.

In the same response, the licensee identified a code of record for NFPA Standards 101, "Life Safety Code," and 241, "Standard for Safeguarding Construction, Alteration, and Demolition Operations," that they comply with, but identified complying with only a few selective sections in each standard. However, the licensee may have missed many sections that pertain to the requirements in the NFPA 805 standard. Please explain if it is accurate to state globally, that the licensee is committed to those editions of NFPA 101, 220, and 240, identified in the response to FPE RAI 01, but only to those sections that pertain to the 2001 edition of the NFPA 805 standard. If not, please provide a justification explaining why not.

Fire Protection Engineering RAI 13.01 By letter dated September 27,2012, the licensee responded to FPE RAI 13 and made several references to NFPA 805, Section 3.3.5.1. However, the RAI concerns NFPA 805, Section 3.3.5.3. Please clarify the response with regard to the correct NFPA 805 section.

Fire Protection Engineering RAI14 Table B-3 Suppression System Clarifications

1. LAR Attachment C (Table B-3), Fire Area RAB 21 (Component Cooling Water Pump B, page C-453), section "Fire Suppression Activities Effect on Nuclear Performance Criteria," states that "This area has a pre-action system." However, LAR Table 4-3, FSAR (Revision 11) page 9.5-60, and the remainder of LAR Table B-3 for Fire Area RAB 21, indicate there is no fire suppression system.

a. Please clarify what type of fixed fire suppression system(s) is installed in Fire Area RAB 21.

b. Please clarify which fixed fire suppression system(s) is credited for NFPA 805 in Fire Area RAB 21.

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2. LAR Table B-3, Fire Area RAB 37 (Emergency Feedwater Pump A, page C-594) states that "no" suppression installed but contradicts with "a pre-action automatic sprinkler system is provided ... ". Final Safety Analysis Report (FSAR), Revision 11, page 9.5-60, and LAR Table 4-3 both indicate Fire Area RAB 37 contains a fire suppression system.

a. Please clarify what type of fixed fire suppression system(s) is installed in Fire Area RAB 37.

b. Please clarify which fixed fire suppression system(s) is/are credited for NFPA 805 in Fire Area RAB 37.

3. LAR Table B-3, Fire Area RCB (Reactor Containment Building, page C-624) states that a "manually actuated water spray system is provided." Under section "Fire Suppression Activities Effect on Nuclear Performance Criteria," it states "no automatic suppression is credited ... ". This wording is not consistent with other fire areas and appears to indicate there is an automatic system installed.

a. Please clarify what type of fixed fire suppression system(s) is installed in Fire Area RCB.

b. Please clarify which fixed fire suppression system(s) is credited for NFPA 805 in Fire Area RCB.

Fire Protection Engineering RAI 15 Table B-3 Suppression Activities' Adverse Effect In several fire areas, it was not clear whether the adverse effects from all applicable fire suppression activities were considered.

For each fire area within Table B-3, please clarify that the statement" ... fire suppression activities will not adversely affect the ability to achieve the nuclear safety performance criteria" accounts for all manual suppression activities including fire brigade, any installed fixed manual suppression system(s), and any installed automatic suppression system(s).

Safe Shutdown RAI 01.01

1. By letter dated September 27, 2012, the licensee responded to Safe Shutdown Analysis (SSA) RAI-01 (a) and stated, "Updating of the SSA is occurring as each engineering package on each subject is generated." Analyses for transition to NFPA 805 should be essentially complete at the time the LAR is submitted. It is unclear from the RAI response if all analyses are complete or some are still ongoing. Please provide the following information:

a. A concise description of the state of completion of the analyses that support compliance with the Nuclear Safety Capability Assessment (NSCA) requirements of NFPA 805, Section 2.4.2, with the exception of the Multiple Spurious Operation (MSO) and Non-Power Operation (NPO) analyses, which were stated

-5 as completed in the RAI response. If any analyses necessary to support compliance with NFPA 805 Section 2.4.2 are not complete, please include a description of the remaining work, schedule for completion, and impacts on the information and analyses contained within the LAR and RAI responses. If no impact is expected, please provide a statement anc~ justification for this expectation.

b. Please provide the status of the latest post-fire SSA. Revision 3 of the SSA was in draft at the time of the audit. If the latest revision is in draft, please provide the estimated completion date and describe the work that remains to be done.

