Letter Sequence Response to RAI |
---|
|
|
MONTHYEARRNP-RA/14-0134, Response (90-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 8052014-12-22022 December 2014 Response (90-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 Project stage: Request RNP-RA/15-0023, Response (60-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 8052015-03-16016 March 2015 Response (60-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 Project stage: Request RNP-RA/15-0071, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2015-07-31031 July 2015 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. Project stage: Response to RAI ML15281A1982015-11-10010 November 2015 Summary of Meeting with Duke Energy Progress Inc., to Discuss the H. B. Robinson Steam Electric Plant Unit No. 2, License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Meeting ML15343A0712015-12-23023 December 2015 September 22-26, 2014, Summary of H. B. Robinson Steam Electric Plant, Unit 2 - Audit Associated with License Amendment Request to Transition to the National Fire Protection Association 805 Standard Project stage: Other ML15342A2052016-01-0808 January 2016 Regulatory Audit in Support of License Amendment Request to Adopt NFPA 805 Project stage: Other ML16048A3492016-03-0202 March 2016 RAI 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 Project stage: RAI RNP-RA/16-0017, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-03-16016 March 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. Project stage: Response to RAI ML16158A0062016-05-25025 May 2016 Response to Request for Additional Information Re License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. Pages 1-21 Project stage: Response to RAI RNP-RA/16-0038, Transition Report, Revision 1, Transition to National Fire Protection Association Standard 805, with Attachments a, I, J, L, M, and V. Pages 22-1742016-05-25025 May 2016 Transition Report, Revision 1, Transition to National Fire Protection Association Standard 805, with Attachments a, I, J, L, M, and V. Pages 22-174 Project stage: Request ML16230A2342016-07-25025 July 2016 Response to Request for Additional Information License Amendment Request to Adopt National Fire Protection Association Standard 805 Project stage: Response to RAI RNP-RA/16-0079, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-10-0505 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. Project stage: Response to RAI ML16337A2642017-02-0303 February 2017 Issuance of Amendments Regarding National Fire Protection Association Standard 805 Project stage: Approval 2016-01-08
[Table View] |
|
---|
Category:Letter type:RNP
MONTHYEARRNP-RA/21-0035, Duke Energy Progress, Inc - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-18018 February 2021 Duke Energy Progress, Inc - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report RNP-RA/20-0234, Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks2020-07-23023 July 2020 Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks RNP-RA/20-0199, Registration of Use of Spent Fuel Casks2020-06-25025 June 2020 Registration of Use of Spent Fuel Casks RNP-RA/18-0063, Request for Extension of Due Date for Seismic Probabilistic Risk Assessment Submittal2018-11-29029 November 2018 Request for Extension of Due Date for Seismic Probabilistic Risk Assessment Submittal RNP-RA/18-0060, Transmittal of Core Operating Limits Report2018-10-17017 October 2018 Transmittal of Core Operating Limits Report RNP-RA/18-0050, Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change2018-08-0101 August 2018 Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change RNP-RA/18-0044, Supplement to License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transform2018-07-11011 July 2018 Supplement to License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers RNP-RA/18-0039, Transmittal of Emergency Procedure Revisions and 10 CFR 50.54(q) Summary of Analysis2018-06-27027 June 2018 Transmittal of Emergency Procedure Revisions and 10 CFR 50.54(q) Summary of Analysis RNP-RA/18-0041, Independent Spent Fuel Storage Installation - Register as User for Cask2018-06-13013 June 2018 Independent Spent Fuel Storage Installation - Register as User for Cask RNP-RA/18-0036, Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ...2018-05-16016 May 2018 Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ... RNP-RA/18-0029, Submittal of 2017 Annual Radiological Environmental Operating Report2018-05-0808 May 2018 Submittal of 2017 Annual Radiological Environmental Operating Report RNP-RA/18-0031, (Hbrsep), Unit 2 - 2017 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Revision 352018-04-23023 April 2018 (Hbrsep), Unit 2 - 2017 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Revision 35 RNP-RA/18-0015, Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequently Requirements to a Licensee Controlled Program2018-04-16016 April 2018 Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequently Requirements to a Licensee Controlled Program RNP-RA/18-0024, Report of Changes Pursuant to 10 CFR 50.59(d)(2)2018-04-0202 April 2018 Report of Changes Pursuant to 10 CFR 50.59(d)(2) RNP-RA/18-0020, Notification of Change in Licensed Operator Status2018-02-20020 February 2018 Notification of Change in Licensed Operator Status RNP-RA/18-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2018-01-23023 January 2018 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report