View source for NL-12-1893, License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

{{Adams
| number = ML12279A235
| issue date = 09/25/2012
| title = License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
| author name = Ajluni M
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000348, 05000364
| license number = NPF-002, NPF-008
| contact person = 
| case reference number = NFPA-805, NL-12-1893
| document type = Letter type:NL, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 16
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Sensitive Information. Withhold from public Mark J. Ajiluni, P.E.          Southern Nuclear              disclosure per 10 CFR 2.390. Decontrolled Nuclear Licensing Director     Operating Company, Inc.       upon removal of Attachments C, D, G, S, 40 Inverness Center Parkway    and W from Enclosure 1.
Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 SOUTHERN Nm COMPANY September 25, 2012 Docket Nos.: 50-348                                                            NL-1 2-1893 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
Ladies and Gentlemen:
In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend Renewed Facility Operating License No. NPF-2 for Joseph M. Farley Nuclear Plant (FNP) Unit 1 and FNP Unit 2 Renewed Facility Operating License No. NPF-8. This License Amendment Request (LAR) requests the Nuclear Regulatory Commission (NRC) review and approval for adoption of a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, Revision 1. to this letter contains the FNP NFPA 805 LAR (Transition Report).
SNC considers Attachments C, D, G, S, and W to Enclosure 1 to be sensitive information and requests that it be withheld from public disclosure pursuant to 10 CFR 2.390. A redacted version is provided as Enclosure 2. In an effort to clarify the FNP approach to NRC concerns with previous LAR submittals that may have FNP applicability, Enclosure 3 provides a table to address each of the "Generic RAIs" identified by the Nuclear Energy Institute (NEI) NFPA 805 Task Force.
This letter contains no NRC commitments. As part of the activities associated with the transition to NFPA 805, FNP shall implement the necessary modifications to complete the transition to full compliance with 10 CFR 50.48(c).
A list of modifications and a schedule for completion is provided in LAR (Transition Report) Attachment S. Implementation of new NFPA 805 fire protection program shall include procedure changes, process updates, and training to affected plant personnel. This will be completed 180 days after NRC approval.

Sensitive Information. Withhold from public U.S. Nuclear Regulatory Commission                     disclosure per 10 CFR 2.390. Decontrolled NL-1 2-1893                                            upon removal of Attachments C, D,G, S, Page 2                                                 and W from Enclosure 1.
If you have any questions, please contact Mr. Ken McElroy at (205) 992-7369.
Mr. Ajluni states he is Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
S        toand subsc* dbefore me this            day of          Ljp               2012.
Notary Pdblic My commission expires: (( Z- Zo        13 Respectfully submitted, M. J. Ajluni Nuclear Licensing Director MJAGAL/lac

==Enclosures:==
: 1. NFPA 805 LAR Transition Report
: 2. NFPA 805 LAR Transition Report (Redacted Version)
: 3. Generic RAIs cc:   Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant License Amendment Request to Adopt NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
Enclosure 3 Generic RAIs

Generic RAIs - Southern FNP Comparison No.              Topic-Generic Issue                   Actions /           Ref.                    Status/Comment                      FNP Disposition Disposition 1    Monitoring Program (ML113210461 -          FAQ 59 will         11/18/11 Meeting Added additional information added to       FNP will create a NFPA Slide 11) - Closure of FAQ 59 is            address this topic. ML113210461      Section 4.6 in LAR Template (Rev. 1 N). 805 Monitoring Program necessary and clarification on use of                           ML113340218       Mirrors RAI responses for Callaway and     similar to the maintenance rule                                                ML120750108       DAEC                                       Maintenqance Rule for HSS Fire Protection FAQ 59, Rev. 5 sent to NRC 02/10/12.       Features and Systems. It Technical agreement reached on 2/16/12. will be documented in the NFPA 805 Monitoring Task Force considers this issue closed. Program Engineering NRC agreed this issue closed 6/28/12.       Evaluation to be developed during Implementation.
2    Seismic standpipes/Hose Stations            Additional dialogue 11/18/11 Meeting The exception to Section 3.6.4 is not       FNP LAR Attachment A, (ML113210461 -Slide 12) - The NRC          with the NRC is     ML113210461      endorsed. The NRC is asking licensees       Section 3.6.4 includes the wants additional information on the ability needed on this      ML113340218      without seismic hose stations to discuss    resolution deemed to fight fires following an earthquake. topic.                               how they would fight a fire in the event of acceptable by the NRC.
a seismic event. This seems to be in conflict with Section III. Comment Resolution on Proposed Rule in the Federal Register.
Discussed at 4/26/12 FAQ meeting. This topic will be eliminated as a generic RAI and plant specific RAIs will be "pulled back" based on NRC discussion with legal staff. ML121370055 Discussed at the 5/24/12 FAQ meeting.
LAR template note will suggest that licensees' (operating plants and plants with construction permits issued prior to July 1, 1976 with non-seismic standpipes and hose stations previously approved in accordance with Appendix A to BTP APCSB 9.5-1) utilize "complies via previous approval" for this Section of NPFA 805.
Task Force considers this issue closed.
NRC agreed this issue closed 6/28/12.
1

