NL-19-0985, Supplemental 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
| ML19225D132 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/09/2019 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-19-0985 | |
| Download: ML19225D132 (8) | |
Text
Attachments C and S contain security-related information and should be withheld under 10 CFR 2.390. Upon removal of Attachment~ C and S, this correspondence is de-controlled.
A. Southern Nuclear August 9, 2019 Docket Nos.: 50-321 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Jamie M. Coleman Nuclear Licensing Manager Edwin I. Hatch Nuclear Plant - Units 1 and 2 3535 Colonnade Parkway Birmingham, AL 35243 205 992 6611 tel 205 992 7601 fax jamiemco@southernco.com NL-19-0985 Supplemental 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 Ladies and Gentlemen:
By letter dated May 28, 2019, Southern Nuclear Operating Company (SNC) responded to a request for additional information (RAI) from the Nuclear Regulatory Commission (NRC) staff regarding the Hatch Nuclear Plant (HNP) application to transition to 1 O CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants.
Due to a software print setting, not all of the SNC markups provided in the attachments to this letter were captured in the file mailed to the NRC. The attachments to this letter provide the updated Revisions to Transition Report Attachments A, C, J, and S, and supersede those attachments provided in the May 28, 2019 letter.
The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original License Amendment Request (LAR) have been reviewed and are unaffected by this supplemental response.
This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of August 2019.
Respectfully submitted,
~::*~
Nuclear Licensing Manager Southern Nuclear Operating Company JMC/RMJ
U.S. Nuclear Regulatory Commission NL-19-0985 Page 2 Attachments: A. Revisions to Transition Report Attachment A C. Revisions to Transition Report Attachm*ent C (Security-related information)
J. Revisions to Transition Report Attachment J S. Revisions to Transition Report Attachment S (Security-related information) cc:
Regional Administrator, Region II NRR.Project Manager-Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004
Edwin I. Hatch Nuclear Plant-Units 1 and 2 Supplemental 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 Attachment.A Revisions to Transition Report Attachment A NEI 04-02 Table 8 Transition of Fundamental FP Program and Design Elements
Southern Nuclear Operating Company Attachment A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements NFPA 805 Ch. 3 Ref.
Requirements/Guidance Compliance Statement 3.3.5.2 Only metal tray and metal Complies conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.
Submit for NRC Approval Complies, with Required Action Compliance Basis Except as identified below, HNP complies with no additional clarification.
FAQ 06-0021 defines "short lengths" as approximately three feet of flexible metallic conduit.
NRC approval of the use of PVC coated flexible conduit in lengths up to 6 feet and embedded non-metallic conduit is being requested in Attachment L, Approval Request 4.
Implementation items are identified below.
IMPLEMENTATION ITEMS (See Attachment S, Table S-3):
Reference Document Drawing A29500, Conduit and Conduit Support, Ver. 3.0 / Section 3.1 Drawing A29501, General Design Document and Details for the Installation of Nonsafety-Related Electrical Work, Ver. 2.0 / Section 6.0 Drawing 813000, Conduit &
Grounding Installation Notes, Ver.
5.0 E-1-03, SNC Raceway Design Standard, Rev. 6 Specification SS-2123-009, Technical Specification for Cable Trays and Cable Tray Accessories for the Edwin I. Hatch Nuclear Plant - Unit 2, Rev. A/ All F AO 06-0021, Cable Air Drops, Rev. 0 / All None IMP-20 Current cable/raceway installation procedures allow for flexible metallic conduit installations up to 6-feet, or greater if approved by the Architectural Engineer. Cable/raceway procedures will be revised to ensure that installation guidance is limited to a maximum of 6 feet for future flexible metallic conduit installations.
HNP Page A-20
Southern Nuclear Operating Company NFPA 805 Ch. 3 Ref.
Requirements/Guidance 3.5.7 Individual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizing valves between connections.
3.5.8 A method of automatic pressure maintenance of the fire protection water system shall be provided independent of the fire pumps.
3.5.9 Means shall be provided to immediately notify the control room, or other suitable constantly attended location, of operation of fire pumps.
3.5.10 An underground yard fire main loop, designed and installed in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be installed to furnish anticipated water requirements.