RNP-RA/17-0085, Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2018-01-0808 January 2018 Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0086, Transmittal of Emergency Procedure Revision and 10 CFR 50.54(q) Summary of Analyses2017-12-14014 December 2017 Transmittal of Emergency Procedure Revision and 10 CFR 50.54(q) Summary of Analyses RNP-RA/17-0081, Submittal of Change in Licensed Operators Medical Status2017-12-11011 December 2017 Submittal of Change in Licensed Operators Medical Status RNP-RA/17-0079, Operator License Renewal Application2017-12-0707 December 2017 Operator License Renewal Application RNP-RA/17-0071, Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks2017-10-19019 October 2017 Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks RNP-RA/17-0068, Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-09-28028 September 2017 Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0037, License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specifications 3.8.1, AC Sources-Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers2017-09-27027 September 2017 License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specifications 3.8.1, AC Sources-Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers RNP-RA/17-0043, Relief Request (RR)-12 for Relief from Volumetric/Surface Examination Frequency Requirements of ASME Code Case N-729-42017-09-22022 September 2017 Relief Request (RR)-12 for Relief from Volumetric/Surface Examination Frequency Requirements of ASME Code Case N-729-4 RNP-RA/17-0065, Refueling Outage 30 Steam Generator Tube Inspection Report2017-09-18018 September 2017 Refueling Outage 30 Steam Generator Tube Inspection Report RNP-RA/17-0060, Notification of Change in Licensed Operator Status2017-08-10010 August 2017 Notification of Change in Licensed Operator Status RNP-RA/17-0058, Notification of Change in Licensed Operator Status2017-08-0303 August 2017 Notification of Change in Licensed Operator Status RNP-RA/17-0055, Transmittal of Core Operating Limits Report for Cycle 312017-07-26026 July 2017 Transmittal of Core Operating Limits Report for Cycle 31 RNP-RA/17-0042, Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals2017-06-29029 June 2017 Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals RNP-RA/17-0051, Submittal of Nine Day Inservice Inspection Summary Report2017-06-29029 June 2017 Submittal of Nine Day Inservice Inspection Summary Report RNP-RA/17-0041, Transmittal of Technical Specifications Bases Revisions2017-05-23023 May 2017 Transmittal of Technical Specifications Bases Revisions RNP-RA/17-0038, (Hbrsep), Unit No. 2 - 2016 Annual Radiological Environmental Operating Report2017-05-0909 May 2017 (Hbrsep), Unit No. 2 - 2016 Annual Radiological Environmental Operating Report RNP-RA/17-0034, Modification of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles (MF9544)2017-05-0202 May 2017 Modification of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles (MF9544) RNP-RA/17-0036, (Hbrsep), Unit No. 2 - 2016 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Current Revision 342017-04-25025 April 2017 (Hbrsep), Unit No. 2 - 2016 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Current Revision 34 RNP-RA/17-0031, Provides Additional Information Regarding License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler 522, Revision 02017-04-20020 April 2017 Provides Additional Information Regarding License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler 522, Revision 0 RNP-RA/17-0033, Flood Hazard Mitigating Strategies Assessment (MSA) Report Submittal2017-04-12012 April 2017 Flood Hazard Mitigating Strategies Assessment (MSA) Report Submittal RNP-RA/17-0014, Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-04-0303 April 2017 Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0028, Submittal of Engineering Calculation in Support of a Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-04-0303 April 2017 Submittal of Engineering Calculation in Support of a Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0021, Transmittal of Core Operating Limits Report2017-03-13013 March 2017 Transmittal of Core Operating Limits Report RNP-RA/17-0019, Supplemental Submittal to Correct Marked Up Technical Specifications (TS) Pages Transmitted with Application for Technical Specification Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Revision 22017-03-0808 March 2017 Supplemental Submittal to Correct Marked Up Technical Specifications (TS) Pages Transmitted with Application for Technical Specification Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Revision 2 RNP-RA/17-0015, Independent Spent Fuel Storage Installations - Letter Regarding Report of Changes Pursuant to 10 CFR 72.482017-02-22022 February 2017 Independent Spent Fuel Storage Installations - Letter Regarding Report of Changes Pursuant to 10 CFR 72.48 RNP-RA/17-0016, Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report2017-02-22022 February 2017 Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report RNP-RA/17-0015, H.B. Robinson Steam Electric Plant & ISFSIs - Report of Changes Pursuant to 10 CFR 72.482017-02-22022 February 2017 H.B. Robinson Steam Electric Plant & ISFSIs - Report of Changes Pursuant to 10 CFR 72.48 RNP-RA/16-0100, Response to Apparent Violation in NRC Inspection Report 05000261/2016404, EA-16-2272017-01-24024 January 2017 Response to Apparent Violation in NRC Inspection Report 05000261/2016404, EA-16-227 