LIC-13-0033, Omaha Public Power District'S, Responses to Second Request for Additional Information License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station

Omaha Public Power District'S, Responses to Second Request for Additional Information License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station

ML13116A015
Person / Time
Site:	Fort Calhoun
Issue date:	04/23/2013
From:	Prospero M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-13-0033, TAC ME7244
Download: ML13116A015 (45)

Text

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosure, Attachment 4 contains Proprietary information.

Upon removal of Enclosure Attachment 4, this letter is Decontrolled.

-UP-Omaha Public Power District 444 South 16"' Street Mall Omaha, NE 68102-2247 LIC-13-0033 April 23, 2013 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from OPPD (J. A. Reinhart) to NRC (Document Control Desk), License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standardfor Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated September 28, 2011 (LIC-11-0099)

(ML112760660)

3. Letter from the NRC (L. E. Wilkins) to OPPD (David J. Bannister), Fort Calhoun Station, Unit No. 1 - Request for Additional Information Re: License Amendment Request to Adopt National Fire Protection Agency Standard NFPA 805 (TAC No.

ME7244), dated April 26, 2012 (NRC-12-0041) (ML121040048)

4. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandardfor Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, dated July 24, 2012 (LIC-12-0083) (ML12208A131)

5. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandardfor Fire Protection for Light Water Reactor GeneratingPlants," 2001 Edition, at Fort Calhoun Station, dated August 24, 2012 (LIC-12-0120) (ML12240A151)

6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandardfor Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, September 27, 2012 (LIC-12-0135) (ML12276A046)

7. Email from NRC (L. E. Wilkins) to OPPD (D. L. Lippy), DRAFT: Fort Calhoun NFPA 805, Second Round (ME7244), dated February 22, 2013 (NRC-1 3-0014)

SUBJECT:

Responses to Second Request for Additional Information Re: License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME7244)

The Omaha Public Power District's (OPPD's) responses to select Nuclear Regulatory Commission (NRC) second requests for additional information (RAIs) regarding the license amendment request (LAR) to adopt National Fire Protection Association (NFPA) 805 at the Fort Calhoun Station (FCS) are provided in the enclosure to this letter.

In the Reference 2 LAR, OPPD requested an amendment to Renewed Facility Operating License No.

DPR-40 for FCS, Unit No. 1, to adopt NFPA 805, Performance-BasedStandardfor Fire Protection for Light Water Reactor GeneratingPlants (2001 Edition). The NRC staff reviewed OPPD's application and determined that additional information was required in order to complete their review and transmitted Employment with Equal Opportunity '400('a t14 -

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosure, Attachment 4 contains Proprietary information.

Upon removal of Enclosure, Attachment 4, this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Page 2 of 2 the original RAIs in Reference 3. OPPD provided responses to the original RAIs in References 4, 5 and 6. The NRC indicated that the staff had reviewed the information provided by the licensee [in References 4-6] and determined that additional information specified in the Reference 7 email is needed for the staff to complete its evaluation.

In Reference 7, the NRC proposed a 60 calendar day response time from the date of draft issuance of the RAIs. However, it was determined that a number of the RAIs would require additional planning and analysis (e.g., sensitivity studies, etc.) in order to complete the final RAI responses. Therefore, the status and proposed extension of select RAI responses were discussed during a clarification teleconference between the NRC and OPPD staff on March 11, 2013. Based on this call and subsequent follow-up discussion with the NRC Project Manager, OPPD is providing the responses to a select number of RAIs in this letter and is scheduled to submit the remainder of the NFPA 805 Round 2 RAI responses on May 21, 2013.

The Enclosure, Attachment 4 contains proprietary information to Westinghouse Corporation LLC in response to OPPD's Probabilistic Risk Assessment (PRA) RAI 14.01. As the document provided in response to PRA RAI 14.01 (Attachment 4) contains information proprietary to Westinghouse Corporation LLC, it is requested that this document be withheld from public disclosure in its entirety in accordance with 10 CFR 2.390. As such, a non-proprietary version is not provided. The affidavit from Westinghouse Corporation (Attachment 3) sets forth the basis on which the information should be withheld from public disclosure by the Commission in accordance with 10 CFR 2.390.

There are no new regulatory commitments being made in this letter as a result of the enclosed NFPA 805 RAI responses. Please note, as indicated in References 4 and 5, OPPD plans to supplement the NFPA 805 transition LAR, which will reflect the applicable information delineated in the enclosed RAI responses. The LAR supplement is being tracked by commitment item AR 48249.

If you should have any questions regarding this submittal or require additional information, please contact the Supervisor - Nuclear Licensing, Mr. Bill R. Hansher at 402-533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 23, 2013.

Michael J. Prospero Plant Manager

Enclosure:

OPPD's Responses to Second Request for Additional Information re: NFPA 805 LAR Attachments: 1. Safe Shutdown RAI 17 Response - Breaker Coordination Curves Figure SSDRAI-17

2. Safe Shutdown RAI Response - Schematic Drawings

3. Probabilistic Risk Assessment [PRA] RAI 14.01 Response WEC CAW-13-3675 -

Affidavit, et. al.

4. PRA RAI 14.01 Response, LTR-RAM-II-10-046, Revision 3 [WEC Proprietary Information]

c: A. T. Howell, NRC Regional Administrator, Region IV(without Enclosure Attachment 4-Proprietary)

L. E. Wilkins, NRC Project Manager (without Enclosure Attachment 4-Proprietary)

J. M. Sebrosky, NRC Project Manager (without Enclosure Attachment 4-Proprietary)

J. C. Kirkland, NRC Senior Resident Inspector (without Enclosure Attachment 4-Proprietary)

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Omaha Public Power District's (OPPD's) Responses to Second 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 Fort Calhoun Station, Unit 1 (TAC No. ME7244)

The NRC proposed a 60-calendar-day response time from the date of draft issuance of the emailed requests for additional information (RAIs). It was determined that a number of the RAIs would require additional planning and analysis (e.g., sensitivity studies, etc.) in order to complete the final RAI responses. Therefore, the status of the RAI responses and proposed extension of select RAI responses were discussed during a clarification teleconference between the NRC and the Omaha Public Power District (OPPD) staff on March 11, 2013. Based on this conference call and subsequent follow-up discussion with the NRC Project Manager, OPPD is providing the responses to the RAIs identified in Table 1 below and is scheduled to submit the remainder of the NFPA 805 Round 2 RAI responses on May 21, 2013.

Table 1 - Round 2 RAIs Responses in this Letter RAI Topic RAI Number Fire Modeling RAI 03.01 Fire Modeling RAI 04.01 Fire Protection Engineering RAI 10.01 Fire Protection Engineering RAI 12.01 Fire Protection Engineering RAI 16.01 Fire Protection Engineering RAI 21 Fire Protection Engineering RAI 22 Fire Protection Engineering RAI 23 Fire Protection Engineering RAI 24 Fire Protection Engineering RAI 25 Fire Protection Engineering RAI 26 Fire Protection Engineering RAI 27 Fire Protection Engineering RAI 28 Safe Shutdown RAI 17 Probabilistic Risk Assessment RAI 01 .d.01 Probabilistic Risk Assessment RAI 01 .i.01 Probabilistic Risk Assessment RAI 14.01 Probabilistic Risk Assessment RAI 19 Probabilistic Risk Assessment RAI 23 Please note that OPPD plans to supplement the NFPA 805 transition license amendment request (LAR) to reflect the applicable information delineated in the following RAI responses. [AR 48249]

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U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Fire Modeling RAI 03.01:

In a letter dated July 24, 2012 the licensee responded to Fire Modeling RAI 03a.

Please provide additional details regarding what the verification process per Westinghouse quality management system (OMS) involves and how the verification was actually performed.

OPPD's Response to Fire Modeling RAI 03.01:

Westinghouse has a documented quality management program, which includes procedures specific to creating (authoring) and reviewing (verifying) documents and calculations. Those procedures were followed in the creation of all Fort Calhoun Station fire PRA documents and calculations authored by Westinghouse. The following paragraph summarizes the procedure for verifying calculations, and additional detail can be found in the Westinghouse proprietary Quality Management System (QMS) procedures.

The engineering manager is responsible for assigning a qualified independent verifier. The verifier is responsible for verifying that the analysis is correct, and several tools are implemented for this review. The verifier uses the "3-Pass Method", which is an iterative review technique starting at a high level and ending with detailed technical verification of all text and calculations in the document.

For calculations, the verifier can either re-perform the calculations using the author's method, or they can perform the calculation using an alternate technique (e.g., using an alternate correlation or model) to verify correctness and reasonableness of the author's calculation. Comments generated during the verification are documented and must be resolved by the author to the verifier's satisfaction. Finally, the document is routed through the Westinghouse Electronic Document Management System (EDMS), including legally binding electronic signatures of the authors, verifiers, and approving manager.

Fire Modeling RAI 04.01:

By letter dated July 24, 2012, the licensee responded to Fire Modeling RAI 04b.

Please provide additional details regarding the processes and procedures in place to ensure that personnel and contractors who will perform fire modeling during and after the transition to National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," have the necessary qualifications.

