Letter Sequence Response to RAI |
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MONTHYEARNL-12-1893, License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)2012-09-25025 September 2012 License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) Project stage: Request ML12345A3982012-12-12012 December 2012 Supplemental Information Needed for Acceptance of Requested Licensing Action Concerning Voluntary Fire Protection Risk Initiative Request (TAC Nos. ME9741 and ME9742)(NL-12-1893) Project stage: Acceptance Review NL-12-2566, Supplemental Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)2012-12-20020 December 2012 Supplemental Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) Project stage: Supplement ML13022A1582013-01-24024 January 2013 Acceptance Review Concerning Voluntary Fire Protection Risk Initiative Request (TAC Nos. ME9741 and ME9742) (N-1-2-1893) Project stage: Acceptance Review ML13050A2862013-02-22022 February 2013 3/7/2013 - Forthcoming Meeting Notice with Southern Nuclear Company to Discuss Responses to Requests for Additional Information Related to Amendment Requests to Transition to the National Fire Protection Association NFPA-805 Methodology Project stage: RAI ML13067A2692013-03-11011 March 2013 03/21/2013 Forthcoming Meeting with Southern Nuclear Company Regarding Voluntary Fire Protection Risk Initiative Amendment Request for Joseph M. Farley Nuclear Plant, Units 1 and 2 Project stage: Meeting ML13176A0932013-07-0808 July 2013 Request for Additional Information Concerning Voluntary Fire Protection Risk Initiative Request (TAC Nos. ME9741 and ME9742) (NL-12-1893) Project stage: RAI ML14038A0192013-09-16016 September 2013 Joseph M. Farley, Units 1 and 2, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generati Project stage: Request NL-13-2039, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants2013-10-30030 October 2013 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Project stage: Response to RAI NL-13-2269, Response to Request for Additional Information Re License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants2013-11-12012 November 2013 Response to Request for Additional Information Re License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Project stage: Response to RAI ML14066A0472014-03-0707 March 2014 Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Adopt Nation Fire Protection Association Standard 805 (TAC ME9741 and ME9742 Project stage: Draft RAI ML14073A0532014-03-28028 March 2014 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: RAI ML14114A5502014-04-23023 April 2014 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Project stage: Response to RAI NL-14-0733, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants2014-05-23023 May 2014 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Project stage: Response to RAI NL-14-0927, Response to RAI Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants. Part 1 of 32014-07-0303 July 2014 Response to RAI Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants. Part 1 of 3 Project stage: Response to RAI ML14176A0702014-07-11011 July 2014 Request for Additional Information Project stage: RAI NL-14-1106, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Lioht Water Reactor Generating Plants2014-08-11011 August 2014 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Lioht Water Reactor Generating Plants Project stage: Response to RAI NL-14-1273, Response to Request for Additional Information Re License Amendment Request for Transition to 10CFR50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for LWR Generating Plants2014-08-29029 August 2014 Response to Request for Additional Information Re License Amendment Request for Transition to 10CFR50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for LWR Generating Plants Project stage: Response to RAI NL-14-1937, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants2015-01-16016 January 2015 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Project stage: Response to RAI ML15023A0522015-01-23023 January 2015 U.S. Nuclear Regulatory Commission, Record of Review Dispositions to Fire PRA Facts and Observations for Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant, Units 1 and 2 Project stage: Request ML15043A4592015-02-24024 February 2015 Summary of Site Audit to Support the Review of a License Amendment Request for Joseph M. Farley Nuclear Plant, Units 1 and 2, to Transition to the National Fire Protection Association Standard 805 Fire Protection Licensing Basis Project stage: Approval ML14308A0482015-03-10010 March 2015 Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) Project stage: Approval 2014-03-28
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Category:Letter type:NL
