ML15086A305

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RAI on License Amendment Request to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants
ML15086A305
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 04/10/2015
From: Farideh Saba
Plant Licensing Branch II
To: Nazar M
Florida Power & Light Co
Saba F DORL/LPL2-2 301-415-1447
References
TAC MF1373, TAC MF1374
Download: ML15086A305 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 April 10, 2015

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS" (TAC NOS. MF1373 AND MF1374)

Dear Mr. Nazar:

By letter dated March 22, 2013, as supplemented by letters dated June 14, 2013, and February 24, March 25, and April 25, 2014, Florida Power & Light Company (FPL, the licensee) submitted a license amendment request for the St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie).

The proposed amendment requested approval to transition the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(b) to 10 CFR 50.48(c),

National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants."

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided by the licensee and participated in an audit at St. Lucie the week of November 18, 2013. By correspondence dated June 7 and December 26, 2013, the NRC staff requested additional information. By letters dated June 14, 2013, and February 24, March 25, April 25, July 14, August 27, September 10, and October 10, 2014, the licensee responded to the staff's requests for additional information (RAls).

The NRC staff determined that it needs additional information to complete the review. On February 19, 2015, draft followup Probabilistic Risk Assessment (PRA) RAI 11.c.02.01 was discussed during a public conference call between the NRC staff and FPL staff. The revised and finalized RAI was e-mailed to Mr. William Cross of FPL on March 25, 2015. By an e-mail dated March 26, 2015, Mr. Cross agreed with the NRC staff request to respond to PRA RAI 11.c.02.01 within 30 days after March 25, 2015 (i.e., April 24, 2015). The enclosure to this letter contains the NRC staff's followup PRA RAI.

If you have any questions, please contact me at (301) 415-1447 or farideh.saba@nrc.gov.

Enclosure:

Request for Additional Information Docket Nos. 50-335 and 50-389 cc w/enclosure: Distribution via Listserv Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

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 ELECTRIC GENERATING PLANTS" FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389 By letter dated March 22, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13088A173), as supplemented by letters dated June 14, 2013, and February 24, March 25, April 25, July 14, August 27, September 10, and October 10, 2014 (ADAMS Accession Nos. ML13170A156, ML14070A097, ML14114A458, ML14135A395, ML14198A087, ML14253A216, ML14259A373, and ML14296A435, respectively), Florida Power and Light Company (the licensee) submitted a license amendment request for the St. Lucie Plant, Unit Nos. 1 and 2. The proposed amendment requested approval to transition the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.48(b) to 10 CFR 50.48(c), National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants."

The U.S. Nuclear Regulatory Commission staff reviewed the information provided by the licensee and determined that it needs additional information for the following Probabilistic Risk Assessment (PRA) request for additional information (RAI) to complete the review.

PRA RAI 11.c.02.01 The response to PRA RAI 11.c.02 implies that there are numerous steps and assumptions involved in estimating the change in risk associated with the cable spreading room but does not clearly describe all of the steps and the assumptions. Most of the information requested below was provided in the slides and discussed with the staff during the public meeting on February 19, 2015 (ADAMS Accession No. 15063A347). Please provide the following information:

a. Identify the criteria for applying this type of change-in-risk estimate to a fire area. Is this method used for any area other than the cable spreading room?
b. Describe how variances from deterministic requirements (VFDRs) in the cable spreading room are defined and identified.

Enclosure

c. Clarify whether the fire frequency in this area is the same for the variant and the complaint plants (i.e., no changes are made to the detection and suppression likelihoods between the variant and compliant plant models). If different, describe the difference.
d. Clarify whether it is possible to shut down from the accident sequence precursor after trying, and failing, to shut down from the main control room.
e. Describe how the complaint case conditional core damage probability (CCDP)/conditional large early release probability (CLERP) is estimated for the three cases discussed during the public meeting (i.e., small fire, more severe fire, and hot gas layer fire).
f.

Describe how the variant case CCDP/CLERP is estimated for the three cases discussed during the public meeting (i.e., small fire, more severe fire, and hot gas layer fire).

g. Describe how the change-in-risk estimates are developed for the three cases discussed during the public meeting (i.e., small fire, more severe fire, and hot gas layer fire).
h. Discuss why the change-in-risk estimates are reasonable or conservative for the three cases discussed during the public meeting (i.e., small fire, more severe fire, and hot gas layer fire). This discussion should include how the impact of VFDRs within the cable spreading room is included in the calculations.

ML15086A305 OFFICE DORULPL2-2/PM DORULPL2-2/LAiT DORULPL2-2/LA DRA/AFPB/BC DORULPL2-2/BC DORULPL2-2/PM NAME FSaba LRonewicz BClayton HHamzehee SHelton FSaba DATE 4/7/15 3/31/15 3/31/15 4/9/15 4/10/15 4/10/15