OPPD's Response to Fire Modeling RAI 04.01:

In accordance with Westinghouse Level II policies and procedures, the Risk Applications and Methods group (the Westinghouse group responsible for the FCS fire PRA) formally maintains a qualification matrix and process that is used to ensure that personnel performing analyses are appropriately qualified. The process considers factors such as formal engineering education, professional licensure, basic engineering skills and experience, general PRA skills and experience, and skills and experience specific to the task at hand (e.g., fire PRA model development, fire modeling, circuit analysis, and fire risk quantification). This process was utilized to develop the FCS fire PRA, and a similar process will be utilized to maintain the fire PRA.

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U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure Fire Protection Engineerinq RAI 10.01:

By letter dated July 24, 2012, the licensee responded to Fire Protection Engineering RAI 10c and indicated that the manual suppression equipment for the yard transformers are located in nearby hose houses that contain "adjustable spray-solid stream nozzles." However, this response does not provide full compliance with NFPA 805, specifically with regards to maintaining "listed electrically safe fixed fog nozzles" for "locations where high-voltage shock hazards exist" as required by NFPA 805, Section 3.6.3. Please provide further justification for the acceptability of the use of non-electrically safe nozzles capable of providing a solid stream in areas containing high voltage equipment (for example, the yard).

In addition, for any non-electrically safe nozzles co-located with electrically safe nozzles in areas of high voltage equipment, please describe how the different nozzles are labeled such that brigade members can identify which nozzle type is which.

OPPD's Response to Fire Protection Enqineering RAI 10.01:

OPPD currently meets the intent of the requirement to provide electrically-safe nozzles in areas with electrical hazards by providing adjustable-type nozzles that the FCS fire brigade is trained to use.

Fire brigade training lesson plans point to the Fire Hazards Analysis Manual to fight electrical fires.

The fire brigade is trained in the use of water for the extinguishment of electrical fires.

In order to enhance compliance with this code requirement, LAR implementation item REC-143 has been generated as part of the Transition Report, Attachment S, Table S-3, to complete the following as part of NFPA 805 implementation:

• Fixed fog-only nozzles will be added to the fire brigade gear bags for use throughout the plant

• Fixed fog-only nozzles will be added to the hose houses and cabinets that house equipment that could be used to fight fires in high voltage electrical fires (including the hose house near the outdoor transformer area)

• Adjustable nozzles will be labeled "not for use on electrical fires"

• The use of the fog nozzles vs. the adjustable nozzles will be incorporated into fire brigade training By implementing these changes, the requirements of NFPA 805 Section 3.6.3 to have "listed electrically safe fixed fog nozzles" for "locations where high-voltage shock hazards exist" will be met.

Fire brigade training and the labeling of adjustable nozzles as "not for use on electrical fires" will ensure that brigade members can identify which nozzle type is which. The updated LAR Attachment S, including this implementation item, will be reflected in the NFPA 805 transition LAR supplement.

[AR 48249]

Fire Protection Engineering RAI 12.01:

By letter dated July 24, 2012, (ADAMS Accession No. ML12208A131) the licensee responded to Fire Protection Engineering RAI 12 and removed the missing implementation item and changed the compliance statement from "Complies with Required Action" to "Complies" and "Complies with Use of EEEEs." However, no existing engineering equivalency evaluation (EEEE) was identified in the response, instead it stated that the license amendment request (LAR) will be updated to provide the referenced document. Please identify and provide a short description of the new EEEE referred to in the original response.

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U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure OPPD's Response to Fire Protection Engineeringq RAI 12.01:

EA-FC-95-022, "NFPA Code Compliance," Revision 4, which was referenced in OPPD's original response to Section 3.4.4 in the NFPA 805 transition LAR (LIC-11-0099, Page A-47), is the existing engineering equivalency evaluation (EEEE) referred to in the original response to RAI 12. The NFPA 600 code review included in EA-FC-95-022 identifies that fire-fighting equipment conforms to the applicable NFPA standards as follows:

Per letter NFPA805-EPM-11-001 from OPPD (J. L. McManis) to Engineering Planning and Management, Inc. (F. Pellizzari) dated January 11, 2011, "Attached is a sample of invoice documentation (Contract 00058660) that confirms that protective clothing, PASS devices, and SCBA equipment are compliant with NFPA, NIOSH, and MSHA requirements. ED M Feld Equipment Company was contacted and stated all Fire Brigade equipment supplied is to the latest NFPA codes. Each item is labeled showing compliance to the NFPA codes and an inspection of the bunker equipment confirmed the labels. Also attached are samples of vendor manuals for applicable equipment that have manuals for inspection and storage."

The updated LAR Transition Report Attachment A (Table B-1), with the corrections to the compliance statement, the corrected compliance basis, and updated reference document in response to this RAI will be reflected in the NFPA 805 transition LAR supplement [AR 48249].

Fire Protection Engineerinq RAI 16.01:

a. LAR Attachment L, Request 3, states that "most of the wiring and cabling that is installed above the suspended or dropped ceilings is in conduit and/or is IEEE-383 qualified." Attachment L, Request 3 further states under "Basis for Request" that "only a minimal amount of wiring installed above suspended ceilings ... is not rated for plenum use or wrapped in conduit." The "Basis for Request" goes on to state that "identified cabling is routed in conduit or raceway and/or is IEEE-383 qualified."

Attachment L, Request 3 appears inconsistent as to the actual qualification or rating of existing wires above suspended ceiling.

Further, it appears an Institute of Electrical and Electronics Engineers (IEEE)-383 qualification is equated to a plenum-use rating which is incorrect. NFPA 805 Section 3.3.5.1 requires cables above suspended ceilings to be plenum-rated, routed in armored cable, routed in metallic conduits, or routed in cable trays with solid metal top and bottom covers. NFPA 805 does not list IEEE-383 as satisfying this requirement. IEEE-383 is a flame spread characteristic whereas the term "plenum-rated" characterizes flame spread and damage threshold. Therefore, the IEEE-383 qualification alone does not meet the requirements of NFPA 805 Section 3.3.5.1. Re-evaluate the cables located above suspended ceilings with regards to NFPA 805 Section 3.3.5.1. Please provide clear descriptions to separate between those that do and do not meet NFPA 805 Section 3.3.5.1 requirements. Revise Attachment L, Request 3 and Table B-i, Section 3.3.5.1 compliance statement, as necessary.

OPPD's Response to Fire Protection Engineering RAI 16.01 a:

The statement that cabling is IEEE-383 qualified was not intended to imply that IEEE-383 qualification is equivalent to a plenum-use rating.

The content of the compliance statement and compliance basis for Table B-1 Section 3.3.5.1 remains unchanged.

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U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure See revised Attachment L item in the response to RAI 16.01 b, below.

b. Cabling introduces both a combustible load and potential ignition source to an area, to varying degrees. Attachment L, Request 3 is requesting that certain cables remain in these concealed spaces without the protection required by NFPA 805 which is a potential reduction in the defense-in-depth (DID) and/or safety margin. The DID discussion should be revised to describe how each layer of DID is adequate and/or compliments the other layers.

Please clarify the following in Attachment L Request 3:

i. What voltage the cables carry.

ii. Whether a fire detection system is installed above the suspended ceiling(s) in the control room (CR) area.

iii. Whether the Gai-tronics cables, fire detection circuits, and lighting/power circuit cables are relied upon to perform any required safe shutdown or fire protection duties.

iv. That if a fire event were to damage these unprotected cables, whether or not the plant would remain capable of performing its safe shutdown and fire protection functions as required.

v. Whether fire damage to these cables (e.g. fire detection, Gai-tronics, etc) would adversely impact the radiological release performance criteria with regards to fire suppression run-off and smoke effluents.

vi. Whether the presence of air handling unit VA-67 in fire area 19 presents a hazard with regards to these non-rated and nonwrapped cables.

vii. Whether the cables compromise fire protection for systems and structures.

OPPD's Response to Fire Protection Engineering RAI 16.01 b:

Attachment L, Approval Request 3 has been revised to incorporate the responses to questions i. through vii. in this RAI, as indicated by the revision bars in the LAR excerpt for Attachment L below. This revision to Attachment L will also be reflected in the NFPA 805 transition LAR supplement [AR 48249].

Approval Request 3 NFPA 805 Section 3.3.5.1...

NFPA 805 Section 3.3.5.1 states:

There is a minimal amount of wiring installed above the suspended ceilings in the Control Room and personnel complex area that does not comply with the requirements of this code section. The wiring in these locations that is not approved for plenum use and not installed in conduit includes lighting/power receptacle circuits, Gai-tronics cables, telephone cables and fire detection circuits.

Basis for Request:

The basis for the approval request of this deviation is:

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U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure

• Only a minimal amount of the wiring installed above the suspended ceilings in the Control Room and personnel complex area is not rated for plenum use or routed in conduit.

• The subject cables are low-voltage type cables for data and communications, such as Gai-tronics, telephone, and fire detection. Such low voltage cables are not susceptible to self-ignition. Therefore, self-ignited cable fires involving this wiring are not of concern above the suspended ceiling.