RNP-RA/16-0097, Transmittal Letter for Response to Inspection Report Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1-7, Inspection Report 05000261/20154052016-12-15015 December 2016 Transmittal Letter for Response to Inspection Report Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1-7, Inspection Report 05000261/2015405 RNP-RA/16-0089, Request for Withdrawal of License Amendment Request for Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2016-11-10010 November 2016 Request for Withdrawal of License Amendment Request for Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/16-0090, Notification of Rescheduled Date for 2017 Emergency Preparedness Graded Exercise2016-11-10010 November 2016 Notification of Rescheduled Date for 2017 Emergency Preparedness Graded Exercise RNP-RA/16-0087, Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors2016-10-31031 October 2016 Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors RNP-RA/16-0078, Technical Specifications Section 5.6.6, Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors2016-10-0505 October 2016 Technical Specifications Section 5.6.6, Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors RNP-RA/16-0079, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-10-0505 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. 2021-02-18
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARRA-23-0136, Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0154, Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0142, Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require2023-07-0707 July 2023 Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require RA-23-0015, Response to Request for Additional Information (RAI) Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.22023-02-0909 February 2023 Response to Request for Additional Information (RAI) Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.2 RA-22-0245, Response to Request for Additional Information (RAI) Regarding Removal of 4.160 Kilovolt Bus 2 from Surveillance Requirement 3.8.1.162022-09-0808 September 2022 Response to Request for Additional Information (RAI) Regarding Removal of 4.160 Kilovolt Bus 2 from Surveillance Requirement 3.8.1.16 RA-22-0210, Supplement to License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2022-07-28028 July 2022 Supplement to License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections RA-22-0144, Response to NRC Request for Additional Information Regarding Supplemental Response to Generic Letter 2004-022022-05-19019 May 2022 Response to NRC Request for Additional Information Regarding Supplemental Response to Generic Letter 2004-02 RA-22-0147, Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Relocating the Duke Energy Emergency Operations Facility2022-05-13013 May 2022 Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Relocating the Duke Energy Emergency Operations Facility RA-22-0106, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2022-04-28028 April 2022 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections RA-21-0230, Duke Energy - Final Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors2021-09-30030 September 2021 Duke Energy - Final Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors RA-21-0063, 1, 2; Catawba Nuclear Station 1, 2; H. B. Robinson Steam Electric Plant 2; Mcgguire Nuclear Station 1, 2; Oconee Nuclear Station 1, 2, 3; Shearon Harris Nuclear Power Plant 1 - Response to RAI Re Amend for Emergency Plan2021-03-11011 March 2021 1, 2; Catawba Nuclear Station 1, 2; H. B. Robinson Steam Electric Plant 2; Mcgguire Nuclear Station 1, 2; Oconee Nuclear Station 1, 2, 3; Shearon Harris Nuclear Power Plant 1 - Response to RAI Re Amend for Emergency Plan RA-21-0032, Duke Energy - Response to Requests for Additional Info for Request to Use a Provision of Later Edition & Addenda of the ASME Boiler & Pressure Vessel Code, Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(42021-02-11011 February 2021 Duke Energy - Response to Requests for Additional Info for Request to Use a Provision of Later Edition & Addenda of the ASME Boiler & Pressure Vessel Code, Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(4)( RA-20-0048, Response to Request for Additional Information for Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Vessel Cold Leg Dissimilar Metal Weld Inspections2020-03-0404 March 2020 Response to Request for Additional Information for Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Vessel Cold Leg Dissimilar Metal Weld Inspections RA-20-0018, Supplement to Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding; Integrated Assessment Submittal2020-01-23023 January 2020 Supplement to Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding; Integrated Assessment Submittal RA-19-0460, Revised Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal2019-12-19019 December 2019 Revised Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal RA-19-0452, Seismic Probabilistic Risk Assessment (Spra), Response to March 12, 2012, Request for Information Regarding Recommendation 2.1: Seismic, of the Near-Term Task Force Related to the Fukushima Dai-ichi Accident2019-12-12012 December 2019 Seismic Probabilistic Risk Assessment (Spra), Response to March 12, 2012, Request for Information Regarding Recommendation 2.1: Seismic, of the Near-Term Task Force Related to the Fukushima Dai-ichi Accident RA-19-0421, Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal (RA-19-0145)2019-11-13013 