2. By letter dated September 27,2012, the licensee responded to SSA RAI-01(b), and stated, "Waterford 3 wi" also be transitioning the Fire Protection Analysis to utilize ARC software." At the time of the audit, licensee staff associated with the NSCA development indicated that the SSA would remain the governing analysis documentation for demonstrating compliance and there was no specific commitment to use the ARC software. Please provide the following information:

a. A discussion of the use of the ARC software in demonstrating compliance with NFPA 805, the continuing role of the SSA and the integration of the two.

b. A discussion of the databases and software that integrate fire protection program structure, system, and component data; fire modeling results, and PRA analyses (e.g., EPM-SAFE-PB and ARC) having a range of uses applicable to NFPA 805 implementation. These uses are subject to several NFPA 805 requirements including those that address determination of success paths; completion of the NSCA; the quality, configuration control, documentation, and verification and validation of analyses; and limitations of use. In addition, these databases and software can be used to facilitate integration of several aspects of NFPA 805 compliance. Specific applicable NFPA 805 requirements include:

NFPA 805 Section 2.2.9, "Plant Change Evaluation," states that: "In the event of a change to a previously approved fire protection program element, a risk informed plant change evaluation shall be performed and the results used as described in 2.4.4 to ensure that the public risk associated with fire-induced nuclear fuel damage accidents is low and that adequate defense-in-depth and safety margins are maintained."

NFPA 805, Section 2.2.11, "Documentation and Design Configuration Control," requires that: 'The fire protection program documentation shall be developed and maintained in such a manner that facility design and procedural changes that could affect the fire protection engineering analysis assumptions can be identified and analyzed."

NFPA 805 Section 2.4.1, "Fire Modeling Calculations," requires: (2.4.1.1)

"The fire modeling process shall be permitted to be used to examine the impact of the different fire scenarios against the performance criteria under consideration." (2.4.1.2.1) "Only fire models that are acceptable to

-6 the authority having jurisdiction shall be used in fire modeling calculations." (2.4.1.2.2) "Fire models shall only be applied within the limitations of that fire modeL" (2.4.1.2.3) "The fire models shall be verified and validated."

NFPA 805 Section 2.4.3.3 regarding fire risk evaluations states: liThe PSA [probabilistic safety assessment] approach, methods, and data shall be acceptable to the AHJ [authority having jurisdictioh]. They shall be appropriate for the nature and scope of the change being evaluated, be based on the as-built and as-operated and maintained plant, and reflect the operating experience at the plant."

NFPA 805 Section 2.4.4, "Plant Change Evaluation," states: "A plant change evaluation shall be performed to ensure that a change to a previously approved fire protection program element is acceptable. The evaluation process shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins. The impact of the proposed change shall be monitored."

NFPA 805 content requirements include:

(2.7.1.1) "The analyses performed to demonstrate compliance with this standard shall be documented for each nuclear power plant (NPP). The intent of the documentation is that the assumptions be clearly defined and that the results be easily understood, that results be clearly and consistently described, and that sufficient detail be provided to allow future review of the entire analyses. Documentation shall be maintained for the life of the plant and be organized carefully so that it can be checked for adequacy and accuracy either by an independent reviewer or by the AHJ."

(2.7.1.2) "A fire protection program design basis document shall be established based on those documents, analyses, engineering evaluations, calculations, and so forth that define the fire protection design basis for the plant. As a minimum, this document shall include fire hazards identification and nuclear safety capability assessment, on a fire area basis, for all fire areas that could affect the nuclear safety or radioactive release performance criteria defined in Chapter 1."

(2.7.1.3) "Detailed information used to develop and support the principal document shall be referenced as separate documents if not included in the principal document."

NFPA 805 configuration control requirements include:

(2.7.2.1) "The design basis document shall be maintained up-to-date as a controlled document. Changes affecting the design, operation, or

-7 maintenance of the plant shall be reviewed to determine if these changes impact the fire protection program documentation."

(2.7.2.2) "Detailed supporting information shall be retrievable records.

Records shall be revised as needed to maintain the principal documentation up-to-date."

Finally, NFPA 805 quality requirements apply to use of integration databases and software:

(2.7.3.1) "Each analysis, calculation, or evaluation performed shall be independently reviewed."