MONTHYEARNL-24-0384, Request for Alternative RR-PR-04 for Inservice Testing of the 2A, 2B, and 2C Charging Pumps and Mini-Flow Isolation Valves2024-10-18018 October 2024 Request for Alternative RR-PR-04 for Inservice Testing of the 2A, 2B, and 2C Charging Pumps and Mini-Flow Isolation Valves NL-24-0320, License Amendment Request Proposing a New Set of Fission Gas Gap Release Fractions for High Burnup Fuel Rods That Exceed the Linear Heat Generation Rate Limit Detailed in Regulatory Guide 1.183, Table 3,.2024-09-27027 September 2024 License Amendment Request Proposing a New Set of Fission Gas Gap Release Fractions for High Burnup Fuel Rods That Exceed the Linear Heat Generation Rate Limit Detailed in Regulatory Guide 1.183, Table 3,. NL-24-0349, Units 1 and 2 - 10 CFR 26.719(c)(1) 30-Day Report Blind Performance Test Results Inconsistent with Sample Provided2024-09-20020 September 2024 Units 1 and 2 - 10 CFR 26.719(c)(1) 30-Day Report Blind Performance Test Results Inconsistent with Sample Provided NL-24-0341, Response to Request for Additional Information Related to the Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency2024-09-10010 September 2024 Response to Request for Additional Information Related to the Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency NL-24-0259, License Amendment Request to Revise Technical Specification 3.4.14, Reactor Coolant System Pressure Isolation Valve Leakage, Surveillance Requirement 3.4.14.3 Acceptance Criteria and Miscellaneous Obsolete Changes2024-09-0404 September 2024 License Amendment Request to Revise Technical Specification 3.4.14, Reactor Coolant System Pressure Isolation Valve Leakage, Surveillance Requirement 3.4.14.3 Acceptance Criteria and Miscellaneous Obsolete Changes NL-24-0340, Unit 1 - Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 1 R322024-09-0404 September 2024 Unit 1 - Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 1 R32 NL-24-0321, License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions - Supplemental Information2024-08-16016 August 2024 License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions - Supplemental Information NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 NL-24-0281, License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions2024-07-18018 July 2024 License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0230, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite – Update to TSTF-3602024-06-28028 June 2024 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite – Update to TSTF-360 NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0235, Manual Reactor Trip Due to Loss of Power to the 2A 125 Volt DC Distribution Panel2024-06-19019 June 2024 Manual Reactor Trip Due to Loss of Power to the 2A 125 Volt DC Distribution Panel NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0221, Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits Due to Setpoint Drift2024-06-17017 June 2024 Pressurizer Safety Valve Lift Pressure Outside of Technical Specifications Limits Due to Setpoint Drift NL-24-0238, RIPE License Amendment Request to Change Containment Air Temperature Actions, Supplemental Information2024-06-14014 June 2024 RIPE License Amendment Request to Change Containment Air Temperature Actions, Supplemental Information NL-24-0229, Notice of Intent to Pursue Subsequent License Renewal2024-06-0707 June 2024 Notice of Intent to Pursue Subsequent License Renewal NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 NL-24-0064, Units 1 & 2 and Hatch Nuclear Plant - Units 1 & 2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.52024-05-0303 May 2024 Units 1 & 2 and Hatch Nuclear Plant - Units 1 & 2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.5 NL-24-0188, Cycle 33 Core Operating Limits Report2024-05-0101 May 2024 Cycle 33 Core Operating Limits Report NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 NL-24-0137, RIPE License Amendment Request to Change Containment Air Temperature Actions2024-04-19019 April 2024 RIPE License Amendment Request to Change Containment Air Temperature Actions NL-24-0123, for Manual Reactor Trip Due to Loss of Power to the 2A 125 Volt DC Distribution Panel2024-04-15015 April 2024 for Manual Reactor Trip Due to Loss of Power to the 2A 125 Volt DC Distribution Panel NL-24-0134, Renewed National Pollutant Discharge Elimination System (NPDES) Permit2024-04-12012 April 2024 Renewed National Pollutant Discharge Elimination System (NPDES) Permit NL-24-0088, Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency2024-04-0505 April 2024 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. NL-24-0116, Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred.2024-03-29029 March 2024 Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred. NL-24-0092, Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R292024-03-15015 March 2024 Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R29 NL-24-0003, Inservice Inspection Program Owners Activity Report (OAR) Supplement for Outages 1 R30 and 1 R312024-02-16016 February 2024 Inservice Inspection Program Owners Activity Report (OAR) Supplement for Outages 1 R30 and 1 R31 NL-24-0042, Response to Request for Additional Information Exemption Requests for Physical Barriers2024-02-13013 February 2024 Response