November 2019 Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal (RA-19-0145) RA-19-0386, Response to Request for Additional Information (RAI) Regarding License Amendment Request Proposing to Revise Technical Specification 3.8.2, AC Sources - Shutdown, Surveillance Requirement 3.8.2.12019-10-24024 October 2019 Response to Request for Additional Information (RAI) Regarding License Amendment Request Proposing to Revise Technical Specification 3.8.2, AC Sources - Shutdown, Surveillance Requirement 3.8.2.1 RA-19-0154, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2019-05-0606 May 2019 Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors RA-19-0026, Response to Request for Additional Information (RAI) Regarding Proposed Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 2 and 10 (18-GO-001)2019-02-11011 February 2019 Response to Request for Additional Information (RAI) Regarding Proposed Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 2 and 10 (18-GO-001) RA-18-0185, Response to Request for Additional Information (RAI) Regarding 10 CFR 50.46 Annual Report, Including Revised Robinson Large Break Loss of Coolant Accident Report2018-12-10010 December 2018 Response to Request for Additional Information (RAI) Regarding 10 CFR 50.46 Annual Report, Including Revised Robinson Large Break Loss of Coolant Accident Report RA-18-0194, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt TSTF-425, Revision 32018-11-13013 November 2018 Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt TSTF-425, Revision 3 RA-18-0193, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power ..2018-11-13013 November 2018 Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power .. RNP-RA/18-0050, Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change2018-08-0101 August 2018 Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change RA-18-0016, Response to Request for Additional Information Regarding Technical Specification Changes to Support Self-Performance of Core Reload Design and Safety Analyses2018-06-0505 June 2018 Response to Request for Additional Information Regarding Technical Specification Changes to Support Self-Performance of Core Reload Design and Safety Analyses RNP-RA/18-0036, Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ...2018-05-16016 May 2018 Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ... RNP-RA/17-0085, Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2018-01-0808 January 2018 Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RA-17-0055, Response to Second Request for Additional Information (RAI) Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Revision 02017-12-19019 December 2017 Response to Second Request for Additional Information (RAI) Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Revision 0 RA-17-0048, Transmittal of Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Rev. 0 (Part 2)2017-10-30030 October 2017 Transmittal of Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Rev. 0 (Part 2) RA-17-0043, Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Revision 02017-10-0909 October 2017 Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3009, Revision 0 RNP-RA/17-0068, Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-09-28028 September 2017 Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RA-17-0039, Response to Request for Additional Information (RAI) Regarding 10 CFR 50.55a(z)(1)Proposed Alternative to ASME Section XI Threads in Flange Examination (17-GO-001)2017-08-0909 August 2017 Response to Request for Additional Information (RAI) Regarding 10 CFR 50.55a(z)(1)Proposed Alternative to ASME Section XI Threads in Flange Examination (17-GO-001) RA-16-0042, Response to Request for Additional Information Application to Revise Technical Specifications for Methodology Reports DPC-NF-2010, Revision 3 & DPC-NE-2011-P, Revision 2. Redacted Version Enclosed2016-11-17017 November 2016 Response to Request for Additional Information Application to Revise Technical Specifications for Methodology Reports DPC-NF-2010, Revision 3 & DPC-NE-2011-P, Revision 2. Redacted Version Enclosed ML16315A2722016-11-10010 November 2016 Duke Energy Transmittal of Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-3008, Revision 0 RNP-RA/16-0079, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-10-0505 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. ML16280A2002016-10-0505 October 2016 Response to Request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals RA-16-0036, Regarding Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-1008, Rev 02016-10-0303 October 2016 Regarding Response to Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-1008, Rev 0 RA-16-0035, Response to Request for Additional Information (RAI) Regarding Application for Emergency Operations Facility (EOF) Consolidation2016-10-0303 October 2016 Response to Request for Additional Information (RAI) Regarding Application for Emergency Operations Facility (EOF) Consolidation RNP-RA/16-0072, Response to Request for Additional Information Regarding Application for Technical Specification Change to Adopt Technical Specifications Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Rev. 22016-09-14014 September 2016 Response to Request for Additional Information Regarding Application for Technical Specification Change to Adopt Technical Specifications Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Rev. 2 