L-18-249, Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805

Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805

ML18324A677
Person / Time
Site:	Davis Besse
Issue date:	11/20/2018
From:	Huey D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF7190, EPID L-2015-LLF-0001, L-18-249
Download: ML18324A677 (11)

Text

FENOC Davrs-Besse Nuclear Power Sfation 5501 North Sfafe Route 2 Oak Hafior, Ohio 43449 FittEnqgy Nuclcil Walini Ctlp{nf November 20, 2018 L-18-249 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Supplemental lnformation Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 (CAC No. MF7190, EPID L-2015-LLF-0001)

By Ietter dated December 16, 2015 (ADAMS Accession No. ML153504314), as supplemented by letters dated March 7,2016, July 28,2016, December 16,2016, January 17,2017, June 16,2017, October9,2017, April 2,2018, and September 11, 2018 (Accession Nos. ML16067A195, M116210A422, ML163514330, M1170174504, ML17170A000, ML17284A190, ML18094A798, and ML18254A073 respectively),

FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request (LAR) to change the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1 fire protection program to one based on the National Fire Protection Association (NFPA)

Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating PIants," 2001 Edition.

FENOC requests a revised implementation schedule for the plant modifications and specific activities required for implementation of the Iicense amendment. The October 9, 2017 letter requested thatthe modifications listed in l-AR Attachment S, Table S-1 be completed by the startup of the first refueling outage following issuance of the license amendment. lt is hereby requested that the single remaining modification be completed within two years following issuance of the license amendment request.

The only remaining modification involves providing fire protection for emergency feedwater system control cables within one of the fire compartments in which they are routed. The probabilistic risk assessment (PRA) model that was used to support the LAR assumed this modification would be installed prior to implementation. A PRA sensitivity study was subsequently pedormed that conservatively estimated the impact of delaying this modification or removing it entirely from the scope of the model by assuming the control cables fail for any fire scenario originating in this compartment.

Davis-Besse Nuclear Power Station, Unit No. 1 L-18-249 Page 2 The sensitivity study resulted in very small increases in the core damage frequency (CDF) and large event release frequency (LERF) per Regulatory Guide 1.174"An Approach for Using Probabilistic Risk Assessment in Risk-lnformed Decisions on Plant-Specific Changes to the Licensing Basis." This sensitivity study did not include multiple compartment fire propagation scenarios. Although multiple compartment scenarios that impact this compartment exist in the PRA model, recent refined fire modeling analyses show there are no fire scenarios from any compartment that can propagate and detrimentally impact this compartment. Therefore, the multiple compartment scenarios that impact this compartment will be removed from the PRA. Although, based on the sensitivity study, it is acceptable from a risk perspective to permanently continue to operate with the existing configuration, FENOC intends to complete the modification in accordance with the proposed license conditions.

Furthermore, proposed modification DB-2061 has been removed from Table S-1 in the attached LAR Attachment S. The fire risk evaluation of the variances from deterministic requirements associated with DB-2061 determined that the modification is not necessary and that the risk of not performing the modification is minimal.

The October 9, 2017 letter also requested that the specific activities listed in LAR Attachment S, Table S-2 be completed within one year following issuance of the license amendment. lt is hereby requested that the specific activities be completed within two years following issuance of the license amendment request.

Additional time is requested to coordinate with the permanent cessation of power operations at DBNPS that was certified to the Nuclear Regulatory Commission (NRC) in FENOC letter dated April 25, 2018 (ML18115A007).

Section 5.5 of the LAR is hereby changed to:

The following schedule for transitioning DBNPS to the new fire protection licensing basis requires NRC approval of the LAR in accordance with the following schedule.

a lmplementation of the new NFPA 805 fire protection program to include procedure changes, process updates, and training to affected pianipersonnel. This will occur within two years following issuance of the license amendment. LAR Attachment S Table S-2 has additional detail.

a LAR Attachment S, Table S-1 provides a listing of plant modifications associated with the transition to NFPA 805. Modifications will be completed within two years following issuance of the license amendment. Appropriate compensatory measures will be maintained until modifications are complete.