Generic RAIs - Southern FNP Comparison No.            Topic-Generic Issue                   Actions /             Ref.                    Status/Comment                     FNP Disposition Disposition 3    Total CDF/LERF (ML113210461-Slide 13)      Guidance on this    11/18/11 Meeting Added "Note to LAR Developer" in Aft. W. FNP LAR Attachment W,
     -NRC indicated that the last sentence on   topic is already in  ML113210461      No technical change made to LAR            Table W-1 provides the Slide 13 was incorrect and the CDF and     the LAR template     ML113340218      Template (Rev. 1L).                        summary of total plant risk LERF values should be E-06 and E-07,        (Rev. 1k), Section                                                              (total CDF and LERF) respectively.                              W.2                                   Task Force considers this issue closed,    including other external NRC agreed this issue closed 6/28/12.      events reported.
4    FSAR (ML113210461-Slide 14) - Industry     Make FSAR           11/18/11 Meeting This topic is not being handled            FNP LAR Section 5.2 expressed concern that the NRC had         content an           ML113210461      consistently between the transitioning     includes FSAR discussion.
changed their mind on this topic and is    attachment in NEI    ML113340218      plants. Is there a need to treat this as a Reference to FAQ 62 is requesting information that previously had 04-02, Rev. 3,                        generic topic.                             made in the LAR with been identified as not necessary. NRC       rather than part of                                                             respect to FSAR content acknowledged the change in direction       the LAR. NRC                          Change made to LAR Template (Rev. 1 L)     and format.
and referred to guidance in RG 1.174 and   desires general                       Section 5.4 (Section 5.4 Transition SRP 19.2 as some of the rationale for      information, not an                   Schedule renumbered to Section 5.5).
desiring information on FSAR content       FSAR markup or                        Added "Note to LAR Developer" detailed information.                          FAQ 12-0062 received technical agreement at FAQ meeting 5/24/12.
Task Force considers this issue closed.
NRC agreed this issue closed 6/28/12.
5    Defense-in-Depth/Safety Margin             LAR Template         11/18/11 Meeting Change made to LAR Template (Rev. 1 L)     There is still uncertainly on (ML113210461-Slide 15)- The NRC           Section 4.5.2.2 to   ML113210461      Section 4.5.2.2.                           the level of detail the NRC expressed concern that guidance on the     include additional   ML113340218                                                 is expecting. FNP LAR process simply referred to NEI 04-02,      information from                      Additional discussion with the NRC is      Section 4.5.2.2 is rather than describing the process in the  FAQ 54 to address                     needed to determine closure method.        enhanced with discussion LAR. They indicated that they do not       this concern                          NRC to review LAR template discussion. of defense in depth.
want detailed information by Fire Area.                                                                                     Additional details are provided in the Fire Risk Evaluation (FRE) report, consistent with LAR template Rev. 1N.
2