RNP-RA/16-0073, Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits2016-09-14014 September 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits ML16230A2342016-07-25025 July 2016 Response to Request for Additional Information License Amendment Request to Adopt National Fire Protection Association Standard 805 RA-16-0027, Response to NRC Regulatory Issue Summary 2016-09 Preparation and Scheduling of Operator Licensing Examinations2016-07-14014 July 2016 Response to NRC Regulatory Issue Summary 2016-09 Preparation and Scheduling of Operator Licensing Examinations ML16158A0062016-05-25025 May 2016 Response to Request for Additional Information Re License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. Pages 1-21 RNP-RA/16-0038, Transition Report, Revision 1, Transition to National Fire Protection Association Standard 805, with Attachments a, I, J, L, M, and V. Pages 22-1742016-05-25025 May 2016 Transition Report, Revision 1, Transition to National Fire Protection Association Standard 805, with Attachments a, I, J, L, M, and V. Pages 22-174 RNP-RA/16-0031, Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits2016-05-0909 May 2016 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits RNP-RA/16-0024, Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits2016-03-31031 March 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits RNP-RA/16-0017, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-03-16016 March 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. ML16063A1032016-02-18018 February 2016 Response to NRC Request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals RNP-RA/16-0011, Response to NRC Request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals2016-02-18018 February 2016 Response to NRC Request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals RNP-RA/15-0117, Supplement to Request for Technical Specification Change to Reactor Coolant System Pressure and Temperature Limits2015-12-22022 December 2015 Supplement to Request for Technical Specification Change to Reactor Coolant System Pressure and Temperature Limits 2023-07-07
[Table view] |
Text
SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 R. Michael Glover
(~ DUKE H. B. Robinson Steam Electric Plant Unit 2 ENERGY~ Site Vice President Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 OCTJ '.1'5 ZOJI 0 : 843 857 1704 F: 843 857 1319 Mike.GICNB'@Jilke-mergy.com Serial: RNP-RA/16-0079 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS"
Dear Sir/Madam:
By letter dated September 16, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13267A211) Duke Energy Progress, Inc. (OEP) submitted a license amendment request (LAR) for H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) . This LAR would adopt a new fire protection licensing basis that complies with the requirements of Title 1O of the Code of Federal Regulations, Sections 50.48(a) and (c); the guidance in Regulatory Guide 1.205, Revision 1, "Risk-Informed , Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants"; and National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants" (2001 Edition).
By letter dated July 31 , 2015 (ADAMS Accession No. ML15212A136), DEP submitted a response to a NRC request for additional information (RAI) . The NRC staff determined that additional information is needed to complete its review related to probabilistic risk assessment (PRA). A draft of that information request was received by DEP via email message on November 20, 2015 (ADAMS Accession No. 15324A328), officially via letter dated March 2, 2016 (ADAMS Accession No. ML16048A349). An RAl clarification call was held on December 7, 2015. The NRC staff also held an onsite audit February 9-10 , 2016, to establish a proposed resolution of outstanding issues associated with the HBRSEP2 NFPA 805 review.
By letter dated May 25, 2016 (ADAMS Accession No. ML16158A006 and ML16158A267), DEP revised the LAR Attachment L, "NFPA 805, Chapter 3 Requirements for Approval," by adding an additional approval request not submitted with the original LAR. DEP requested NRC staff review and approval of a performance-based method to demonstrate an equivalent level of fire protection for the requirements of NFPA 805 Section 3.3.4, Insulation Materials, because the insulation materials do not meet the definition of limited combustible due to the heat value exceeding 3500 Enclosure 2 to this letter contains SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 Upon removal of Enclosure 2, this letter is decontrolled.
SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Serial: RNP-RA/16-0079 Page2 Btu/lb. Based on the information provided by DEP in its request, the NRC staff requested additional information to complete its review. Enclosure 1 of this submittal provides the response to this request and DEP's revision to LAR Attachment L, Approval Request 5.
Discussions with the staff regarding the retirement of Fire Protection FAQ 08-0046, prompted DEP to provide new LAR section 4.8.3.3 to discuss the sensitivity for the credit given for in-cabinet Incipient Detection in the analysis. This also prompted the revision of Implementation Item 14, from Table S-3 in the LAR. Enclosure 2, which contains security-related information, conveys this revision to Table S-3.
Please address any comments or questions regarding this matter to Mr. Tony Pila, Acting Manager
- Nuclear Regulatory Affairs at (843) 857-1409.
There are no new regulatory commitments made in this letter.