• Based on visual inspection and review of EA-FC-97-001 and drawings 11405-A-21, 11405-E-64, 11405-E-74 Sheet 1, and 11405-M-89 (with the exception of air handling unit VA-67 above the suspended ceiling of fire area 19 as discussed below) there are no ignition sources in the areas above the suspended ceilings of fire areas 19 and 42, and, with the exception of the cabling for which approval is requested herein, cabling is routed in conduit or raceway and/or is rated for plenum use. Air handling unit VA-67 is a two (2) horsepower unit and as such does not represent a potential ignition source.

• Loss of fire detection, communications, or other systems is not credible considering a fire involving this wiring, because there are negligible quantities of wiring and no ignition sources above the suspended ceilings.

" The Gai-tronics system is not credited in the nuclear safety capability assessment, and the presence/loss of emergency lighting has been evaluated.

• SO-G-21, Modification Control, will be revised to ensure restrictions are in place to mandate the use of plenum rated wiring above suspended ceilings for future installations.

Acceptance Criteria Evaluation:

Nuclear Safety and Radiological Release Performance Criteria:

The presence of non-rated and non-protected wiring above the suspended ceilings in the Control Room and personnel complex area does not affect nuclear safety. Loss of cables for data and communications, such as Gai-tronics, telephone, and fire detection, is not credible considering these low voltage cables are not susceptible to self-ignition and therefore, self-ignited cable fires are not a concern. There are negligible quantities of wiring and no additional ignition sources as the air handling unit VA-67 is a two (2) horsepower unit and is not a potential ignition source. Further, even if a fire above the suspended ceiling were to affect these systems, the Gai-tronics system is not credited in the nuclear safety capability assessment, and the presence/loss of emergency lighting has been evaluated. Therefore there is no impact on the nuclear safety performance criteria.

The location of non-rated and non-protected wiring above suspended ceilings has no impact on the radiological release performance criteria. These criteria are achieved through engineered controls for the containment of water and smoke, based on the potential location of radiological concerns, and are not affected by the presence of the non-rated and non-protected wiring above these suspended ceilings.

Safety Margin and Defense-in-Depth:

The amount of non-rated and non-protected wiring above the ceilings in the Control Room and personnel complex area is negligible. Because these cables carry a low voltage, they are not susceptible to self-ignition. Therefore, a fire resulting from the ignition of these cables is not credible. Fixed ignition sources are absent in the plenum 6

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure space above the Control Room suspended ceiling, and air handling unit VA-67 above the suspended ceiling in the personnel complex area is a small, 2-horsepower unit that does not represent a potential ignition source. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.

The presence of the non-rated and non-protected wiring routed above the suspended ceilings in the Control Room and the personnel complex area does not impact fire protection defense-in-depth. The three echelons of defense-in-depth are 1) to prevent fires from starting (combustible/hot work controls); 2) rapidly detect, control and extinguish fires that do occur thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); and 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). The presence of this wiring does not affect echelons 1, 2 or 3. These cables introduce a negligible amount of combustible material into these plenum spaces, fixed ignition sources are negligible, and procedures govern the performance of hot work near combustible materials. Detection is not provided above these suspended ceilings, however, the Control Room and the personnel complex area are normally occupied areas that are both protected by automatic fire detection systems below the suspended ceilings, and fires will be detected manually or automatically in order that the appropriate actions can be taken to notify the fire brigade to begin fire suppression efforts. The wiring located above the suspended ceilings in the Control Room and personnel complex area does not directly result in compromising fire protection for systems and structures, automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability...

Fire Protection Engineering RAI 21:

Regarding LAR Attachment L, Request 1 and Table B-i, Section 3.3.1.2(1):

a. Please identify what other equipment, besides hand tools, is meant by "commonly available equipment".

OPPD's Response to Fire Protection Enqineeringq RAI 21 a:

"Commonly available equipment" as referred to in Attachment L, Approval Request 1 includes wood that is an integral part of portable tools, equipment, pallets or other apparatus.

b. For "commonly available equipment" other than hand tools:

i. Please clarify whether and how all untreated wood is administered under the combustible control program.

OPPD's Response to Fire Protection Engineering RAI 21 b.i:

Standing Order SO-G-91, Control and Transportation of Combustible Materials, administers untreated wood under the combustible control program as follows:

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U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure SO-G-91, Revision 28, Section 5.2.12: "All wood (except wood that is an integral part of portable tools, equipment, pallets or other apparatus) used within the Protected Area shall be treated with a flame retardant."

SO-G-91, Revision 28, Section 5.2.13: 'Wood (including that treated with flame retardant) shall not be retained in the Containment, Auxiliary Building or Intake Structure for longer than necessary to support an activity. It should be taken into these areas as near to the start of the activity as possible, and should be removed from the area as soon as possible following completion of the activity."

ii. Please clarify whether and how quantities will be within the transient and in-situ fire loads calculated in the fire hazards analysis (FHA), the fire probabilistic risk assessment (FPRA), and any associated fire modeling calculations.

OPPD's Response to Fire Protection Engineeringq RAI 21 b.ii:

The fire loads calculated in the fire hazards analysis provide for a token quantity for miscellaneous combustibles that are not typically figured into combustible loading calculations. This value is equal to 5 percent of the existing fixed and general area combustibles for each area. The amount of untreated wood is negligible and limited to hand tools and other commonly available equipment as identified in the response to part (a) of this question, and is considered to be within this 5 percent token value.

The fire PRA does not explicitly credit the use of fire retardant wood to reduce or otherwise modify the postulated transient fire Heat Release Rates (HRR). With the exception of FC32 and FC41 as discussed in response to PRA RAI 07, the 98th percentile transient fire HRR of 317 kilowatts (kW), per Table G-1 of NUREG/CR-6850, was implemented for all postulated transient fire scenarios. This HRR prescribed by NUREG/CR-6850 implicitly considers fire retardant wood to the extent that this value was developed by reviewing actual nuclear power plant (NPP) fire events, and to the extent that treatment or non-treatment of wood contributed to those events. Because FCS is not considered an outlier with respect to its restrictions placed on non-treated wood, the HRR value prescribed by NUREG/CR-6850 is considered applicable without modification.

iii. Please clarify whether and how any loading that exceeds the permissible loadings will be reviewed by a fire protection engineer to identify and implement any special precautions or limitations.

OPPD's Response to Fire Protection Engineering RAI 21 b.iii:

The plant's combustible loading calculation provides for a token quantity for miscellaneous combustibles that are not typically figured into combustible loading calculations. This value is equal to 5 percent of the existing fixed and general area combustibles for each area. The amount of untreated wood is negligible and limited to hand tools and other commonly available equipment as identified in the response to part (a) of this question, and is considered to be included in this 5 percent token value.

Regardless, any loading that exceeds the permissible loadings for an area is reviewed by a fire protection engineer to identify and implement any special precautions or limitations in accordance with SO-G-91. This procedure identifies that if the additional British Thermal Units (BTU) load in a fire area or fire zone is less than 12,620 BTU/square foot (ft2) per work area, the loading amount is considered bounded by the fire hazards 8

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure analysis and the combustible loading calculation and no additional compensatory measures are required. Above this value, fire watches are required, and above 240,000 BTU/ft 2, the guidance of the fire protection engineer is required.

iv. Please provide justification on the acceptability of any untreated wood in close proximity of ignition sources or equipment important to safety.

OPPD's Response to Fire Protection Engineering RAI 21 b.iv:

The amount of untreated wood is negligible and limited to hand tools and other commonly available equipment as identified in the response to part (a) of this question. In addition, as identified in the response to part (b.i) of this question, wood shall not be retained in areas important to nuclear safety for longer than necessary to support an activity, and shall not be stored in these areas.

v. Please clarify whether and how this performance-based method does not change the assumptions and limitations of the analytical methods used in the development of the FPRA.

OPPD's Response to Fire Protection Engqineering RAI 21 b.v:

The fire PRA does not explicitly credit the use of fire retardant wood to reduce or otherwise modify the postulated transient fire Heat Release Rates (HRR). With the exception of FC32 and FC41 as discussed in response to PRA RAI 07, the 98th percentile transient fire HRR of 317 kW, per Table G-1 of NUREG/CR-6850, was implemented for all postulated transient fire scenarios. This HRR prescribed by NUREG/CR-6850 implicitly considers fire retardant wood to the extent that this value was developed by reviewing actual NPP fire events, and to the extent that treatment or non-treatment of wood contributed to those events. Because FCS is not considered an outlier with respect to its restrictions placed on non-treated wood, the value prescribed by NUREG/CR-6850 is considered applicable without modification.

vi. Please clarify whether and how untreated wood within the power block will directly compromise fire protection for systems and structures, or post-fire safe shutdown capability.

OPPD's Response to Fire Protection Engineeringq RAI 21 b.vi:

The amount of untreated wood in the power block is negligible and limited to hand tools and other commonly available equipment as identified in the response to part (a) of this question. In addition, as identified in the response to part (b.i) of this question, wood shall not be retained in areas important to nuclear safety for longer than necessary to support an activity, and shall not be stored in these areas. This minimal amount of untreated wood in the power block will not compromise fire protection for systems and structures, or post-fire safe shutdown capability.