to Request for Additional Information Exemption Requests for Physical Barriers NL-24-0033, Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers2024-02-0505 February 2024 Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers NL-24-0011, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2024-01-11011 January 2024 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0901, 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers2023-12-15015 December 2023 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers NL-23-0908, Cycle 30 Core Operating Limits Report2023-12-13013 December 2023 Cycle 30 Core Operating Limits Report NL-23-0828, Main Steam Safety Valve Lift Pressure Outside of Technical Specifications Limits Due to Setpolnt Drift2023-11-30030 November 2023 Main Steam Safety Valve Lift Pressure Outside of Technical Specifications Limits Due to Setpolnt Drift NL-23-0877, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0825, Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection2023-11-14014 November 2023 Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection NL-23-0739, Response to NRC Inspection Report and Preliminary White Finding2023-09-0808 September 2023 Response to NRC Inspection Report and Preliminary White Finding NL-23-0716, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0713, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0704, Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-22022 August 2023 Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0628, Readiness for Supplemental Inspection EA-22-1012023-07-26026 July 2023 Readiness for Supplemental Inspection EA-22-101 NL-23-0566, ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use2023-07-13013 July 2023 ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications 2024-09-04
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Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham. AL 35242 COMmWY August 11,2014 Docket Nos.: 50-348 NL-14-1106 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Lioht Water Reactor Generating Plants Ladies and Gentlemen:
By letter dated September 25,2012, the Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Joseph M. Farley Units 1 and 2 (Ref. TAC NOS. ME9741 and ME9742). The proposed amendment requests the review and approval for adoption of a new fire protection licensing basis which complies with the requirements in Sections 50.48(a) and 50.48(c) to Title 10 to the Code of Federal Regulations (10 CFR), and the guidance in Regulatory Guide (RG) 1.205, Revision 1, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants.
By letter dated December 12,2012, the Nuclear Regulatory Commission (NRC)
Staff requested supplemental infomiation regarding the acceptance of the license amendment (Adams Accession No. ML12345A398). SNC provided the requested information by letter dated December 20,2012. The NRC staff subsequently completed the acceptance review by letter dated January 24,2013, (Adams Accession No. ML13022A158).
By letter dated July 8,2013, the NRC Staff fomially transmitted a request for additional information (RAI) related to the referenced license amendment. SNC's responses to these RAIs are being provided by three submittals. By letter dated September 16,2013, SNC provided the first set of responses. By letter dated October 30,2013, SNC provided the second set of responses and by letter dated November 12,2013, SNC provided the remaining set of response.
By letter dated March 28,2014, the NRC Staff formally transmitted the second round of requests for additional information related to the referenced license amendment request. By letter dated April 23,2014, SNC provided the 30 day response to the second round of RAIs. By letter dated May 23,2014, SNC provided the 60 day response to six of the eight remaining RAIs.
U.S. Nuclear Regulatory Commission NL-14-1106 Page 2 By letter dated July 3,2014, SNC provided revised Attachments S, V, and W.
The updated total plant. Fire PRA, and delta risk values were provided in the updated Attachments V and W. These attachments provided the response to PRA RAIs oe.a.oi and 35. The revised Attachment S reflects the updates associated with the RAI responses. Revisions to Attachments C and G will be provided in a separate submittal. Along with other revisions, a new modification item has been added to Attachment S for installation of the next generation Westinghouse shutdown seals for the reactor coolant pumps on both Unit 1 and Unit 2.
By letter dated July 11, 2014, the NRC staff transmitted additional RAIs related to the credit for the next generation of the Westinghouse Reactor Coolant Pump shutdown seals (RAI 35.01) and the composite analysis of the probabilistic risk analysis (RAI 36). During a teleconference held on August 1, 2014, it was agreed that the response to RAIs 16.a.02 and 35.01 would be provided by August 11, 2014 and the response to RAI 36 would be provided by August 29,2014. The enclosure to this letter provides the responses to RAIs 16.a.02 and 35.01.