I declare under penalty of perjury that the foregoing is true and correct. Executed on 0-...l-o~ar S , 2016.
R. Michael Glover Site Vice President RMG/jmw : NFPA 805 Section 3.3.4, Insulation Materials, RAI response and revision to LAR Attachment L, Approval Request 5 : Revision of Implementation Item 14 from Table S-3.
cc: Region Administrator, NRC, Region II Mr. Dennis Galvin, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP2 Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)
(w/o Attachment)
Enclosure 2 to this letter contains SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Upon removal of Enclosure 2, this letter is decontrolled.
U. S. Nuclear Regulatory Commission to Serial: RNP-RA/16-0079 9 Pages (including this cover sheet)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, PERFORMANCE-BASED STANDARD FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval Approval Request 5 NFPA 805 Section 3.3.4 NFPA 805 Section 3.3.4 states:
Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.
Per the HBRSEP piping and equipment thermal insulation specification, AP Armaflex, Insul-Tube 180 and Insul-Sheet thermal insulation materials are used at HBRSEP.
These insulation materials meet the flame spread rating criteria but do not meet the NFPA 805 Section 3.3.4 definition of non-combustible or limited combustible regarding heat value content. This approval request is limited to the thermal insulation materials used at HBRSEP.
NFPA 805 Section 1.6.36 has re-defined earlier definitions of non-combustible material to the now current definition of limited combustible material:
Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg) and either has a structural base of noncombustible material with a surfacing not exceeding a thickness of 1/8 in. (3.2 mm) that has a flame spread rating not greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.
Therefore the above described thermal insulation materials utilized at HBRSEP are considered to be in deviation from the NFPA 805 Chapter 3 element, for which approval is requested for continued use of these thermal insulation materials.
Basis for Request:
In several areas at HBRSEP, exposed thermal insulation materials are installed for industrial personnel safety and on miscellaneous system piping to prevent sweating.
These materials met the Branch Technical Position (BTP) APCSB 9.5.1/Appendix R requirements for limited combustibles by complying with the flame spread rating of 25 or less as measured using the test method of ASTM E-84, but do not meet the current decreased heat value content requirement based on the definition of a limited combustible due to the heat value exceeding 3500 Btu/lb. Typical thermal insulation materials were noted as having heat contribution values of approximately 9,000 to11,000 Btu/lb, which, while higher than the definition, is not considered to contribute appreciably to the spread of fire, nor represent a secondary combustible beyond those currently analyzed in the FPRA due to the limited applications.
The basis for the approval request of this deviation is:
- The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less HBRSEP LAR Rev 2 Page L-15
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval and will not support continued progressive combustion. Specifically, the thermal insulation materials used at HBRSEP have fuel contribution, flame spread, and smoke developed ratings of 25, 25, and 50 per ASTM E-84, respectively.
Although the thermal insulation materials exceed the NFPA 805 heat value of 3500 Btu/lb, AP Armaflex will not contribute significantly to fire per ASTM E-84, and Insul-Tube 180 and Insul-Sheet are self-extinguishing per ASTM D635.
- The forms in which the thermal insulation are installed and the conditions anticipated do not impact the three echelons of defense-in-depth:
o Echelon 1 is not impacted because the thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less and will not support continued progressive combustion.
o Echelon 2 is not impacted because the limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not result in increased combustible loading which would challenge the design bases of the installed fire protection systems. The presence of the thermal insulation and associated procedural controls do not impact the ability of the automatic suppression and detection systems to perform credited functions, as the materials at HBRSEP are of limited in quantities will not support continued progressive combustion.
o Echelon 3 is not impacted because the limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not adversely impact the installed fire protection systems and features, and essential safety functions are maintained and capable of being performed. The insulation material does not impact the post-fire safe shutdown capability in any of the fire areas where it is installed.
- The forms in which the thermal insulation materials are installed and the conditions anticipated do not impact Nuclear Safety. The limited applications of exposed thermal insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed and considered. Adequate defense-in-depth measures are in place as described above to ensure that essential safety functions are maintained and capable of being performed.
- The identified installations were evaluated against the fire scenarios supporting the FPRA. In all instances, the supporting analyses and existing fire scenarios were found to be bounding (expanded zones of influence would not fail additional HBRSEP LAR Rev 2 Page L-16
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval FPRA targets) or there were no FPRA credited targets in the area. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required.