(2.7.3.2) "Each calculational model or numerical method used shall be verified and validated through comparison to test results or comparison to other acceptable models."

(2.7.3.3) "Acceptable engineering methods and numerical models shall only be used for applications to the extent these methods have been subject to verification and validation. These engineering methods shall only be applied within the scope, limitations, and assumptions prescribed for that method."

(2.7.3.4) "Cognizant personnel who use and apply engineering analysis and numerical models (e.g., fire modeling techniques) shall be competent in that field and experienced in the application of these methods as they relate to nuclear power plants, nuclear power plant fire protection, and power plant operations." "An uncertainty analysis shall be performed to provide reasonable assurance that the performance criteria have been met."

The NRC staff notes that, given the broad range of requirements applicable to use of integration databases and software, the Transition Report provided insufficient details for the staff to complete its review of the various areas affected by this software and is requesting that the following additional information be provided.

1) A description of how the post transition change evaluation process will ensure that the potential interfaces between integration databases and software and other databases and analyses (e.g., the cable and raceway database, the NSCA, the FPRA, and fire modeling) are evaluated and updated, as appropriate.

2) A description of the process that will be employed to ensure that integration databases and software are maintained in accordance with documentation and design configuration control processes and procedures.

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3) A description of the process and procedures that will be used to ensure that integration databases and software analyses are conducted and/or updated by persons properly trained and experienced in its use.

4) A description of the processes and procedures that will be used to ensure that integration databases and software analyses comply with NFPA 805 fire modeling, content, and quality control requirements.

c. The SSA RAI-01(b) response further states, "Attachment S, item S2-13, implements the actions above." This item describes development of new procedures and processes based on the NSCA analyses, but does not appear to address either the specific update of the SSA, or the transition to the use of the ARC software as described in the response.

Please provide a new implementation item in Attachment S or revise the existing implementation items in Attachment S that specifically address the work to be completed as part of transition, as your response to this RAI or the previous SSA RAI-01.

Safe Shutdown RAI 02.01 By letter dated September 27,2012, the licensee responded to SSA RAI-02, and identified specific gaps between Revision 1 and Revision 2 of Nuclear Energy Institute (NEI) 00-01 as applicable to Waterford 3. NRC staff review of the response has identified the following concerns requiring additional information:

a. The bulleted responses identify a number of commitments to perform additional work but there is no discussion on how this work may impact the existing analyses, including those analyses that have been reviewed by the staff and may be relied on for approval in the safety evaluation. Please discuss the expected impact of the additional work on the conclusions of the existing analyses (i.e., the nuclear safety capability assessment (NSCA) and FPRA, as reviewed by the staff during the audit).

b. The second bullet addresses the categorization of safe shutdown components as required for safe shutdown and important to safe shutdown. This equipment categorization aspect of NEI 00-01, "Guidance for Post Fire Safe Shutdown Circuit Analysis, Rev. 2, is not applicable under NFPA 805. As described in NEI 00-01, Rev. 2, the categorization or segregation of components as "required for" or "important to" safe shutdown is associated with the multiple spurious operation (MSO) methods there-in. The MSO methods applicable to NFPA 805, as implemented in the LAR, are those associated with the expert panel process as described in NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)", Rev. 2, (ADAMS Accession No. ML081130188), as endorsed by Section 3.3 of Regulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for EXisting light-Water Nuclear Power Plants," Rev. 1,2009 (ADAMS Accession No. ML092730314), and supplemented by NRC FAQ 07-0038, Lessons Learned

-9 on Multiple Spurious Operations, (ADAMS Accession No. ML110140242).

Please clarify how Waterford 3 intends to use the equipment categorization of NEI 00-01, Rev. 2, and identify the impact on the submitted safe shutdown analyses.

c. Related to Item a. above, the last paragraph of the response states, "An implementation item has been added to Attachment S to cover the updating of the NSCA to cover the transition to Revision 2, Section 3.0 of NEI 00-01."

Provide the new Attachment S showing the implementation item.