Generic RAIs - Southern FNP Comparison No.            Topic-Generic Issue                    Actions /            Ref.                   Status/Comment                       FNP Disposition Disposition 6    Fire PRA Quality (ML113210461 -Slide      The NFPA 805 TF      11/18/11 Meeting Added "Note to LAR Developer" to Tables    FNP LAR Section U and V
: 16) - Inconsistent use of terms was the    will work with the   ML113210461      U-1 and V-1 that discusses closure of      writers confirmed main concern (focused scope peer            Fire PRA TF to      ML113340218      F&Os, treatment of suggestion F&Os, and    consistent terminology and review, gap assessment, etc.)              clarify terminology                   adequate documentation of F&O              content of these sections and update the                        resolution.                                meet anticipated NRC LAR template, as                                                                expectations.
necessary (Aft. U,                   Need to add the NEI guidance that V).                                   provides guidance for these terms. NEI to look at terms for Fire PRA quality.
7    Post-Transition Change Process              Guidance about      11/18/11 Meeting Added "Note to LAR Developer" in Section   FNP LAR Section 4.7.2 is (ML113210461-Slide 17) -The NRC            this is provided in  ML113210461      4.7.2 of LAR Template (Rev. 1L) and        consistent with the Generic wants to know more on site specific        the LAR template     ML113340218      referred to an example (utility response   Template and other implementation. The industry expressed     (Rev. 1k) Section                     dated 9/27/10 and 8/13/2009).              industry submittals.
concern about being able to provide a lot  4.7.2. FAQ 61                                                                    Industry questions the of specifics with the LAR submittal. The   (under                                Task Force considers this issue closed,    generic nature of this RAI NRC indicated that some level of detail on development) will                     NRC to review LAR template discussion. as it showed up only at one which site specific processes and          help address this                                                                utility and the industry procedures would be modified would         topic.                                                                           responses are very similar.
need to be provided in the LAR                                                                                              FAQ 61 is under NRC review.
8    Non-Power Operations (ML113210461-        The TF will update   11/18/11 Meeting Added "Note to LAR Developer" in           FNP LAR Attachment D Slide 18) - The NRC wants more detailed    the LAR template     ML113210461      Attachment D of LAR Template (Rev. 1 L). includes the statement "No information in the LAR on pre-fire actions (Section 4.3.2, Aft. ML113340218                                                 pre-fire actions or recovery to prevent spurious operation (e.g.,       D) to address this                    Task Force considers this issue closed,    actions were credited in removal of power to component) and         topic, rather than                    NRC agreed this issue closed 6/28/12.      developing the pinch point recovery actions.                          trying to revise FAQ                                                             tables."
40.
9    B-2 Table (ML113210461-Slide 19) - The    The TF will review   11/18/11 Meeting No change to LAR Template (Rev. 1L)        FNP LAR Attachment 2 -
concern was that B-2 table statements      and see if           ML113210461                                                 Table B-2 (when should reference how the post-transition   additional guidance  ML113340218      Task Force to monitor to see if additional completed) will be program meets the guidance, and not        is needed in LAR                      guidance is warranted.                     reviewed to ensure no reference Appendix R or superseded         template (Section                                                                reference to Appendix R is documents.                                 4.2.1, Aft. B).                                                                  made.
3

Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue                     Actions /              Ref.                     Status/Comment                       FNP Disposition Disposition 10   NEI 00-01 Rev. 2 (ML113210461-Slide           The NRC would like    11/18/11 Meeting Added additional discussion and "Note to      FNP LAR Section 4.2.1.1
: 20) - Although FAQ 39 endorsed Rev. 1         a gap analysis of     ML113210461       LAR Developer" to LAR Template (Rev.         includes discussion on the of NEI 00-01 Chapter 3 in the B-2 table,      Rev. 2 vs. Rev. 1 of  ML113340218       1L) Section 4.2.1.1.                         additional review the NRC referenced Rev. 2 of NEI 00-01        NEI 00-01 and a                                                                      performed to NEI 00-01 in RG 1.205 Rev. 1. The NRC would like        discussion of the                      Task Force developed a list of the            Revision 2.
a gap analysis of Rev. 2 vs. Rev. 1 of NEI    gap analysis and                       'substantive change topics' 00-01 and a discussion of the gap             results in the LAR analysis and results in the LAR submittal. submittal (Section                     Task Force considers this issue closed.
4.2.1, Att. B)..                       NRC agreed this issue closed 6/28/12.
11   Safe and Stable (ML113210461-Slide 21)       Guidance on this      11/18/11 Meeting No change to LAR Template (Rev. 1 L)          FNP LAR Section 4.2.1.2
     - The NRC would like a justification          topic is already      ML113210461                                                    does not include a defined (qualitative risk analysis) if a defined time available in FAQ 54   ML113340218      Additional reviews indicate that the NRC      time period.
period is specified.                          and in the LAR                         may desire a qualitative risk analysis even template. (Section                     if a defined time period is not specified. FNP does not include a 4.2.1.2)                                                                             statement on qualitative NEI will clarify in template that qualitative risk analysis. It is not clear risk analysis should be provided whether      exactly what the NRC or not a defined time period is provided in   expectations are. FNP is safe and stable definition,                   consistent with other recent submittals. This item is not deemed to be a LIC 109 risk, but has potential for an RAI.
12   Complies with Clarification                   It was believed that  11/18/11 Meeting No change made to LAR Template (Rev.          FNP LAR Attachment A (ML113210461-Slide 22) - This concern        sufficient guidance   ML113210461      1 L).                                         uses the 'Complies with was referencing an incorrect compliance       exists on this topic. ML113340218                                                    Clarification" compliance statement.                                                                           Task Force to monitor to see if additional    statement twice. Each guidance is warranted.                        case is used appropriately.
13   Redaction of Security Related Information     NEI-NRC to work       11/18/11 Meeting Not characterized as "Generic RAI" at         LAR redaction will be done (ML113210461 -Slide 27)                      on approach           ML113210461      11/18/11 meeting. No change made to           by FNP licensing at their ML113340218      LAR Template (Rev. 1 L).                      discretion.
Discussed 6/27 - 6/28/12. NEI to revise template to remove redactions of entire statement and reference guidance from NRC (with decision on specifics ultimately left to individual plant processes).
4

Generic RAIs - Southern FNP Comparison No.            Topic-Generic Issue                   Actions /            Ref.                   Status/Comment                       FNP Disposition Disposition 14   Treatment of FPRA Unreviewed Analysis      Industry needs      11/18/11 Meeting Not characterized as "Generic RAI" at      FNP Fire PRA has not Methods (UAMs) (ML113210461 -Slide         clear understanding ML113210461      11/18/11 meeting.                          used any UAM; however, 61).                                       of how UAMs are     ML113340218                                                 SNC has used methods treated and closed                   No change made to LAR Template (Rev.       which are not explicitly out.                                 1 L).                                      defined in NUREG/CR-6850. These methods are Additional discussion with the NRC is      discussed in item 27.
needed to determine closure method.
15   NRC now asking for 10 CFR                                      Two utilities    New item discussed at 3/22/12 TF           The FNP LAR did not 50.48(c)(2)(vii) submittal for use of EPRI                                      meeting.                                   address this generic RAI process for surveillance optimization                                                                                      topic. This specific topic is uses. (two utilities)                                                           Need additional discussion with staff to   still developing and under determine path for closure. Industry       discussion with the NRC.
working on generic response to this topic. Both pilot plants did not use this approach and received SE's. This item is not deemed to be a LIC 109 risk, but has the high potential for an RAI 5

Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue                 Actions /             Ref.                  Status/Comment                   FNP Disposition Disposition 16   FPRA - Sensitivity study on CPT factor 2.                                     New item discussed at 3/22/12 TF         FNP Fire PRA does a RAI's for several meeting.                                 sensitivity analysis on all It was recently stated at the industry fire                 utilities and                                              hot short probabilities by forum that the Phenomena Identification                     "generic"         Need additional discussion with staff to multiplying them by a factor and Ranking Table Panel being                                RAIs (#9)        determine path for closure,              of 2. The results from this conducted for the circuit failure tests from                                                                           sensitivity study are the DESIREEFIRE and CAROL-FIRE                                                6/28/12 - Additional discussion needed   discussed in Att V of LAR.
tests may be eliminating the credit for                                       on how to treat this Fire PRA topic (not Control Power Transformers (CPTs)                                             necessarily as a LAR template item). NEI (about a factor 2 reduction) currently                                        to work on how to treat Fire PRA topics allowed by Tables 10-1 and 10-3 of                                            likely to get extensive reviews/RAIs.
NUREG/CR-6850, Vol. 2, as being invalid when estimating circuit failure probabilities. Provide a sensitivity analysis that removes this CPT credit from the PRA and provide new results that show the impact of this potential change on CDF, LERF, ACDF, and ALERF. If the sensitivity analysis indicates that the change in risk acceptance guidelines would be exceeded after eliminating CPT credit, please justify not meeting the guidelines.
17   Please describe how your evaluation                          "generic"        This is addressed by SRs within the PRA  The increase in total heat includes the possible increase in heart                     RAIs (#1)         Standard.                                release rate due to (sic) release rate caused by the spread of                                                                             intervening combustibles is a fire from the ignition source to other                                      6/28/12 -Additional discussion needed    considered in the Farley combustibles. Please summarize how                                            on how to treat this Fire PRA topic (not Fire PRA.
suppression is included in your                                               necessarily as a LAR template item). NEI evaluation.                                                                   to work on how to treat Fire PRA topics likely to get extensive reviews/RAIs.
6

Generic RAIs - Southern FNP Comparison No.              Topic-Generic Issue                Actions /           Ref.               Status/Comment                   FNP Disposition Disposition 18  Transient fires should at a minimum be                       "generic"   This is addressed by SRs within the PRA  A transient fire is placed in locations within the plant PAUs                   RAIs (#2)    Standard.                                postulated in any location where CCDPs are highest for that PAU,                                                                             that it is plausible.
i.e., at "pinch points." Pinch points include                            6/28/12 - Additional discussion needed   Plausible in this context, locations of redundant trains or the vicinity                            on how to treat this Fire PRA topic (not based on plant specific of other potentially risk-relevant                                       necessarily as a LAR template item). NEI physical features.
equipment, including the cabling                                         to work on how to treat Fire PRA topics associated with each. Transient fires                                    likely to get extensive reviews/RAIs. FNP scenario report should be placed at all appropriate                                                                               describes the transient locations in a PAU where they can                                                                                 scenario identification threaten pinch points. Hot work should be                                                                         process.
assumed to occur in locations where hot work is a possibility, even if improbable (but not impossible), keeping in mind the same philosophy.
19  Discuss the calculation of the frequencies                   "generic"   This is addressed by SRs within the PRA  A discussion is provided in of transient and hot work fires.                            RAIs (#3, 4) Standard.                                the Farley Plant Characterize your use of the influence                                                                            Partitioning and Ignition factors for maintenance, occupancy, and                                  6/28/12 - Additional discussion needed   Frequency Development storage, noting if the rating "3" is the most                            on how to treat this Fire PRA topic (not report includes a common, as it is intended to be                                          necessarily as a LAR template item). NEI discussion for influence representative of the "typical" weight for                               to work on how to treat Fire PRA topics  factors used other than "3".
each influence factor.                                                   likely to get extensive reviews/RAIs.
The assignments are FAQ 12-64 addresses this topic.          based on insights from a plant review panel.
7

Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue                 Actions /          Ref.                 Status/Comment                   FNP Disposition Disposition 20   Section 10 of NUREG/CR-6850                                  "generic"   This is addressed by SRs within the PRA   This sensitivity study is Supplement 1 states that a sensitivity                       RAIs (#7)   Standard.                                 presented in Att V of the analysis should be performed when using                                                                            LAR. Because SNC plans the fire ignition frequencies in the                                      6/28/12 - Additional discussion needed   to reestablish baseline and Supplement instead of the fire ignition                                   on how to treat this Fire PRA topic (not delta risk estimates by frequencies provided in Table 6-1 of                                      necessarily as a LAR template item). NEI replacing 2012 industry NUREG/CR-6850. Provide the sensitivity                                   to work on how to treat Fire PRA topics   consensus electrical analysis of the impact on using the                                       likely to get extensive reviews/RAIs. cabinet model with Supplement 1 frequencies instead of the                                                                            NURG/CR-6950 model, no Table 6-1 frequencies on CDF, LERF,                                                                                additional work is ACDF, and ALERF for all of those bins                                                                              performed to justify the that are characterized by an alpha that is                                                                         results of the sensitivity less than or equal to one. If the sensitivity                                                                      study. Rather, the ignition analysis indicates that the change in risk                                                                         frequency study will be acceptance guidelines would be                                                                                     revised concurrently with exceeded using the values in Table 6-1,                                                                            changes in baseline and please justify not meeting the guidelines,                                                                         delta risk estimates.
21   Please describe how CDF and LERF are                        "generic"    This is addressed by SRs within the PRA   Scenarios have been estimated in main control room (MCR)                        RAIs (#8)    Standard.                                 defined that cause MCR abandonment scenarios. Do any fires                                                                                Abandonment. A range of outside of the MCR cause MCR                                             6/28/12 - Additional discussion needed    screening values are used.
abandonment because of loss of control                                   on how to treat this Fire PRA topic (not and/or loss of control room habitability?                                necessarily as a LAR template item). NEI  The FRE report and the Are "screening" values for post MCR                                      to work on how to treat Fire PRA topics   FNP Scenario report abandonment used (e.g., conditional core                                 likely to get extensive reviews/RAIs. include additional damage probability of failure to                                                                                   information for MCR successfully switch control to the Primary                                                                         scenarios.
Control Station and achieve safe 3 shutdown of 0.1) or have detailed human error analyses been completed for this activity. Please justify any screening value used.
8

Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue              Actions /           Ref.               Status/Comment                      FNP Disposition Disposition 22   Attachment W of the LAR provides the                      "generic"   This is a candidate for revision to LAR    The methodology used for
     ..CDF and ..LERF for the variances from                   RAIs (#10)  template.                                  performing fire risk the deterministic requirements (VFDRs)                                                                           evaluations is discussed in for each of the fire areas, but the LAR                               Added section to Attachment W.             Att W of the LAR.
does not describe either generically or specifically how ..CDF and ..LERF were                                6/28/12 - Additional discussion needed     All of the methods utilized calculated. Describe the method(s) used                               on how to treat this Fire PRA topic (not   in the development of FNP to determine the changes in risk reported                             necessarily as a LAR template item). NEI   Fire PRA have been peer in the Tables in Appendix W. The                                      to work on how to treat Fire PRA topics    reviewed.
description should include:                                           likely to get extensive reviews/RAIs. NEI to look at existing guidance.              No new operator actions a) A summary of PRA model additions or                                                                           are credited in the change modifications needed to determine the                                                                            in risk estimates.
reported changes in risk. If any of these model additions used data or methods not included in the fire PRA Peer Review please describe the additions.
b) Identification of new operator actions (not including post MCR abandonment which are addressed elsewhere) that have been credited in the change in risk estimates. If such actions are credited, how is instrument failure addressed in the HRA.
23   Did the peer reviews for both the internal                "generic"   Added the following note to LAR            Both the FNP Fire and events and fire PRAs consider the                        RAIs (#11)   Developer in Attachment U:                 Internal Events PRAs have clarifications and qualifications from                                                                           undergone a RG 1.200, Regulatory Guide (RG) 1.200, Revision 2,                              Provide a general discussion of the        Revision 2, Peer Review.
     "An Approach for Determining the                                      standards against which the Internal Technical Adequacy of Probabilistic Risk                              Events PRA has been reviewed. Ensure Assessment Results for Risk- Informed                                 that RG 1.200 Revision 2 has been Activities," March 2009 (ADAMS                                        considered.
Accession No. ML090410014) to the ASME/AMS PRA Standard? If not,                                        6/28/12 - NRC questioned RG 1.200 Rev.
provide a self-assessment of the PRA                                  2 for fire and asked to ensure guidance in model for the RG 1.200 clarifications and                             LAR template addressed fire.
qualifications and indicate how any identified gaps were dispositioned.
9