Finalfy, FENOC letter dated April 2,2018 submitted a revised LAR Attachment S that added item DB-2120 to Table S-2. However, subsequent FENOC letter dated

Davis-Besse Nuclear Power Station, Unit No. 1 L-18-249 Page 3 September 1 1,2018 submitted a revised LAR Attachment S that inadvertently rernoved item DB-2120 from the table. This issue has been entered into the FENOG Gonective Action Program. A conected Attachment S is provided that has added item DB-2120 back into Table S-2.

The information provided by this submittal does not invalidate the significant hazards consideration analysis provided in the December 16, 2015 letter.

There are no regulatory comrnitments included in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager - Nuclear Licensing and Regulatory Affairs, at (330) 3156808.

I declare undq penalty of perjury that the foregoing is true and conect. Executed on November zP ,2018.

Sincerely B Huey Director, Site Performance lmprovement Attachment S: I-AR Attachment S - Modifications and lmplementation ltems cc: NRC Regional Administrator - Region lll NRC Resident Inspector NRC Project Manager Utility Radiological Safety Board Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Attachment S L-18-249 LAR Attachment S - Modifications and lmplementation ltems (7 pages, excluding this page)

FENOC Attachment $ - Modifications and Implementation ltems S Modifications and lmplementation Items 6 Pages Attached Davis-Besse Page S-1

FENOC Attachment S - Modifications and lmplementation ltems Table S-1, Plant Modifications Committed, provided below, include a description of the modifications along with the following infomation:

. Risk ranking of the modification,

. A problem statement,

. A description of the proposed modification,

. An indication if the modification is currently included in the FPRA,

. A statement if compensatory measure is in place; and

. A risk-informed charac{erization of the modification and compensatory measure.

. The following legend should be used when reviewing the tables:

o High = Modification would have an appreciable impact on reducing overall fire CDF.

o Medium = Modification would have a measurable impact on reducing overall fire CDF.

o Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.

Table S-1 Plant Modifications Committed ln Comp ltem Rank Problem Statement Proposed Modification FPRA Measure Risk lnformed Characterization DB-1421 H Fire damage could result ECP 13-0195 installs the emergency water Yes No This modifieation provides an in loss of both steam storage tank and facility. This provides alternate source of feedwater by driven auxiliary feedwater emergency power sources and makeup water. providing a diesel-driven power pumps. This could ECP 13-0196 installs the diese!-driven emergency source and expanded emergency challenge the NSPC for feedwater pump and auxiliary equipment. water storage.

decay heat removal. ECP 16-0332 provides fire protection for control cables in the emergency feedwater system Davis-Besse Page S-2

FENOG Attachment S - Modifications and lmplementation ltems Table S-2, ltems provided below are those items (procedure changes, prooess updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program.

Table S-2 lmplementation ltems Item Description LAR Section/Source D8-0341 Revise Pre-Fire PIans and Associated Training Modules to lnclude Action for Radioactive Release Attachment E and D8-0538 Scenarios; Review Pre-Fire Plans Against Safe Shutdown Analysis and Revise as Necessary; Attachment A1, Sections 3.4.3(a), 3.4.2, DB-1074 Revise Pre-Fire Plans to lnclude Rooms 330,317A,605, and 417A; Develop Pre-Fire Plan for and 3.4.2.1 DB-1093 Potential Radioactive Release Areas.

DB-1095 DB-0463 Update DB-OP-02501 to Reference Ammeters for Runout Detection Attachment C DB-0492 Generate an Inspection Procedure for the Ceramic Fiber used in Trays. Attachment V D8-0525 Revise DB-FP-00007 for Combustible and Transient Loading Program Requirements and to Attachment A1, Sections 3.3.1.2 and DB-1058 lnclude Duration Limits Based on Fire Modeling. 3.3.1.2(4)

DB-0540 Revise Transformer lnspection Procedure for Gravel Bed Drainage. Attachment Al, Section 3.3.9 FPE RAI 01.02 DB-0541 Revise Fire Brigade Policies and Practices Based on the NFPA 600 Code Review Attachment A1, Sections 3.4.1(a),

3.4.3(a), and 3.4.4 DB-0557 Revise Fire Brigade Drills to lnclude Areas Essential to Plant Operation, Safe Shutdown Areas, Attachment A1, Sections 3.4.3(b) and and to Control Radioactive Release. 3.4.3(c)

DB-0572 Revise Affected Procedures to lnclude Credited NFPA 805 Fire Protestion Equipment. Attachment 41, Section 3.2.3(2)