The No Significant fHazards Consideration determination provided in the original submittal is not altered by the RAI responses provided herein.
This letter contains no new NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.
Mr. C. R. Pierce states he is Regulatory Affairs Director of Southem Nuclear Operating Company, is authorized to execute this oath on behalf of Southem Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true and correct.
Respectfully submitted, , :
C. R. Pierce ^ ~
Regulatory Affairs Director \ ^
CRP/jkb/lac "
SwortyXo and subscribed before me this 11 day of 2014.
Notary Public My commission expires: /ohizon : Response to Requests for Additional Infonnation
U.S. Nuclear Regulatory Commission NL-14-1106 Page 3 cc: Southern Nuclear Operating Company Mr. 8. E. Kuczynski, Chainnan, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. 8. L. Ivey, Vice President - Regulatory Affairs Mr. T. E. Tynan, Vice President - Fleet Operations Mr. B. J. Adams, Vice President - Engineering Mr. R. R. Martin, Regulatory Manager - Farley RTYPE: CFA04.054 U. S. Nuclear Reaulaton/ Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector - Farley Mr. K. E. Miller, Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer
Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48fc)
NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generatinq Plants Enclosure 1 Response to Request for Additional Information
By letter dated July, 11,2014, the NRC staff requested additional infonnation (RAI) associated with the SNC license amendment request to transition Farley to fire protection licensing basis National Fire Protection Association (NFPA)
Standard NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition).
Farley PR A RAI 16.a.02 In a letter dated May 23, 2014, (ADAMS Accession No. ML14147A368) the licensee responded to PRA 16.a.01 citing planned enhancement of operations guidance for controlling fires in the main control board (MCB) panels prior to the assumed damage time of 10 minutes for sensitive electronics. Describe if there is an implementation item to Attachment S that addresses the development and implementation of this procedure. If not, describe the method that will be used to ensure development of the procedure.
RESPONSE
Implementation Item number 31 has been added to Attachment S, Table S-3, Implementation Items, regarding the need to evaluate the initial fire and to open the panel doors ifthe potential exists for damage/overheating in an adjacent panel for a fire originating in the Main Control Room. The revised Attachment S containing this implementation item was provided in SNC's letter NL-14-0927 dated July 3,2014.
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Farley PRA RAI 35.01 In the submittal dated September 25, 2012, a reference to the Fire PRA Logic Model (App. 6 on page B-1) states that Farley Unit 1 installed the new Westinghouse Shutdown Seal (SDS) in fall 2010. The internal events PRA, upon which the Fire PRA is based, takes credit for the SDS (failure probability of 0.0271/demand), limiting the leakage rate to 2 gpm where the faces of the SDS seal components remain in contact. The assumed leakage rate is Increased to 19 gpm if the SDS actuates but the pump shaft continues to rotate if not tripped in a timely manner. Finally, if the SDS does not actuate at all, "existing" seal model leakage rates are applied as stated in WCAP-15603, Rev. 1-A, (Non-Proprietary)
"WOG 2000 Reactor Coolant Pump Seal Leakage Model for Westinghouse PWRs" (MUMP-6074) (ADAMS Accession No. ML032040132). Based on the July 26,2013, Part 21 issuance by Westinghouse concerning defects with the SDS performance, discuss if there have been any new developments regarding the status of the SDS performance. If the licensee is still planning to take credit for an upgraded SDS:
- a. Provide relevant information from technical design documents, testing evaluations, draft topical reports, etc., that support the incorporation and quantification of the SDS perfonnance in the Farley Fire PRA model. As appropriate, justify any assumptions for new risk reduction credit or retention of credit previously assumed in and consistent with Final Safety Evaluation For Pressurized Water Reactor Owners Group Topical Report WCAP-17100-P/Np, Revision 1, "PRA Model For The Westinghouse Shut Down Seal," PA-RMSC-0499 (ADAMS Accession No. ML110880526), or other NRC endorsed technical bases.