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U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Fire Protection Engineering RAI 22:

Attachment L, Request 2 states that "a significant portion of transient combustible material at FCS consists of temporary scaffolding that is constructed in place or combustible equipment/supplies that are not easily relocated due to size, weight or bulk."

a. Please identify the "combustible equipment/supplies that are not easily relocated due to size, weight or bulk." Provide several examples of equipment/supplies that fall into this category.

b. Please clarify what limitations and administrative controls are in place to:

i. Limit the combustible load/quantity.

ii. Limit the type of combustible material.

iii. Limit the total time present within the power block.

c. The request makes the statement that an hourly fire watch would be an appropriate compensatory measure to address these additional combustibles. The staff notes that from a risk perspective, periodic fire watch patrols (hourly) do not provide a significant risk reduction as a compensatory measure. Please provide a quantitative analysis that demonstrates that an hourly fire watch patrol would adequately compensate for the increased fire risk of a substantial increase in combustible fuel load.

d. From a combustible loading standpoint, treated wood used in temporary scaffolding constructed in place does not present a major fire risk. The staff sees the request to be exempted from the requirement to remove this combustible material at the end of the shift as reasonable. However, the request and its associated acceptance criteria evaluation must be revised to address the limited scope of this request. Other aspects of scaffolding need to be evaluated and addressed as necessary on a case-by-case basis. The NRC staff cannot make a blanket approval of scaffolding installations since numerous other considerations must be addressed.

For instance, the installation of substantial quantities of scaffolding can adversely impact fire detection and both automatic and manual fire suppression functions.

Please provide justification for the statement that the introduction of temporary scaffolding that is constructed in place does not impact fire protection defense-in-depth. The installation of scaffolding can have a significant impact on fire detection and suppression systems due to obstruction of air flow and to manual suppression due to physical access to fight fires.

Scaffolding can also have an adverse impact on safety margins. Scaffolding can result in significant degradation of detection and suppression system effectiveness, resulting in response substantially below assumptions in approved codes and standards. Please provide justification for the statement that following the introduction of temporary scaffolding... "the safety margin inherent in the analysis of the fire event has been preserved."

e. As presently written, the request discusses "combustible equipment/supplies that are not easily relocated due to size, weight or bulk" with no discussion of limitations and/or controls with regard to combustible loading. Significant increases in combustible loading can have an adverse impact on safety margins since the increase 10

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure could result in fire size exceeding the capability of installed suppression systems to control and extinguish the fire. In addition, additional combustible loading can result in fuel loading outside the assumptions used in designing the systems in accordance with NFPA codes and standards (NFPA 13, 15, etc.). Please provide additional justification for the statement that this performance-based change will preserve the safety margin in the fire protection program.

OPPD's Response to Fire Protection Engineering RAI 22:

Item d. of this question states, "...treated wood used in temporary scaffolding constructed in place does not present a major fire risk. The staff sees the request to be exempted from the requirement to remove this combustible material at the end of the shift as reasonable. However, the request and its associated acceptance criteria evaluation must be revised to address the limited scope of this request." Given the fact that this request is limited to temporary scaffolding, which is constructed of treated wood, Attachment L, Approval Request 2 is considered no longer necessary and is considered deleted from the LAR. The revised response to NFPA 805 Section 3.3.1.2(3), is as follows:

NFPA 805 Compliance Compliance Basis Reference Document Ch 3 Ref Statement 3.3.1.2(3)

• Complies No Additional Clarification Standing Order SO-G-91, Control of "Control and Transportation of Combustible Combustible Materials," Rev.

Materials 25 / sections 5.2.11 and 1_ 1_5.2.11 A through 5.2.11 .C.3 The revised response to NFPA 805 Section 3.3.1.2(3), as well as the revised Attachment L, will be reflected in the NFPA 805 transition LAR supplement. [AR 48249].

Fire Protection Engineering RAI 23:

In EA-FC-95-022, the referenced EEEE code compliance for NFPA 511B, "Standard for Fire Prevention During Welding, Cutting, and Other Hot Work," refers to (Implementation Item)

REC-033 regarding a conflict meeting Section 3-1(b) of NFPA 51B. However, REC-033 is not identified in the LAR. This appears to be an oversight. If not, please provide justification for not including REC-033 in the list of items needing to be completed during NFPA 805 implementation in Attachment S-3.

OPPD's Response to Fire Protection Engineering RAI 23:

REC-033 was originally created to address a conflict meeting Section 3-2(b) of NFPA 51B during multiple iterations of EA-FC-95-022, "NFPA Code Compliance" for the NFPA 805 transition project.

An earlier revision of the EA was mistakenly placed on the FCS NFPA-805 transition LAR web portal for NRC review. OPPD has since placed the correct version of EA-FC-95-022, Revision 4, (which is the revision referenced in Attachment A of the Transition Report, and does not include Implementation Item REC-033 and is pending OPPD owner acceptance reviews) on the portal.

The current compliance statement for Section 3-2(b) of NFPA 51 B is as follows:

11

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure NFPA 51B-1999 Edition, Section 3-2: COMPLIES WITH CLARIFICATION. The current Nonpermissible Areas. Hot work shall not standard of care for hot work (NFPA 51 B-2009 Edition) be allowed in the following areas: allows hot work in buildings with impaired sprinkler (b) In sprinklered buildings while such protection, provided that the requirements of NFPA 25 protection is impaired. are met. FCS meets the requirements in Chapter 15, "Impairments" of NFPA 25-2008 Edition, and has a process in place for addressing impaired equipment (SO-G-28). Based on compliance with the newer standard of care, the intent of this requirement is satisfied.

Fire Protection Engineering RAI 24:

In Table B-i, Section 3.3.1.3.1, the referenced procedure, SO-M-9, allows roving hot work fire watches. This does not meet the requirements or intent of NFPA 51B nor branch technical position (BTP) 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," requirements.

Based on the staff's review of SO-M-9, the document should be revised to be compliant with the requirements of NFPA 51 B, or NRC approval should be requested. If the licensee desires to include roving hot work fire watches in the performance-based NFPA 805 fire protection program, please submit a request in accordance with 10 CFR 50.48(c)(2)(vii) and provide justification that the change meets the requirements for risk, DID and safety margins.

OPPD's Response to Fire Protection Engineering RAI 24:

Standing Order SO-M-9, Hot Work Operations, has been revised to be compliant with the requirements of NFPA 51B with respect to the disallowance of roving hot work fire watches.

Revision 30 of SO-M-9 removes the definition of "roving fire watch" and associated procedural steps referring to it. The updated LAR transition report Attachment A (Table B-i), with this correction to the reference document and removal of discussion of "roving fire watch", will be reflected in the NFPA 805 transition LAR supplement [AR 48249].

Fire Protection Engineering RAI 25:

In regards to Table B-i, Section 3.3.1.3.4, implementation Item REC-004 will update plant procedure FCSG-15-11 to include "prohibit[ing] the use of portable fuel-fired heaters in safety related areas..." NFPA 805 Section 3.3.1.3.4 states that portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety. Please provide justification that prohibiting fuel fired heaters in only safety related areas will encompass all plant areas containing equipment important to nuclear safety.

OPPD's Response to Fire Protection Engineeringq RAI 25:

REC-004 will be revised as follows: "Guideline FCSG-1 5-11, "Fire Prevention Plan," will be revised to address the control of electric heaters and prohibit the use of portable fuel-fired heaters in the power block. This revision is being tracked by EC 50741 and will be completed as part of LAR implementation." The updated LAR Transition Report Attachment A (Table B-i) and Attachment S, with these corrections to implementation item REC-004, will be reflected in the NFPA 805 transition LAR supplement [AR 48249].

Fire Protection Engineerinq RAI 26:

Attachment L Request 4 is not clear as to exactly what is requested. Table B-1 Sections 3.5.3

& 3.5.6 indicates the request is only for the remote stopping of fire pumps. In contrast, only the acceptance criteria evaluation section of Attachment L Request 4 mentions the ability to 12

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure remotely stop the fire pump (FP-1A). The main body, including the basis for request and conclusion sections, indeterminately present various code requirements beyond the remote stopping requirement in a way that generates confusion as to what exactly is being requested.

a. NFPA 805 does not contain a specific requirement regarding remote stop features; however, NFPA 20, "Standard for the Installation of Stationary Fire Pumps for Fire Protection," Section 7-5.2.3 does prohibit such features. Please identify, clearly and concisely, the exact request(s) asked for and include the associated code requirement(s). Clarify the purpose and the intended scenarios regarding the use of this remote stop switch.

OPPD's Response to Fire Protection Engineering RAI 26 a:

The requests for NRC approval in Attachment L, Approval Request 4 are the following:

1. NFPA 805 Section 3.5.3 requires compliance with NFPA 20. Section 7-5.2.3 of NFPA 20, 1996 Edition, which is the code of record for fire pumps at FCS, requires "...Where additional control stations for causing non-automatic continuous operation of the pumping unit, independent of the pressure-actuated switch, are provided at locations remote from the controller, such stations shall not be operable to stop the motor." OPPD is requesting a deviation to compliance with NFPA 20 to allow the electric fire pump motor to be stopped from the Control Room.