During development of this approval request a number of plant locations were identified where insulation material is used for low point obstruction or head-bump protection (industrial safety). These applications include less than one pound of material affixed to pipes, conduits, and structural components. Additional limited anti-sweat applications were identified primarily in the Turbine Building on piping associated with heating, ventilation and air conditioning systems supporting Power Block structures including the following:
- System 8150 - Containment Building HVAC - piping routed in the Turbine Building
- System 8210 - Auxiliary Building HVAC - piping routed in the Turbine Building
- System 8220 - Control Room HVAC - HVAC Equipment Room for the Control Room
- System 8260 - Turbine Building HVAC - piping routed in Turbine Building Non-HVAC anti-sweat applications were limited to systems (System 4011, Condenser Ball Cleaning) supporting the condenser located on or adjacent to the waterboxes.
All of the identified locations were evaluated against the fire scenarios supporting the FPRA. In all instances, the supporting analyses and existing fire scenarios were found to be bounding or there were no FPRA credited targets in the area. The limited applications of exposed thermal insulation material were not of a quantity that would impact the fire scenarios or zones of influences and target failures developed in support of the fire and PRA analysis, and do not compromise automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required.
HBRSEP LAR Rev 2 Page L-17
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval Acceptance Criteria Evaluation:
Nuclear Safety and Radiological Release Performance Criteria:
The use of thermal insulation material other than non-combustible and more than limited combustible in the plant does not affect Nuclear Safety. The limited applications of exposed thermal insulation materials do not compromise post-fire safe shutdown capability. Essential safety functions are maintained and capable of being performed.
The forms in which the thermal insulation materials are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. The selection and application of thermal insulation material is controlled per the HBRSEP piping and equipment thermal insulation specification. The Fire PRA development requires the inclusion of the effect of intervening or secondary combustibles to be documented and included in the analysis where determined to have fire effects as part of the performance-based approach. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required.
Plant walkdowns and personnel interviews concluded that there were no large concentration installations of thermal insulation in the plant. The most common applications include less than a pound for industrial safety (head-bump protection) and anti-sweat installations on small diameter piping. The impact of the negligible quantities of exposed materials was noted to be bounded by the currently analyzed fire scenario zones of influence, and did not result in new or expanded ZOIs that impacted additional FPRA targets. No existing fire scenarios as considered in the FPRA were adversely impacted.
The use of insulation material other than non-combustible and more than limited combustible has no impact on the radiological release performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing or potentially containing radioactive materials and is not dependent on the type of thermal insulation material. The insulation material, regardless of heat contribution value, does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained and smoke is monitored. The insulation materials do not add additional radiological materials to the area or challenge systems boundaries.
Safety Margin and Defense-in-Depth:
The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not compromise automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.
HBRSEP LAR Rev 2 Page L-18
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval The insulation materials in the current configurations are considered as non-cable intervening combustibles and are bound by the FPRA, and safety margin is not affected.
The selection and application of thermal insulation material is controlled per the HBRSEP piping and equipment thermal insulation specification. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required. The precautions and limitations on the use of these materials do not impact the fire safety analysis of the fire event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged.
The three echelons of defense-in-depth are,
- 1) to prevent fires from starting (combustible/hot work controls),
- 2) rapidly detect, control and extinguish fires that do occur thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans), and,
- 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).
The use of insulation material which is non-combustible or more than limited combustible does not affect Echelons 1, 2, and 3. The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not introduce new ignition sources, does not exceed the design bases of installed fire protection systems, does not compromise manual fire suppression functions, and does not adversely impact fire protection systems and features or post-fire safe shutdown capability as previously designed, reviewed and considered.
- 1) Prevent Fires from Starting:
The thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. Specifically, the thermal insulation materials used at HBRSEP have fuel contribution, flame spread, and smoke developed ratings of 25, 25, and 50 per ASTM E-84, respectively. Although the thermal insulation materials exceed the NFPA 805 heat value of 3500 Btu/lb, AP Armaflex will not contribute significantly to fire per ASTM E-84, and Insul-Tube 180 and Insul-Sheet are self-extinguishing per ASTM D635.
The selection and application of thermal insulation material is controlled per the HBRSEP piping and equipment thermal insulation specification. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required.
HBRSEP LAR Rev 2 Page L-19
Duke Energy Attachment L - NFPA 805 Chapter 3 Requirements for Approval
- 2) Rapidly Detect, Control and Extinguish Fires that do Occur thereby Limiting Damage:
The limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not result in increased combustible loading which would challenge the design bases of the installed fire protection systems. The presence of the thermal insulation and associated procedural controls do not impact the ability of the automatic suppression and detection systems to perform credited functions, as the materials at HBRSEP are limited in application and will not support continued progressive combustion.