- b. If the credit is dependent upon plant operational experience with the upgraded SDS, discuss to what extent credit can and will be taken prior to installation/upgrade and completion of any required operational duration necessary to justify such credit.
- c. If an alternative to the SDS is planned, provide the analogous information to the above for the alternative.
- d. Describe if there is an implementation item to Table S-3 that will identify when a confirmatory evaluation of the achieved NFPA-805 transition risk and changes in risk (that includes when the installed and tested seals) will be completed. Include what change in risk guidance will be used to determine any required actions, and what actions will be required to complement this new implementation item. If there is no new implementation item, describe the method that will be used to report the confirmatory evaluation activities listed above.
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RESPONSE
- a. Farley plans to install Westinghouse's redesigned SDS, referred to as Generation III, as a replacement for the previous SDSs, in Unit 2 during the 2014 Fall refueling outage followed by installation in Unit 1 in 2015.
The Generation III seal addresses vulnerabilities identified in previous designs. The basis for the confidence in the Generation III seals being able to perform as designed is described in TR-FSE-14-1-P, Revision 1, "Use of Westinghouse SHIELD Passive Shutdown Seal for FLEX Strategies," dated March 2014. A copy of this report, containing the technical design information and testing evaluations as well as other technically pertinent information is available in ADAMS at Accession number ML14084A496 (Non-Public). The nonproprietary version of the technical report is available in ADAMS at Accession number ML14084A495. The report was reviewed by the NRC and was endorsed by letter to Westinghouse dated May 28, 2014. Therefore, consistent with the current state-of-the-practice PRA modeling, SNC will model the Generation III SDS in the Farley Fire PRA logic model using the leakage flow rates and failure probabilities in the Generation III consensus PRA model developed by Westinghouse for the Pressurized Water Reactor Owners Group (PWROG). This model is described in Topical Report (TR)
PWROG-14001-P, Revision 1, "PRA Model for the Generation III Westinghouse Shutdown Seal," dated July 2014. The PWROG submitted this report to the NRC Staff for review on July 3, 2014, (ADAMS Accession Number ML14190A331). Additionally, based on the analysis results using a draft of the Farley Internal Events PRA, with credit for Generation III SDS modeled as described in PWROG-14001-P, Revision 1, the risk reduction benefit of the Generation III SDS in the Farley Fire PRA is expected to be consistent with analyses results with the previous SDS.
- b. The credit that will be taken in the SNC internal events and fire PRA models is based on the detailed design infomnation and full engagement of the SNC's pump experts in the design and conduct of successful test results. Credit is not based on plant operational experience with the upgraded SDS. These test results are provided in TR-FSE-14-1-P, Revision 1, "Use of Westinghouse SHIELD Passive Shutdown Seal for FLEX Strategies," dated March 2014. The report was reviewed by NRC and was endorsed by letter to Westinghouse on May 28, 2014. As explained in TR-FSE-14-1-P, Revision 1, the Generation III design addresses the deficiencies of the previous SDS designs while improving on their strengths. As a result there are substantial differences between the Generation III design and previous SDS designs. The Generation III SDS has been extensively tested in conditions more severe than RCS conditions expected during plant operations with successful results.
As stated in TR-FSE-14-1-P. Revision 1, these tests were completed in series such that all effects compounded onto one another. As a validation E-3
of the severity of the tests, the test conditions used for the Generation III qualification resulted in failures of the previous SDS designs when tested under the same conditions. Based on the comprehensiveness of the tests, the test results, and SNC's engagement in the design and conduct of these tests, SNC is confident that the credit taken is reasonable and justified.
- c. No other alternative is planned at this time.
- d. Implementation item 32 was created and added to Table S-3. The implementation item states that following installation of the shutdown seal modification and the as-built installation details, additional refinements surrounding the modification may need to be incorporated into the Fire PRA model {the Fire PRA will verify the validity of the reported change-in-risk on as built conditions after the modification is completed). The revised Table S-3 containing this new item was provided as Attachment S in SNC's letter NL-14-0927, dated July 3, 2014.
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