2. NFPA 805 Section 3.5.6 requires that "Fire pumps shall be provided with automatic start and manual stop only." OPPD is requesting a deviation from this requirement to allow the feature for the electric fire pump hand switch to be placed in the pull-to-lock position which prevents it from starting automatically.

See the revised request for NRC approval in the response to RAI 26 d.

b. The request addresses the function of the PULLOUT switch under normal circumstances. The request does not address the impact on the fire protection program (FPP) of a fire in the MCR. Please describe the possible failure modes of the PULLOUT switch and their impact on the fire protection water supply. Please identify if there are any fire-induced failure modes that can either prevent the automatic starting of pump PlA or stop PlA once automatically or manually started. If fire-induced damage can stop the operation of PlA, provide justification for the acceptability of this condition.

OPPD's Response to Fire Protection Engineering RAI 26 b:

Spurious trip of the electric fire pump control switch, or failure of electric fire pump FP-1A to start upon operation of this switch, can occur as a result of power and/or control cable failures to breaker 1A1-0 cables associated with this switch, in any fire area in which these cables are routed. Failure of FP-1A to start due to failure of the control switch circuit will not have an impact on the fire protection water supply. Diesel fire pump FP-11B is available in all of these areas, and will start on a low water pressure signal upon failure of FP-1A to start.

Further, there are no circuits in the Control Room that would disable FP-1 B if damaged due to fire. Additionally, alarms are provided in the Control Room for motor-driven fire pump trouble (caused by actuation of the control switch) and for fire protection header low pressure, both of which require an operator to report to the fire pumps to ensure operability.

13

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure There is no water suppression system in the Control Room, so failure of FP-1A due to a fire in the Control Room would not reduce the level of fire protection afforded to this area.

c. In addition, Attachment L Request 4 describes the FP-1A remote stop switch as an existing pullout switch which also overrides the pump's automatic start capability when in the PULLOUT position. This preventing or overriding the automatic start of a fire pump is not in compliance with NFPA 805 Section 3.5.6; however, Attachment L, Request 4 does not appear to include this as a specific request. Please clarify whether a request is needed for the pullout switch's ability to override the automatic start function. Please clarify the purpose and the intended scenarios regarding the use of this remote pullout switch.

OPPD's Response to Fire Protection Engineering RAI 26 c:

OPPD is requesting approval for a deviation from the requirements in NFPA 805 Section 3.5.6 for the control switch's ability to override the automatic start function when placed in pull-to-lock.

The operation of this switch in pull-to-lock is limited to occasions such as during maintenance activities, post-fire, or testing when a fire is NOT in progress (e.g., pipe failure, or when the pump is not needed after the fire is extinguished, or when the fire pumps are being tested in accordance with operating instruction procedure OI-FP-1). At any time the pump is not in auto (i.e., the switch is in the pull-to-lock position), a fire impairment is required and restoration of the pump is governed by SO-G-103, Fire Protection Operability and Surveillance Requirements.

See the revised request for NRC approval in the response to RAI 26 d.

d. As necessary, the Attachment L Request 4 discussions on safety margin and DID should be revised to account for all its identified requests (e.g. automatic start override, remote stop, etc).

OPPD's Response to Fire Protection Engineering RAI 26 d:

Attachment L Request 4 is revised as follows (changes indicated by revision bars in the margin):

Approval Request 4 NFPA 805 Section 3.5.3 NFPA 805 Section 3.5.3 states:

"Firepumps, designed and installed in accordance with NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largestpump or pump power source."

NFPA 20, 1996 Edition, Section 7-5.2.3 NFPA 20, 1996 Edition, Section 7-5.2.3 states:

14

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure "Manual Electric Control at Remote Station. Where additional control stations for causing non-automatic continuous operation of the pumping unit, independent of the pressure-actuatedswitch, are provided at locations remote from the controller, such stations shall not be operable to stop the motor."

NFPA 805 Section 3.5.6 NFPA 805 Section 3.5.6 states:

"Firepumps shafl be provided with automatic start and manual stop only."

Both the diesel engine-driven (FP-1B) and electric motor-driven (FP-1A) fire pumps are normally configured for automatic start on low system pressure. Both pumps require manual operation to stop once started. For FP-1 B, the manual operation to stop must be performed locally at the pump controller. However, FP-1A can be stopped locally at the pump, locally at the associated 4160 V switchgear, and remotely in the Control Room by use of a control switch. In addition, the control switch in the Control Room can be locked in the pull-to-lock position to override automatic start of FP-1A. An alarm will be received in the Control Room when the control switch is placed in pull-to-lock, precluding inadvertent performance of this action. No action in the Control Room can override automatic start of FP-1 B.

In the case where FP-1A is stopped, either remotely or locally, the redundant fire pump FP-1 B will activate when the fire water supply header pressure drops below 100 psi or if FP-1A fails to start within 10 seconds of an automatic signal.

OPPD requests NRC approval of deviation from the following sections of NFPA 805:

1. NFPA 805 Section 3.5.3 requires compliance with NFPA 20. Section 7-5.2.3 of NFPA 20, 1996 Edition, which is the code of record for fire pumps at FCS, requires

"...Where additional control stations for causing non-automatic continuous operation of the pumping unit, independent of the pressure-actuated switch, are provided at locations remote from the controller, such stations shall not be operable to stop the motor." OPPD is requesting a deviation to compliance with NFPA 20 to allow the electric fire pump motor to be stopped from the Control Room.

2. NFPA 805 Section 3.5.6 requires that "Fire pumps shall be provided with automatic start and manual stop only." OPPD is requesting a deviation from this requirement to allow the feature for the electric fire pump hand switch to be placed in the pull-to-lock position which prevents it from starting automatically.

Basis for Request:

The basis for the approval request of this deviation is:

Redundant fire pump FP-11B will automatically activate in the case where FP-1A has stopped or has not started after automatic signal.

There are administrative controls placed over the use of the Control Room pullout switch to stop or disable FP-1A. The operation of this switch is limited to occasions when a fire is NOT in progress (e.g., pipe failure or when the pump is not needed after the fire is extinguished, or when the fire pumps are being tested in accordance with operating instruction procedure OI-FP-1).

15

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure Placing the switch in the pull-to-lock position results in FP-1A being non-functional per SO-G-103, Fire Protection Operability and Surveillance Requirements. SO-G-103 requires that when this switch is actuated, either a dedicated operator be stationed at the Control Room switch and briefed on the required actions to be performed in the event water is needed for the fire suppression water system, or contingencies are required to maintain the fire protection system operable, such as ensuring that FP-11B remains available.

Acceptance Criteria Evaluation:

Nuclear Safety and Radiological Release Performance Criteria:

The means of remotely stopping FP-1A and remotely disabling FP-1A do not affect nuclear safety. When this switch is in the pull-to-lock position, whether to stop the pump or to keep the pump from starting, FP-1A is considered non-functional and contingency actions are required per standing order SO-G-103, Fire Protection Operability and Surveillance Requirements, unless a dedicated operator has been assigned. The dedicated operator must be stationed at the Control Room switch and must be briefed on the required actions to be performed in the event that water is needed for the fire suppression water system. SO-G-103 requires one pump to be functional at all times if the other pump is unavailable, and contingencies are in place if both FP-1A and FP-1B are non-functional, regardless of the position of the control switch in the Control Room.

The use of this switch does not result in the fire protection system being outside of the guidelines of the plant's system operability procedure. Failure of FP-1A would not render FP-1B non-functional; therefore, there is no adverse impact on nuclear safety performance criteria.

The means of remotely stopping FP-1A and remotely disabling FP-1A have no impact on the radiological release performance criteria. These criteria are achieved through engineered controls for the containment of water and smoke, and they do not rely upon the availability of the fire protection water supply system.

Safety Margin and Defense-in-Depth:

Electric motor-driven fire pump FP-1A operates automatically and is monitored and controlled by trained operators. Failure of the fire pumps to operate alarms in the Control Room, and operations procedures require the fire pumps to be verified functional upon receipt of these alarms. Use of the control switch in the Control Room to stop or disable FP-1A is strictly controlled by procedure, and its improper operation or failure would result in alarms to alert the Control Room. The use of this switch to stop or disable FP-1A renders FP-1A non-functional per the functionality requirements of SO-G-103, and contingencies are required to maintain the fire protection water supply system in service, regardless of whether the functionality of FP-1A is a result of placement of the Control Room control switch. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.

The three echelons of defense-in-depth are 1) to prevent fires from starting (combustible/

hot work controls); 2) rapidly detect, control and extinguish fires that do occur thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); and 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, 16

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure recovery actions). The capability to stop FP-1A from the Control Room or to disable FP-1A from the Control Room does not affect echelon 1, as the fire pumps are not credited for fire prevention. Echelon 2 is met because the use of this means to stop or disable FP-1A does not impair the fire protection system outside of the guidelines of SO-G-103.

SO-G-103 requires that the fire protection water supply system remain functional, and contingencies are required if the system is considered non-functional, regardless of the position of the control switch in the Control Room. Echelon 3 is met because failure of FP-1A due to the position of or failure of the Control Room control switch will not prevent essential safety functions from being performed. FP-1 B remains available to supply water to the fire protection system. The capability to stop FP-1A from the Control Room or to disable FP-1A from the Control Room does not result in compromising automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability.