Safe Shutdown RAI 03.01 By letter dated September 27, 2012, the licensee responded to SSA RAI-03 and stated, "Since the submittal of the LAR, the instrument air compressors have been added to the SSEL [Safe Shutdown Equipment Ust] and the circuits routed." Please provide an explanation of the basis for this change, including a detailed discussion of the impact of this change on the NFPA 805 related analyses (e.g., NSCA, FPRA, and NPO) and the information previously submitted in the LAR. In addition, should Waterford 3 intend to credit the availability of instrument air, please provide the analysis or justification that the associated instrument air piping and tubing, which may have brazed or soldered joints, will remain free of fire damage.

Safe Shutdown RAI 08.01

1. By letter dated September 27, 2012, the licensee responded to SSA RAI-08(a) and described how each of the 11 feasibility criteria in FAa 07-0030, "Establishing Recovery Actions" (ADAMS Accession No. ML110070485), is addressed. It appears that the basis is for compliance with Appendix R and does not yet incorporate the FAa criteria for demonstrating feasibility to meet NFPA 805. Please provide the following additional information:

a. FAa 07-0030, Criterion 2, addresses consideration of the availability of systems and indications essential to performing recovery actions (RAs). The letter dated September 27, 2012, references the conclusions of the SSA for plant monitoring instrumentation. The response does not address the availability of systems and indications with respect to the feasibility of performing the RAs identified in the LAR. Please provide a confirmation that the selected plant monitoring instrumentation bounded those systems and indications essential to performing RAs, or provide additional discussion of how Criteria 2 of FAa 07-0030 is met with regard to determining the availability of those systems and indications necessary to perform the RAs in LAR Attachment G.

b. FAa 07-0030, Criterion 4, addresses emergency lighting. The letter dated September 27, 2012, states that sufficient emergency lighting is installed to support access/egress to local equipment for required hot standby manual actions. LAR Attachment G and Attachment S, however, state a modification is necessary to install emergency lights. Please clarify the apparent discrepancy between the feasibility analYSis as described in the RAI response and the LAR

- 10 statements that additional lighting is needed. Also, please clarify if emergency lighting is provided at the local equipment to support the performance of the RAs.

c. FAQ 07-0030, Criterion 5, addresses the availability of tools, equipment, and keys required for the RA. The letter dated September 27,2012, only addresses cold shutdown repairs. Please provide additional discussion of tools, equipment, keys, or any other similar operator aids necessary to achieve the RAs in LAR Attachment G.

d. Please discuss any ongoing or completed actions to incorporate the FAQ 07-0030 criteria in the licensee's documentation for compliance with NFPA 805.

2. By letter dated September 27,2012, the licensee responded to SSA RAI-08(b) and stated that the actions covered in the its feasibility analysis include RAs to meet NFPA 805 Safe and Stable Hot Shutdown. However, based on the NRC staff's review of RAs described in LAR Attachment G for Fire Area RAB-1, there are RAs that do not appear to have been addressed in the feasibility analysis as stated.

a. Please justify the differences between the list of RAs in LAR Attachment G and those listed in the feasibility analysis.

b. Please justify not performing the feasibility analysis on any NFPA 805 RA identified in LAR Attachment G, utilizing the 11 criteria of FAQ 07-0030, if applicable.

c. Please update the SSA if new RAs have been added to meet NFPA 805 Safe and Stable Hot Shutdown.

Safe Shutdown RA110.01 By letter dated September 27,2012, the licensee responded to SSA RAI-10 and stated, "Should a recovery action be utilized as a means of reducing fire risk during a NPO High Risk Evolution (HRE), the action would be evaluated for feasibility. This feasibility evaluation is not required to be in accordance with FAQ 07-0030, but would ensure the equipment is functional and that operators are available to perform the action with the time frame required."

Since the licensee is not performing the feasibility criteria per FAQ 07-0030, please describe how the equipment is ensured to be functional and how the operators will be able to feasibly perform the actions within the required timeframe using the criteria of NEt 04-02. Please describe and provide a justification for each of the feasibility criteria in NEI 04-02 that are not applied to NPO RAs, and describe any additional assumptions and criteria that are not prescribed in NEI 04-02 (if there are any).

Safe Shutdown RAI12 By letter dated September 27, 2012, the licensee responded to SSA RAI-06 and stated that when new RAs are implemented (Attachment S, Line Item S1-6), FAQ-07-0030 Revision 5

- 11 (11 feasibility criteria) will again be reviewed to verify that the RAs are feasible. The RAI response to SSA RAI 07(c) also states that additional actions determined to be RAs as a result of the updated fire risk evaluation will also be evaluated for risk and feasibility.

