ML13127A395

License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 1 of 3

ML13127A395
Person / Time
Site:	Nine Mile Point
Issue date:	04/30/2013
From:	Costanzo C Constellation Energy Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME8899
Download: ML13127A395 (3)

Text

This letter forwards Security-Related Information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-Security Related Information upon removal of Enclosure 6.

Christopher R. Costanzo P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CENG.

a joint venture of Ocnsear 6gyeDF NINE MILE POINT NUCLEAR STATION April 30, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 1; Docket No. 50-220 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Request for Additional Information (TAC No. ME8899)

REFERENCES:

(a) Letter from K. Langdon (NMPNS) to Document Control Desk (NRC), dated June 11, 2012, License Amendment Request Pursuant to 10 CFR 50.90:

Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

(b) Letter from B. Vaidya (NRC) to K. Langdon (NMPNS), dated January 3, 2013, Nine Mile Point Nuclear Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805 (TAC No.

ME8899)

(c) Letter from C. R. Costanzo (NMPNS) to Document Control Desk (NRC), dated February 27, 2013, License Amendment Request Pursuant to 10 CFR 50.90:

Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Request for Additional Information (TAC No. ME8899) 1 This letter forwards Security-Related Information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-Security Related Information upon removal of Enclosure 6.

Z-oI

Document Control Desk April 30, 2013 Page 2 Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted request for amendment to Nine Mile Point Unit 1 (NMP 1)

Renewed Operating License DPR-63. The initial request, dated June 11, 2012 (Reference a), proposed the adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and 10 CFR 50.48(c); the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1; and National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition.

The supplemental information provided in Enclosure 1 to this letter responds to the following three requests for additional information (RAIs) documented in the NRC's letter dated January 3, 2013 (Reference b): Safe Shutdown / Circuit Analysis RAI 01, RAI 03, and RAI 07. As stated in Reference (b),

NMPNS agreed to provide responses to these three RAIs by April 30, 2013. Associated revisions to the originally submitted Transition Report, including the Attachment W Fire PRA insights and results, are provided in Enclosures 3 through 6.

The responses to Safe Shutdown / Circuit Analysis RAI 01 and RAI 03 note that NMPNS has elected to modify its NFPA 805 transition analysis for NMP 1 to revise the approach for demonstrating the ability to reach and maintain safe and stable conditions, as specified by NFPA 805. The original Nuclear Safety Capability Assessment (NSCA) established as its basis for demonstrating safe and stable conditions the requirement to maintain Kff < 0.99 with a reactor coolant temperature at or below the requirements for hot shutdown and then subsequently cool down and maintain the plant in a cold shutdown condition.

Consistent with NFPA 805 and supplemental guidance, NMPNS is revising its basis for the NMP1 NSCA to include only the requirement to establish hot shutdown conditions, including long-term hot shutdown capability. The Fire Probabilistic Risk Assessment (PRA) has been re-quantified and the delta risk parameters have been re-calculated to incorporate this revised safe and stable analysis basis. Also included in the Fire PRA re-quantification are the affects associated with the responses to Probabilistic Risk Assessment RAIs (where applicable) that were previously provided in Reference (c).

In addition, by letter dated February 27, 2013 (Reference c), NMPNS provided responses to requests for additional information documented in Reference (b). In the February 27, 2013 letter, NMPNS committed to provide updates to the responses for Probabilistic Risk Assessment RAI 05 and Probabilistic Risk Assessment RAI 08 (if needed) to reflect the response to Safe Shutdown / Circuit Analysis RAI 01. The updated responses to these two RAIs are provided in Enclosure 2. contains security-related sensitive information and is requested to be withheld from public disclosure under 10 CFR 2.390 and in accordance with Regulatory Issue Summary 2005-26, "Control of Sensitive Unclassified Nonsafeguards Information Related to Nuclear Power Reactors." A redacted version of the information in Enclosure 6 with the security-related sensitive information removed is provided in Enclosure 5.

This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental information to the appropriate state representative. This letter contains no new regulatory commitments.

Document Control Desk April 30, 2013 Page 3 Should you have any questions regarding the information in this submittal, please contact J. J. Dosa, Director Licensing, at (315) 349-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30, 2013.

Very truly yours, CRC/DEV

Enclosures:

1. Nine Mile Point Unit 1 - Response to NRC Request for Additional Information Regarding the Proposed Adoption of NFPA 805 (2001 Edition)

2. Nine Mile Point Unit 1 - Updated Responses to Probabilistic Risk Assessment RAI 05 and RAI 08

3. Revisions to the LAR Transition Report with Changes Highlighted

4. Revisions to the LAR Transition Report, Re-Typed with Changes Incorporated

5. Revisions to the Redacted Version of the LAR Transition Report, Attachment C and Attachment W

6. Revisions to the Non-Redacted Version of the LAR Transition Report, Attachment C and Attachment W cc: Regional Administrator, Region I, NRC (w/o Enclosure 5)

Project Manager, NRC Resident Inspector, NRC (w/o Enclosure 5)

A. L. Peterson, NYSERDA (w/o Enclosure 6)