Conclusion:

" FCS determined that the performance based approach utilized to evaluate a variance from the requirements of NFPA 805 Chapter 3:

" Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release;

" Maintains safety margins; and

" Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

Fire Protection Engineerinq RAI 27:

NFPA 805 Section 3.6.1 states all power block buildings shall have a Class III standpipe and hose system installed in accordance with NFPA 14, "Standard for the Installation of Standpipes and Hose Systems." Table B-1 Section 3.6.1 indicates "Submit for NRC Approval" via Attachment L, Request 6 for use of hose lengths greater than allowed by NFPA

14. The Attachment L, Request 6 introduction mentions the cable spreading room (CSR) and containment; however, the discussions only include the CSR. In addition, LIC-77-0103 (9 77), and respective NRC letter dated 10-17-77, appear to grant previous NRC approval for lack of hose stations inside containment which is not claimed. Please clarify whether previous approval, if valid, will be claimed for lack of hose stations inside containment. If claimed, revise Table B-i, Section 3.6.1 to include the appropriate compliance statement. Please reference any applicable documentation.

OPPD's Response to Fire Protection Engineerincq RAI 27:

The request for NRC approval in Attachment L, Approval Request 6, is limited to the cable spreading room because the absence of hose stations in containment was previously approved by the NRC.

Excerpts of the NFPA 805 Attachment A, Table B-i, Section 3.6.1, which includes the revision to the Compliance Statement, the Compliance Basis and the applicable reference documents for previous approval are provided below with new text delineated by revision bars. These revisions to Table B-1 will be reflected in the NFPA 805 transition LAR supplement [AR 48249].

Note that, after further OPPD review, it was identified that clarification of NRC approval is required for a portion of this previous approval, which will be reflected in Attachment T of the NFPA 805 transition LAR supplement [AR 48249] and is also included below in this RAI response.

17

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure NFPA 805 Compliance Compliance Basis Reference Document Ch 3 Ref Statement I 3.6.1 " Complies by COMPLIES BY PREVIOUS NRC EA-FC-95-022, "NFPA

[Standpipe Previous APPROVAL: Code Compliance," Rev. 4 /

and Hose NRC Per the response to question 9 in the Attachment 11 Station Code Approval enclosure to Letter LIC-77-0103, "Initial Requirements] " Complies suppression of fires inside containment EA-FC-97-041, "Analysis of with Use of will be by manual use of portable Manual Hose Station EEEEs extinguishers. As noted in the Locations," Rev. 0 / All

" Submit for Licensee's report, there are five 10-lb NRC and five 20-lb dry chemical EC 50741, "License Approval extinguishers, as well as two 15-lb Amendment Request

" Complies, carbon dioxide extinguishers. In case LAR10-07; NFPA 805 Fire with additional fire suppression capability is Protection Transition Required required, a hose line could be brought Project #10000092" Action in from the auxiliary building through the containment airlock. This hose line NFPA 14, "Standard for the would provide fire suppression Installation of Standpipe, capability in the cable penetration Private Hydrant, and Hose area." Systems," 1996 Edition / All Per Section 5.20.4 of Enclosure 2 to Letter LIC-76-0180 from NRC-78-0104, "Eleven portable Short (OPPD) to Lear extinguishers are distributed (NRC) dated December 30, throughout the area. Containment 1976 / Attachment, fire area HVAC charcoal filters are equipped 30 with a deluge system supplied by the containment spray system." Letter LIC-77-0103 from Per Section 5.20.5, "Portable Short (OPPD) to Lear extinguishers are inadequate to (NRC) dated September suppress a fire involving reactor 27, 1977 / Enclosure, coolant pump lubrication oil. Access for Question 9 fire fighting would be difficult due to smoke which may be produced by the Letter NRC-78-0104 from fire and due to radioactivity associated Reid (NRC) to Short with the area." (OPPD) dated August 23, Per Section 5.20.6, "One additional 1978 / Enclosure 2, Safety portable extinguisher will be provided. Evaluation Report, section The licensee has also agreed to 5.20 provide one of the following:

Letter NRC-80-0233 from (1) A lube oil collection system to NRC to Jones (OPPD) contain lube oil leakage and to drain dated December 18, 1980/

leaked oil to a safe place. Page 4 (2) A fire suppression system to control a lube oil fire and to protect the reactor components from that fire.

(3) A study for NRC consideration which includes a detailed evaluation of the installation of the lube oil collection system and the lube oil fire suppression system, and a detailed analysis that shows the facility can be safely shutdown in the event of an unmitigated lube oil fire. The unmitigated fire analysis will consider, 18

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure but is not limited to, localized effects of the fire, effects on containment filters and other combustibles in the containment, as well as pressure and temperature effects throughout the containment building.

The staff's evaluation of the licensee's analysis or proposed modification will be addressed in a supplement to this report."

Per Page 4 of Letter NRC-80-0233, "The licensee was required by Fire Protection Safety Evaluation Report (SER) to complete all items listed in Table 3.1 of the SER by November 1, 1980. The inspector has determined through observations, records review and discussions with licensee representatives that all items were completed by November 1, 1980 with the exception of monitoring of three additional fire doors."

COMPLIES WITH USE OF EEEEs:

Standpipe and hose systems comply with NFPA 14-1996 Edition as evaluated in EA-FC-95-022.

SUBMIT FOR NRC APPROVAL:

NRC approval of the use of lengths of hose at hose stations greater than lengths allowed by NFPA 14 is being requested in Attachment L of the Transition Report, Item 6.

NRC clarification of the approval of fire protection in containment (fire area 30) is requested in Attachment T, with respect to the presence of a deluge system protecting the HVAC charcoal filters.

The following text will be reflected in Attachment T of the NFPA 805 transition LAR supplement:

Prior Approval Clarification Request 13 Current Licensing Basis:

By safety evaluation report dated August 23, 1978 (NRC-78-0104), the NRC accepted the fire protection configuration in containment upon completion of modifications. By letter dated December 18, 1980 (NRC-80-0233), the NRC confirmed that the modifications required in 19

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure containment were completed and the fire protection configuration in containment was deemed acceptable. Part of the basis for acceptability of the configuration in NRC-78-0104 was the presence of a deluge system supplied by the containment spray system protecting the HVAC charcoal filters. This statement requires clarification.

Background/Basis:

OPPD's description of containment in its response to Appendix A to BTP APCSB 9.5-1, dated December 30, 1976 (LIC-76-0180), identified that a high temperature deluge system exists for the charcoal HVAC filters. The report goes on to describe this system as follows:

"The primary source of combustibles on the operating level are the charcoal filters. The postulated fire may spread from the initial location to a maximum of one-half the total filters. The filter fire in itself would cause no damage to safety related equipment, other than the ventilation system. A charcoal fire is relatively isolated by the structure of the filter assembly. These are dampers, mist extractors, and absolute filters in front of the charcoal filters. After the filters there is a long section of ventilation ducting leading to the ventilation fans. These features can be expected to contain the charcoal fire in the filter assembly. A deluge system which receives containment spray water is installed in these filters. The deluge system is manually initiated. No safety related cable trays are at this evaluation. This postulated fire would not prevent safe shutdown, nor cause radioactivity release outside the containment."

In its approval of the configuration of fire protection in containment, the NRC stated, in NRC-78-0104, "Containment HVAC charcoal filters are equipped with a deluge system supplied by the containment spray system."

Request:

This prior approval requires clarification that the deluge system supplied by the containment spray system to protect the containment HVAC charcoal filters is not a fire protection system meeting the requirements of NFPA 13. It was installed to suppress a fire post-LOCA that could be ignited due to high temperatures caused by decay heat from radionuclides accumulating in the charcoal filters, which is why the system is fed from the containment spray system and not the fire protection system. Its presence was never intended to be considered a part of the fire protection program and is not identified as a fire protection system in Table 4-3 or Attachment C of the NFPA 805 Transition Report. The system remains in place as approved in the 1978 SER; therefore, the bases for acceptability of fire protection in containment as listed in the SER remain valid and unchanged.

Fire Protection Enflineerinq RAI 28:

LAR Table 4-3 and Table B-3, for Fire Area 47, credits the transformer deluge water spray system as required for risk significance; however, Table B-i, Section 3.9.1(2), regarding compliance with NFPA 15, "Standard for Water Spray Fixed Systems for Fire Protection,"

states there are no water spray systems credited for NFPA 805. Please clarify the correct compliance statement. Revise Tables 4-3, B-i, and B-3 as applicable to reflect correct compliance and credit.