Based on the responses provided to SSA RAI-06 and SSA RAI-07(c), please provide a new LAR Attachment S reflecting the commitments to perform the cited feasibility analyses, reviews, and include these actions within the scope of Implementation Item S2-17.

Safe Shutdown RAI 13 By letter dated September 27,2012, the licensee responded to PRA RA157. The NRC staff's review of that response and efforts associated with development of the draft safety evaluation has identified a need for additional information regarding the treatment of RAs:

a. The response to PRA RAI 57, Item c.i, states, "There is a separation issue in the area and fires impacting both A and B charging pumps are possible. The train B pump variance from deterministic requirement (VFOR) is based solely on a credited SSA RA (one that is not included in LAR Attachment G)." If an RA is "credited" to address a separation issue and resolve a VFOR, it should be included in LAR Attachment C, Attachment G, and the additional risk of the action provided in Attachment W. Please provide additional explanation of the credited SSA RA and why this action is not included in the LAR.

b. Attachment G, Step 2, "Results," states, "The results in Table G-1 identify four RAs (Fire Areas RAB 5 and RAB 6) necessary to meet the risk acceptance criteria. The remaining RAs (Fire Area RAB 1) are required to maintain a sufficient level of defense-in-depth [(DID)]." Contrary to the statements in Attachment G, the Table B-3 summary for Fire Areas RAB 5 and RAB 6 state that, "The fire risk evaluation determined that the applicable risk, defense-in depth, and safety margin criteria were satisfied without further action." The summary further states under "DID Maintained" that "recovery actions are required for this area to meet defense-in-depth criteria." Please provide the following information:

1) Clarify if the RAs in RAB 5 and RAB 6 are required to meet risk acceptance criteria as stated in Attachment G or defense-in-depth (DID) as stated in Attachment C of the LAR.

2) VFOR 5-13 is listed in Attachment G with the action in RAB 5, but the VFOR disposition (in Attachment C) does not identify that an RA is necessary.

3) VFORs 6-09 and 6-10 are listed in Attachment G with an action in RAB 6, but the VFOR dispositions (in Attachment C) do not identify that an RA is necessary.

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4) Attachment G states that RAB 1 RAs are DID. VFOR 1-054 states, "This variance is identified as an RA action in Attachment G." Is this action required or DID?

5) Attachment W reports the additional risk of RAs for RAB 1, 5, and 6. If all RAs are DID, how was the risk of the actions calculated?

c. Attachment C contains a "Fire Risk Summary" for each performance-based area, and each summary includes the following statement: 'The fire risk evaluation determined that the applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action" [emphasis added]. However, under the "DID Maintained" heading for several fire areas (e.g., RAB 1, RAB 2, RAB 5, RAB 6, RAB 7A, RAB 7B, RAB BA-C, RAB 23, and RAB 25) modifications or DID RAs are identified. These modifications and actions are tied to VFOR resolutions associated with these fire areas. Please provide additional explanation to rectify the apparent contradiction of the summary statement that criteria were satisfied without further actions and the identification of RAs or modifications that apply to these areas.

d. Similar to Item 3 above, VFOR dispositions state that risk, DID, and safety margin criteria are met without further action [emphasis added] and then list modifications or DID RAs. Please confirm that the modifications and RAs listed in the VFOR dispositions are necessary to satisfy the risk, DID, or safety margin criteria.

Safe Shutdown RAI14 The disposition statement in LAR Attachment C, VFOR BC-30 is incomplete. Please provide the corrected statement.

Safe Shutdown RAI15 Under the "Basis" heading in LAR Attachment K, Oeviation-42, Item (d) states, "The section of ductwork between the two valves will be provided with a 1-hour fire resistant barrier." This commitment was contained in the original approval request dated September 9, 19B3. Please confirm that this 1-hour barrier is installed and remains intact.

- 2 If you have any questions, please contact me at (301) 415-1480 or bye-mail at kaly.kalyanam@nrc.gov.

Sincerely, IRAJ N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 Enclosure cc w/encl: Distribution via Listserv DISTRIBUTION:

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