D8-0573 Revise Performance-Based lnspection Requirements to Include NFPA 805 Credited Fire Attachment Al, Sections 3.11.1 and D8-0600 Protection Equipment. 3.2.3(1)

DB-0582 Assess Current Transformer Fire Effects Due to Open Secondary Circuits. Attachment B, NEI Section 3.5.2.1 DB-0759 Revise Control Room Fire Alarm Response Procedure DB-OP-02529. Attachment A1, Section 3.4.1(d)

D8-0779 Revise the DBNPS Fire Protection Program, or equivalent replacement procedure, to List NRC as Attachment Al, Section 3.2.2.4 AHJ. FPE RAI 01.02 Davis-Besse Page S-3

FENOC Attachment S - Modifications and lmplementation ltems Table S-2 lmplementation ltems Item Description LAR Section/Source DB-1147 Develop a Monitoring Program as Required by NFPA 805. 4.6.2, Attachment E, and Attachment V DB-1744 DB-1949 DB-1591 Revise Documents to Include Fire Protection Water System Connections. Attachment A1, Section 3.5.16 DB-1603 Review of MOVs for Crediting CPT. Attachment V DB-1695 Revise PRA to reflect the transitioning plant: If the resulting risk estimates exceed RG 1.174 Attachment V criteria, then model refinements, plant modifications, and/or procedure changes will be made as PRA RAt 02.d.01 necessary prior to the use of the model.

DB-1696 Update the lgnition Frequency Calculation and Fire Modeling for the following: Implementation of Attachment V DB-2013 the DAFW System and FLEX, Add the Satellite phone Equipment That Will be Added to the EFWF DB-2014 and MCR per ECP-14-0465; Evaluate for lmpacts on the lmplementation of NFPA 805E for CP 14-0646 that Adds New Sound Powered Phone Equipment.

DB-1810 Revise lnterior Finish Procurement Specifications to lnclude Radiant Heat Flux. Attachment A1, Section 3.3.3 DB-1812 Revise Procedures to Trip RCPs During a Serious Fire Event. Attachment C DB-1825 Revise DBNPS EEEEs including NPE-98-00081 or its replacement (to remove credit for 4.2.2 sprinklers). FPE RAI 01 FPE RAI 06 DB-1838 Create a NFPA 13 and NFPA 72 Code Compliance Review for SBO Diesel Generator Building. Attachment 42, Fire Compartment OS D8-2041 FPE RAI 01.02 SSA RAI 01 DB-1878 Verification of Fire Damper Rating. Attachment A2, Fire Compartment ll-04 DB-1900 Update Combustible Loading Analysis to include SBO Diesel Building and Review SBO DG Day Attachment A1, Section 3.3.8 Tank to NFPA 30. FPE RAI 01.02 DB-1908 Revise Procedures and Conduct Training to lmplement NPO Requirements for NFPA 805. Attachment D DB-1912 Include inspection of Dampers 1203 and 1204 in Fire Damper lnspection Procedure. Attachment A2, Fire Compartments BG-01 and ll-01 FPE RAI 01.02 Davis-Besse Page S,il

FENOG Attachment S - Modifications and lmplementation ltems Table S-2 lmplementation ltems Item Description LAR Section/Source DB-1915 Revise Pre-Fire Plans and Training Materials to Address Radioactive Release. Attachment E DB-1941 Revise Procedures lncluding Fire Brigade Training and Drills to Incorporate Recovery Actions. Attachment G DB-1943 Review and Revise Fire PRA Human Reliability Analysis Upon Completion of Procedure Updates, Attachment G Modifications, and Training.

DB-1964 ReviseCableSpecifications. Attachment A1, Sections 3.3.5.1 and 3.3.5.3 FPE RAI 01 DB-1988 Update SAFE to Document ECP 13-0406 Fuse Protection for DB Ammeters Attachment C DB-2005 Perform NFPA 58 Code Review of the Permanent Propane Tanks lnstallation. Attachment A1, Section 3.3.7.1 DB-2015 Revise the Level 1 Failure Reports to Reflect Where Normal Control Power is Available Attachment C and Attachment V D8-2020 Resolve the Non-enclosed Power Wiring for the Emergency Backup Lighting in Fire Compartment Attachment A1, Section 3.3.5.1 cc-o1.