Portable fire extinguishers and hose stations are available for manual firefighting activities by the site fire brigade. Therefore, if a fire was to occur damage would be limited.
- 3) Provide Adequate Level of Fire Protection for Systems and Structures so that a Fire will not Prevent Essential Safety Functions from being Performed :
The limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not adversely impact the installed fire protection systems and features, and essential safety functions are maintained and capable of being performed. The insulation material does not compromise post-fire safe shutdown capability as previously designed, reviewed and considered.
The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at HBRSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. The identified installations were evaluated against the fire scenarios supporting the FPRA. In all instances, the supporting analyses and existing fire scenarios were found to be bounding (expanded zones of influence would not fail additional FPRA targets) or there were no FPRA credited targets in the area. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and FPRA, resulting in updates to the applicable analyses and calculations as required. The presence of the thermal insulation does not compromise automatic/manual fire protection functions, or post-fire safe shutdown capability and will not prevent essential safety functions from being performed.
==
Conclusion:==
NRC approval is requested for use of thermal insulation materials that meet the flame spread criteria, but do not meet the heat value content criteria of NFPA 805 based on these materials meeting BTP APCSB 9.5.1/Appendix R requirements. HBRSEP has determined that the approach satisfies the following criteria:
- Satisfies the performance goals performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release;
- maintains safety margin; and,
- maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
HBRSEP LAR Rev 2 Page L-20
Duke Energy 4.0 Compliance with NFPA 805 Requirements 4.8.3.3 FPRA Credit for In-Cabinet VEWFDS The Fire PRA used for the Robinson NFPA 805 LAR credited VEWFDS for in-cabinet installations. At the time of the LAR submittal, and throughout the RAI process, FAQ 08-0046 was the only method accepted by the AHJ to apply quantitative credit for VEWFDS for in-cabinet installations. Recently the NRC issued a letter that retired FAQ 08-0046 in anticipation of new guidance that will be published as NUREG-2180.
At this time it is not practical or appropriate to revise the Robinson LAR since all of the formal analysis was completed and reviewed using FAQ 08-0046 and the updated methods have not been finalized. Robinsons existing PRA update process is in place to evaluate method changes including any updates to the credit applied for VEWFDS.
A sensitivity case was performed based on using the guidance provided in the pre-publication draft NUREG-2180 in order to assess the potential impact. The total potential CDF/LERF as well as the delta CDF/LERF results are provided below for the areas which credited in-cabinet VEWFDS as well as the total. Note that the sensitivity also applied the draft NUREG guidance for area wide application as applicable for the totals.
RNP Total ES SWGR Rod CR Hagan Rm Using Draft CDF (FC200) (FC210) (FC230)
NUREG-LERF FA A16 FA A17 FA A18 2180 Variant 3.48E-05 6.44E-06 6.82E-07 4.43E-06 case 4.03E-06 7.68E-07 1.29E-07 3.99E-07 Compliant 2.88E-05 5.03E-06 3.35E-07 4.43E-06 case 3.54E-06 6.75E-07 1.07E-07 3.99E-07 6.35E-06 1.44E-06 3.47E-07 0.00E+00 Deltas 5.42E-07 9.51E-08 2.14E-08 0.00E+00 Based on the sensitivity results the CDF and LERF values generally increase however there are no excessive changes and it is reasonable to continue using the current Robinson LAR as the basis to continue forward with LAR approval process and subsequent self-approval status for Robinson.
HBRSEP LAR Rev 2 Page 58
Duke Energy 4.0 Compliance with NFPA 805 Requirements Fire Areas A16 and A17 each have only one fire compartment as shown above. Fire Area A18, however, is comprised of Fire Compartments FC 220, Control Room, and FC 230, Hagan Room. For Table W-5 comparison purposes, the sensitivity results are provided below for Fire A18:
RNP Fire Area A18 Using Draft Control Room and Hagan Room NUREG-2180 Variant 1.19E-05 case 1.21E-06 Compliant 1.04E-05 case 1.06E-06 1.51E-06 Deltas 1.51E-07 The delta in this area is still attributable to control room abandonment. Since there is no delta contribution from the hagan room, changes to incipient detection credit does not impact the delta.
HBRSEP LAR Rev 2 Page 58a