20

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure OPPD's Response to Fire Protection Engineering RAI 28:

The transformer deluge water spray systems are credited for risk significance. The revised response to NFPA 805 Section 3.9.1(2) to correct this discrepancy, which will be reflected in the NFPA 805 transition LAR supplement [AR 48249], is as follows:

NFPA 805 Compliance Compliance Basis Reference Document Ch 3 Ref Statement 3.9.1(2) . Complies Transformer deluge water spray EA-FC-95-022, "NFPA Code

[Fire with Use of systems comply with NFPA 15 as Compliance," Rev. 4 /

Suppression EEEEs evaluated in EA-FC-95-022. Section 5.3.2 System Code Requirements]

21

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Safe Shutdown RAI 17:

LAR Attachment S for the proposed plant modification REC-117 states, "Modification to change the normal operating alignment for 480 V load center tie breakers BT-1B4A, BT-1B3B, and BT-1 B4C from normally open and racked-in, to normally racked-out (or otherwise disabled from spuriously closing due to fire damage to DC breaker control circuits in the opposite Train 4kV switchgear room, main control room, or cable spreading room). This modification addresses the issue associated with electrical failure resulting from spurious connection of out-of-synch power sources (offsite power to diesel generator, diesel generator to diesel generator).

The LAR for REC-117 also states, "The proposed modification will maintain breaker manual trip capability from main control room, protective trip, automatic load shed trip and accident signal trip for fire areas 36A, 36B, 41 and 42."

According to NRC Special Inspection Report dated March 12, 2012 (ADAMS Accession No ML12072A128), there are interconnecting control wires (operated at 125 V DC) between 480V tie breakers in Electrical Switchgear Fire Areas 36A (East Switchgear) and 36B (West Switchgear) (typical - between breakers BT-11B3A and BT-11B4A). These wires are used in the control circuitry of the breakers. A fire in these breakers in either Switchgear Fire Area 36A or 36B can cause damage to the control wires (such as shorts to ground) in the opposite area breakers.

Considering the fire scenario explained in the above inspection report (fire across an open tie breaker BT-11B4A), explain how modification REC-117 will eliminate the damage to the interconnecting control wires between any two tie-breakers located in opposite fire areas, and thus potentially adversely impacting the operation of the opposite area/train tie-breaker.

Please provide a schematic diagram for each of these breakers (typical) having interconnecting wires between the fire areas 36A and 36B. Also, provide time-overcurrent coordinating curves of the control fuses of these breakers and the next upstream protective devices.

OPPD's Response to Safe Shutdown RAI 17:

The modification described in REC-117 will not eliminate damage to the interconnecting control wires, the modification will eliminate the impact that damage to the wiring could potentially have on safe shutdown (i.e., prevent spurious operation of a normally opened tie breaker). By racking out the normally open breaker (or otherwise disabling the breaker from closing), or providing some other method of separation, it can be ensured that during a fire event in the opposite switchgear, the normally open breaker will not spuriously close thereby connecting the unaffected train to the affected train. Note that as shown on the breaker schematic for BT-11B4A (11405-E-18, sheet 3, typical) the trip and close circuits are fused separately. Only the close circuit is impacted by the cross train interlock addressed by REC-1 17. The trip circuit will remain available. Also note that the protective overcurrent trip for the 480V load center breakers is not dependent on the breaker close or trip control circuits remaining free of fire damage, nor is it dependent on availability of DC control power to the breaker. Once tripped on overcurrent, a breaker cannot be reclosed until locally reset.

22

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Additionally, as can be seen from the coordination curves in Attachment 1, the 30-Amp NON fuse coordinates with the 100-Amp, 125VDC breaker (EE-8F-CB14) which feeds the 480 VAC switchgear control power. Note that the 30-Amp fuse represents worst case coordination as the other fuses in the breaker control circuits are rated at 6-Amp and 10-Amp. This coordination ensures that while the control circuit fuses may be blown during a fire event, the upstream circuit breaker coordinates with the fuse to ensure that control power remains available to the bus. In summary, separation is maintained by:

1) Disabling the normally open tie breaker to prevent spurious closing

2) The use of selective coordination which ensures that only the affected, non-credited circuits would be lost during a fire event, and that control power remains available to support the credited safe shutdown equipment.

The schematic drawings listed below are provided in Attachment 2 for the associated breakers:

• 480V Bus Tie Breaker BT-1B3A (Unit 104B), 11405-E-18, Sheet 2 (File 57303)

• Bus Tie Bkr BT-1 B4A (Unit 200B), 11405-E-18, Sheet 3 (File 57304)

• 480V Transf. Sec. Bkr. 1B3A (Unit 101B), 11405-E-19, Sheet 2 (File 57310)

• 480V Bus Tie Bkr 1B4A (Unit 203B), 11405-E-19, Sheet 5 (File 57313)

" Simplified One-Line Diagram Plant Electrical System P&ID, Figure 8.1-1 (File 12234) 23

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure Probabilistic Risk Assessment RAI 01.d.01:

By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.d that the root cause of the peer reviewer-identified errors were "challenges reading the cable and raceway layout drawings...." This does not appear to be the cause of the specific error identified by the peer reviewer, who noted that four highly risk significant cable trays were not included as targets for ignition source FC36A-IS13 even though these cable trays were correctly identified in both the initial walkdowns and data verification walkdowns. In this case, the error appears to be due to incorrect transposition of the targets identified on the walkdown data sheets into the FPRA FSS database. Please explain how the sampling study, and other plant processes if applicable, addressed the potential for walkdown sheets-to-FSS database transposition errors. Indicate how these processes provide confidence that these types of errors were addressed.

OPPD's Response to Probabilistic Risk Assessment RAI 01 .d.01:

The walkdown data collection and entry into the fire scenario selection (FSS) database were subject to a quality assurance program that included authorship and verification. The discrepancy identified during peer review does represent an error that was not caught by the quality assurance process. As an aside, note that the raceways failed per fire scenario were identified via drawing review and not field walkdown.

The large sampling study performed in response to this error was designed as a diverse method for collecting the fire scenario target data. That is, the original process identified all targets within each fire scenario's zone-of-influence. In the sampling study, risk-significant cables were traced throughout the plant, and each fire scenario that could affect each cable was identified. This study and resulting improvements to the fire PRA data provided OPPD confidence that the source-target data are adequate for the purposes of the fire PRA and its application to NFPA 805. No further sampling or validation was determined necessary.

Recognizing the enormity of the fire PRA dataset, it is not inconceivable that infrequent errors related to other types of field data could have occurred. However, subsequent to the peer review, the exercising of the fire PRA model for the NFPA 805 application has provided many opportunities to re-walkdown fire scenarios and other elements of the PRA important to the NFPA 805 transition.

Response to NRC audit questions and RAIs provided additional walkdown opportunities. The walkdowns often included engineers new to the project, providing "fresh eyes". These efforts over the

-2.5 years since the peer review have not identified vulnerabilities regarding the accuracy of walkdown data.

Probabilistic Risk Assessment RAI 01 .i.01:

By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.i. Please address the following issues identified in the response to PRA RAI O1.i:

a. The sensitivity case ACDF for FC 20-1 and FC 34B-1 are substantially lower than the corresponding values for the base case, whereas the ignition frequencies generally increased as did the ALERF values. Please explain this anomalous result.

24

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 01 .i.01 a.:

The FC20-1 sensitivity study case for VFDR ACDF was a typographical error; the correct value is 8.03E-08 /yr. As identified by this RAI, the increase between the base case and sensitivity case is expected given that the fire frequencies increased between these two cases. This error carried into the calculation, and its correction increased the total VFDR ACDF from 8.46E-06 /yr, as reported in the RAI response, to 8.53E-06 /yr. Correction of the error does not affect the total plant CDF within the significant digits reported in the RAI response.

The FC34B-1 sensitivity study case for VFDR ACDF was a typographical error; the correct value is 7.33E-08 /yr. As identified by this RAI, the increase between the base case and sensitivity case is expected given that the fire frequencies increased between these two cases. This typographical error did not carry into the calculation of VFDR ACDF or total CDF.

The R.G. 1.174 Region II acceptance criteria for ACDF, ALERF, total CDF, and total LERF remain met as reported in the RAI response. The remaining VFDR ACDF and ALERF values reported in the RAI response have been reviewed and verified to be correct.

b. The sensitivity case ACDF and ALERF for the CSR, FC 41, is substantially lower than the corresponding values for the base case, whereas the ignition frequencies generally increased. Based on Note 4, this appears to be due to different modeling assumptions between the two cases. Also, Note 4 states that the ACDF and ALERF values for the CSR may be modified as a result of analysis performed in response to PRA RAI 01j. Please provide the revised results for CDF/LERF/ACDF/ALERF for the CSR (FC41) based on these issues.

OPPD's Response to Probabilistic Risk Assessment RAI 01 .i.01 b.:

The total ignition frequency for FC41 increased for the sensitivity study case, as compared to the base case. However, the sensitivity study case VFDR ACDF and ALERF decreased, since the sensitivity case included credit for the alternate shutdown process implemented by AOP-06, whereas the base case did not credit alternate shutdown. The manner in which alternate shutdown was credited in the sensitivity study is consistent with the treatment in response to PRA RAI 01j.

Probabilistic Risk Assessment RAI 14.01:

By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 14 and stated that "In order to demonstrate compliance with RG 1.200, Rev 2, the Enclosure 1 of the LAR supplement dated December 22, 2011, (LIC-11-0136), has been revised". Table 6-3 of that enclosure, which includes justification of SRs previously assessed less than Capability Category II or not previously assigned a grade, has been considerably expanded.