D8-2029 Create Analysis Assessment to create the Data Set and Testing Criteria due to Modification of Attachment V EFW and FLEX.

D8-2031 Update documentation due to addition of power converters for the Auxiliary Feedwater and Motor Attachment C and Attachment V Driven Feedwater target rock valves.

D8-2035 Update documentation such as SAFE for Containment Spray Modifications and Instrumentation. Attachment C D8-2036 DB-2037 Develop Fire Modeling Qualification Guides and Procedures Attachment V DB-2049 Develop the DBNPS NFPA 805 Design Basis Document. 4.7.1 FPE RAI 01 DB-2050 Develop New NFPA 805 Control Procedures and Processes. 4.7.2 FPE RAI 01 DB-2053 The NFPA 20 Code of Record Compliance Review will be updated to be in the format of an EEEE Attachment 41, Section 3.5.3 FPE RAI 05 Davis-Besse Page S-5

FENOC Attachment S - Modifications and lmplementation ltems Table S-2 Implementation ltems Item Description LAR Section/Source DB-2054 The NFPA 10 Code of Record Compliance Review will be updated to be in the format of an EEEE Attachment A1, Section 3.7 FPE RAI 05 D8-2055 The NFPA 72E Code of Record Compliance Review will be updated to be in the format of an Attachment 41, Section 3.8.2 EEEE. FPE RAI 05 D8-2056 The NFPA 13 and NFPA 15 Code of Record Compliance Review will be updated to be in the Attachment 41, Section 3.9.1 format of an EEEE. FPE RAI 05 D8-2057 The NFPA 80 and NFPA 90A Code of Record Compliance Review will be updated to be in the Aftachment A1, Section 3.1 1.3 format of an EEEE. FPE RAI 05 D8-2062 Update the Conduct of Operations procedure to provide clarification required for fire brigade Attachment 41, Section 3.4.1(c) qualifications necessary to meet NFPA 805 Section 3.4.1(c). FPE RAI 02 D8-2063 Perform a review of the performance-based methods described in EPRI TR-1006756 for Attachment A1, Section 3.2.3(1 );

establishing the appropriate frequencies for inspection, testing, and maintenance procedures, and Attachment L adjust the site program to address and differences identified. FPE RAI 03 DB-z120 Update PRA to address weaknesses identified in PRA RAI 03(d) response: Conseruatism related PRA RAI 03 to Multiple Compartment Scenarios impacting the Cable Spreading Room, overly conservative PORV cable mapping, missing Makeup System logic. lnclude model enhancements using NRC approved methods to maintain risk within acceptable limits. Re-perform Risk and Transition Change in Risk calculations to ensure RG 1.205 risk acceptance guidelines continue to be met with the revised model.

DB-z128 lmplement a means to obtain steam generator level locally during fire scenarios that lnclude PRA RAI 03.01.c Control Room evacuations.

Davis-Besse Page 5-6

FENOC Attachment S - Modifications and Implementation ltems Table S-3, Plant Modifications Completed, provided below, include a description of the modifications along with the following information:

. Risk ranking of the modification,

. A problem statement,

. A description of the proposed modification,

. An indication if the modification is cunently included in the FPRA,

. A statement if compensatory measure is in place; and

. A risk-informed characterization of the modification and compensatory measure.

' The following legend should be used when reviewing the tables:

o High = Modification would have an appreciable impact on reducing overall fire CDF.

o Medium = Modlfication would have a measurable impact on reducing overall fire CDF.

o Low = Modification would have either an insignificant or no impact on rcducing overall fire CDF.

Table S-3 Plant Modifications Gompleted ln Comp Item Rank Problem Statement Proposed Modification FPRA Measure Risk !nformed Characterization DB-1983 H FLEX RCS Charging ECP 13-0463 adds the FLEX RCS Makeup and Yes No This modification will help mitigate Modification Boration System. This includes the two FLEX RCP seal LOCAs should seal RCS charging pumps that are credited in the fire cooling and seal injection or seal PRA model. return be lost through the use of 2 FLEX RCS charging pumps.

DB-2010 H Install Oil Containment Install oil containment systems for the unit sub Yes No The oil collection system is Systems transformers in compartments X-01 and Y-01. currently credited in the FPRA and is used to help prevent the creation of a hot gas layer in fire compartments X-01 and Y-01.

Davis-Besse Page S-7