HNP Attachment A - NEI 04-02 Table 8 Transition of Fundamental FP Program and Design Elements Compliance Statement Complies Complies Complies Complies with Use of EEEE's Compliance Basis No Additional Clarification No Additional Clarification No Additional Clarification The underground yard fire main loop is designed in accordance with NFPA 24 as identified in Calculation SMNH-16-031, NFPA 24 Code Compliance Review.
Reference Document Drawing H-11033 Sheet 1, Fire Protection-P&ID Pumphouse Layout, Ver. 51.0 I All Drawing H-11033 Sheet 1, Fire Protection-P&ID Pumphouse Layout, Ver. 51.0 I All A-42162, Unit No. 1 / 2 Fire Protection Detection/Annunciation Multiplex Database, Rev. 10 / All Procedure 34SV-X43-001 -1, Fire Pump Test, Ver. 3.5 / Section 7.0 Calculation SMNH-16-031, NFPA 24 Code Compliance Review, Ver.
1 / All Drawing H-11033 Sheet 1, Fire Protection-P&ID Pumphouse Layout, Ver. 51.0 I All NFPA 24, Standard for Outside Protection, 1973 Edition / All
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Page A-46
3.5.10 Complies, with Required Action IMPLEMENTATION ITEMS (See Attachment S, Table S-3):
Implementation items are identified below.
None IMP-21 Bollards or other appropriate protection will be provided for yard post indicator valves 1 Y 43-F308P and 1 Y 43-F316P in accordance with approved plant design.
Edwin I. Hatch Nuclear Plant - Units 1 and 2 Supplemental 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 Attachment J Revisions to Transition Report Attachment J Fire Modeling V&V
Southern Nuclear Operating Company Attachment J - Fire Modeling V&V Table J-1 V & V Basis for Fire Models / Model Correlations Used Calculation Heat Detection Actuation Correlation HNP Application Al~ling Jet eorrelatioo---is usefl to fletermine temperature anfl the I leskest1td---aftd Deliehatsios temperature to smolte flensit) correlation for smoke fleteetion timing estimates An optical density method, developed from Alpert's ceiling jet temperature correlation, is used determine the time to automatic smoke detection.
Estimates heat detector timing based on the Alpert ceiling jet temperature, velocity, and thermal response of sprinkler.
V & V Basis Technical
Reference:
NUREG-1805, Chapter 11, 2004 NUREG-1824, Volume 4, 2007 NUREG-1934, Chapter 2, 2012 SFPE Handbook of Fire Protection Engineering, 5th Edition, Chapter 40, Custer R., Meacham B., and Schifiliti, R., 2016 SFPE Handbook of Fire Protection Engineering, 5th Edition, Chapter 14, Alpert, R., 2016 Technical
Reference:
NUREG-1805, Chapter 11, 2004 NFPA Fire Protection Handbook, 19th Edition, Chapter 3-9, Budnick, E., Evans, D., and Nelson, H.,
2003 NUREG-1824, Volume 4, 2007 NUREG-1934, Chapter 2, 2012 Discussion The smoke detection correlation is contained in NUREG-1805.
Alpert's ceiling jet correlation V&V is documented in NUREG-1824.
The correlation has been applied within its limits of applicability and the validated range reported in NUREG-1 824 or, if applied outside the validated range, the model has been justified as acceptable, either by qualitative analysis, or by quantitative sensitivity analysis. The methodology for justifying application of the fire model outside the range is in accordance with e IP.d in I IR 3
o e
o
- 1 e *a11 llowing HNP Calculations:
A, "Hatch Fire PRA Task 8/11a, Fire Scenario Development nd Detailed Fire Modeling", Version 2, Attachment A, Fire M eling Workbook Methodology for HNP The correlation is ocumented in an authoritative publication of the NFPA Fire Pr tection Handbook.
Alpert's ceiling j t correlation V&V is documented in NUREG-1824.
has been applied within its limits of applicability and the vali led range reported in NUREG-1 824 or, if applied outside the alidated range, the model has been justified as acceptabl, either by qualitative analysis, or by quantitative sensitivit analysis. The methodology for justifying application of the fi~ model outside the range is in accordance with metho documented in NUREG-1934.
The applic bility of the V& V basis to the model implementation in the HNP FP is described in the following HNP Calculations:
H-IE-FIREPRA-UOO-OOBA, "Hatch Fire PRA Task 8/11a, Fire S enario Development and Detailed Fire Modeling", Version 2, tachment A, Fire Modeling Workbook Methodology for HNP Page J-6