In light of the fact that this revised document presents information key to demonstrating compliance to American Society of Mechanical Engineers/American Nuclear Society (ASME/ANS) "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Application," RA-Sa-2009, as clarified by RG 1.200, "An Approach For Determining The Technical Adequacy Of Probabilistic Risk Assessment Results For Risk-Informed Activities," Rev. 2, please provide this revised document as part of the RAI response.

25

U. S. Nuclear Regulatory Commission LIC-1 3-0033 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 14.01:

In response to PRA RAI 14.01, OPPD is providing a copy of letter LTR-RAM-II-10-046, Revision 3, "OPPD NFPA-805, Task 7.17: Fire PRA Self-Assessment, ASME/ANS RA-Sa-2009 Roadmap and Peer Review History for the Internal Events PRA and the Fire PRA of Fort Calhoun Station," dated June 8, 2012 (Proprietary) in Attachment 4. The Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-13-3675, the accompanying Affidavit, Proprietary Information Notice, and Copyright Notice are provided in Attachment 3 to this RAI response.

LTR-RAM-II-10-046, Revision 3 was prepared and classified as Westinghouse Proprietary Class 2.

Westinghouse requests that the document be considered proprietary in its entirety. As such, a nonproprietary version will not be issued. As LTR-RAM-II-10-046, Revision 3, contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit in Attachment 3 sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the NRC's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Probabilistic Risk Assessment RAI 19:

Transient fires should at a minimum be placed in locations within the plant PAUs where conditional core damage probabilities (CCDPs) are highest for that PAU, i.e., at "pinch points." Pinch points include locations of redundant trains or the vicinity of other potentially risk-relevant equipment, including the cabling associated with each. Transient fires should be placed at all appropriate locations in a PAU where they can threaten pinch points. Hot work should be assumed to occur in locations where hot work is a possibility, even if improbable (but not impossible), keeping in mind the same philosophy. Please describe how transient and hot work fires are distributed within the PAUs. In particular, identify the criteria for your plant which determines where an ignition source is placed within the PAUs. Also, if you have areas within a PAU where no transient or hot work fires are located since those areas are considered inaccessible, please define the criteria used to define "inaccessible."

Note that an inaccessible area is not the same as a location where fire is simply unlikely, even if highly improbable.

OPPD's Response to Probabilistic Risk Assessment RAI 19:

Consistent with the RAI text, the FCS fire PRA postulates transient fires at pinch points. Pinch points are defined as areas where the highest concentrations of cable trays exist within a given compartment, and where the 98th percentile heat release rate of a potential transient fire could damage those cable trays. High concentrations of conduits were also considered when identifying pinch points.

The fire PRA postulates transient fires caused by hotwork at the same locations as postulated general transient fires (i.e., at the pinch points). For cable fires caused by hotwork, response to RAI 01 .c.01 will include an analysis where hotwork-induced fire risk to every individual cable tray within a given compartment is quantified.

26

U. S. Nuclear Regulatory Commission LIC-13-0033 Enclosure The inaccessibility of a compartment was not used as a basis to screen transient fires from consideration.

Probabilistic Risk Assessment RAI 23:

HRA-Cl-01: Calculation FC07825 describes the post-fire human reliability analysis methodology and results. Please indicate if Set 1, Set 2, Set 3, or Set 4 criteria from Chapter 12 of NUREG/CR-6850 were used to characterize the human error failure probabilities.

Summarize your use of Set 1, Set 2, Set 3, and Set 4 criteria to characterize the failure probabilities associated with your HRA analysis. In particular, for the application of Set 2, please state if the Set 1 criteria were incorporated in the Set 2 definition. Please identify any deviations from the applied criteria from Chapter 12 of NUREG/CR-6850.

OPPD's Response to Probabilistic Risk Assessment RAI 23:

The OPPD fire HRA process that was peer reviewed uses elements of the guidance in NUREG/CR-6850, a process presented by Macleod, et. al., at the ANS PSA 2008 Topical Meeting, and the early draft version of NUREG-1921 available at the time the fire HRA was initiated in 2009. The OPPD fire HRA was discussed during the March 2012 NRC audit and made available to the NRC in FC07825, "Fire Human Reliability Analysis," prior to the audit. While the process does not rigorously implement the screening approach (i.e., Set 1, 2, 3 and 4 criteria) from NUREG/CR-6850 Chapter 12, the process does account for fire impacts on credited cues, environmental conditions along the travel path to the action location, environmental conditions at the action location, and increased stress due to the fire. The process also systematically evaluates dependencies between human failure events within the same sequence.

OPPD plans to upgrade the fire HRA to NUREG-1921 during the NFPA 805 implementation period.

While OPPD does not expect the HRA upgrade to change the overall conclusions of the NFPA 805 transition, OPPD will notify the NRC and provide a resolution plan if the upgrade causes any of the VFDR ACDF, ALERF, total CDF, and total LERF acceptance criteria to be exceeded.

27

LIC-13-0033 Enclosure, Attachment 1 Page 1 of 2 Safe Shutdown RAI 17 Response Breaker Coordination Curves Figure SSDRAI-17

LIC-13-0033 Enclosure, Figure SSDRAI-117 CURENT INAMPEWS low

e~1 2 3 4 671110 1 20 30 40 60 00ROMP t*I il~ Rib- ifso+i+t 1000 a0 7000 400 100 --- No 400 400. 300 200

• 200 100 90 IN 70 .70 so 60 40 40 31)--.- t- 30 20 -

10 I ,++*;

S 7

S -6 I

S 4 -4 3 3 2:

000 060 . .. 0.70 070 000o 0o0 050 040 040 030 0..

30 Bussmann 0 10 010 O00 01U 00U 00?

007 O.O7 OW 005 006 004 004 003 on5 001 001 -

001 2 3 4 506 ?9 10 20 3D 4o so 0070Img I IR AUNEK x 4 4 1 if Current Scale: x 10 Ref. Voltage: 125 TCC Name: EE-F-CB14 Check Curve Printout Drawn by- EN. April 2, 2013

LIC-13-0033 Enclosure, Attachment 2 Page 1 of 6 Safe Shutdown RAI 17 Response Schematic Drawings

" 480V Bus Tie Breaker BT-1 B3A (Unit 104B), 11 405-E-1 8, Sheet 2 (File 57303)

• Bus Tie Bkr BT-1 B4A (Unit 200B), 11405-E-1 8, Sheet 3 (File 57304)

• 480V Transf. Sec. Bkr. 1B3A (Unit 101 B), 11405-E-1 9, Sheet 2 (File 57310)

" 480V Bus Tie Bkr 1B4A (Unit 203B), 11405-E-1 9, Sheet 5 (File 57313)

• Simplified One-Line Diagram Plant Electrical System P&ID, Figure 8.1-1 (File 12234)

LIC-13-0033 Enclosure, Attachment 3 Page 1 of 8 Probabilistic Risk Assessment RAI 14.01 Response Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-1 3-3675 Affidavit, Proprietary Information Notice, and Copyright Notice for LTR-RAM-II-10-046, Revision 3

U0 Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CFTC-13-38 CAW- 13-3675 March 26, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-RAM-II-10-046, Rev. 3, "OPPD NFPA-805, Task 7.17: Fire PRA Self-Assessment, ASME/ANS RA-Sa-2009 Roadmap and Peer Review History for the Internal Events PRA and the Fire PRA of Fort Calhoun Station," June 8, 2012 (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3675 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, Westinghouse is not planning to issue a non-proprietary version.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Omaha Public Power District.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW- 13-3675, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, 1 4 J. A. Gresham, Manager Regulatory Compliance Enclosures

CAW- 13-3675 AFFIDAVIT STATE OF CONNCTICUT:

ss COUNY OF HARTFORD:

Before me, the undersigned authority, personally appeared C. M. Molnar, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

C. M. Molnar, Principal Engineer Regulatory Compliance

2 CAW- 13-3675 (I) I am Principal Engineer, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW- 13-3675 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW- 13-3675 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is contained in LTR-RAM-II- 10-046, Rev. 3, "OPPD NFPA-805, Task 7.17: Fire PRA Self-Assessment, ASME/ANS RA-Sa-2009 Roadmap and Peer Review History for the Internal Events PRA and the Fire PRA of Fort Calhoun Station" (Proprietary) dated June 8, 2012, for submittal to the Commission, being transmitted by Omaha Public Power District (OPPD) letter LIC- 13-0033 and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with documentation of the American Society of Mechanical Engineers (ASME) / American Nuclear Society (ANS)

RA-Sa-2009 Roadmap and Peer Review History for the Internal Events (IE) Probabilistic Risk Assessment (PRA) and the Fire PRA (FPRA) of Fort Calhoun Station (FCS), and may be used only for that purpose.

5 CAW- 13-3675 This information is part of that which will enable Westinghouse to:

(a) Support the Fort Calhoun Station License Amendment Request concerning its National Fire Protection Association NFPA-805 application.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of defending the technical basis for model adequacy for supporting an NFPA-805 risk informed application.

(b) Westinghouse can sell support and defense of analyses involving Westinghouse methods used for similar risk informed applications.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar reports and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information provided is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.

COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.