Generic RAIs - Southern FNP Comparison No.              Topic-Generic Issue              Actions /           Ref.              Status/Comment                       FNP Disposition Disposition 24   Identify if any variance from deterministic                "generic"   See item 22                                 Not applicable. FNP does requirement (VFDRs) in the LAR involved                   RAIs (#12)                                               not have VFDRs related to performance-based evaluations of                                                                                   embedded or wrapped wrapped or embedded cables. If                                                                                     cables.
applicable, describe how wrapped or embedded cables were modeled in the Fire PRA including assumptions and insights on how the PRA modeling of these cables contributes to the VFDR delta risk evaluations.
25   Identify any plant modification                            "generc"    Added a note to LAR developer in            An implementation item is (implementation item) in Attachment S of                  RAIs (#13)   Attachment S.                               identified in Table S-3 of the LAR that have not been completed                                                                               the LAR. This but which have been credited directly or                               The task force considers this issue closed, implementation item will indirectly in the change-in-risk estimates                             Task Force considers this issue closed,     adjust the FNP Fire PRA to provided in Attachment W. When the                                     NRC to review LAR template discussion.      reflect the as built plants affects of a plant modification has been                                                                           after modifications have included in the PRA before the                                                                                     been implemented.
modification has been completed, the models and values used in the PRA are                                                                              Should the condition arise necessarily estimates based on current                                                                             such that the as-built plans. The as-built facility after the                                                                             change-in-risk exceed modification is completed may be different                                                                         estimates reported in the than the plans. Please add an                                                                                      LAR, Corrective action implementation item that, upon                                                                                     would take place.
completion of all PRA credited implementation items, verifies the validity of the reported change-in-risk. This item should include your plan of action should the as-built change-in-risk exceed the estimates reported in the LAR.
10

Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue               Actions /          Ref.               Status/Comment                   FNP Disposition Disposition 26   Please identify any changes made to the                    "generic"   This is a candidate for revision to LAR There have been no internal events or fire PRA since the last                RAIs (#14)   template.                               changes to the internal full scope peer review of each of these                                                                        events or Fire PRA model PRA models that are consistent with the                                6/28/12 - NEI to review for possible    that would be considered a definition of a "PRA upgrade" in                                       updates to LAR template.                "PRA upgrade" since the ASME/ANS-RA-Sa-2009, as endorsed by                                                                            last full scope Peer Regulatory Guide 1.200. Also, please                                                                           Review.
address the following:
i)        If any changes are characterized as a PRA upgrade, please identify if a focused scope peer review was performed for these changes consistent with the guidance in ASME/ANS-RA-Sa-2009, as endorsed by Regulatory Guide 1.200, and describe any findings from that focused-scope peer review and the resolution of these findings for this application.
ii)       ii) If a focused-scope peer review has not been performed for changes characterized as a PRA upgrade, please describe what actions will be implemented to address this review deficiency.
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Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue             Actions /              Ref.                     Status/Comment                    FNP Disposition Disposition 27   During the 5/24/12 public meeting the The staff has                           This is addressed by SRs within the PRA    FNP Fire PRA has used NRC asked that the licensee identify  noticed that this                       Standard.                                 one alternate analysis deviations from NUREG/CR 6850         has been treated                                                                   method (Panel Severity methods including those that involve  inconsistently in the                   Need additional discussion with staff to   Factor) to NUREG/CR-justifications.                       submittals.                             determine path for closure (i.e., the     6850 which is discussed in correct amount of information to be       the FNP LAR Attachment included in the LAR versus supporting     V. This discussion documentation.                            includes the results from a sensitivity study. Although the sensitivity study yields results estimated delta CDF/LERF values around the acceptance criteria defined in RG 1.174, SNC intends to follow direction from the NRC staff to replace the 2012 industry consensus electrical cabinet model with the model prescribed by NUREG/CR-6850.
28   Clarification between IEEE-383 Flame                        6/27/12 Public    This is not necessarily a LAR template    The FNP Scenario report Spread Rating and damage threshold                          Meeting (Slide 8) item, but a topic that should be          discusses the types of understood by licensees in preparation of cables installed in the plant the LAR.                                  and their damage threshold. This is discussed in terms of the damage threshold of thermoplastic and thermoset cables.
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Generic RAIs - Southern FNP Comparison No.             Topic-Generic Issue                 Actions /           Ref.                   Status/Comment                      FNP Disposition Disposition 29   NFPA 805 Quality Section 2.7.3 - NRC                        6/27/12 Public    Candidate for LAR template revision.      FNP LAR Section 4.7.3 is concerns about future commitment to                         Meeting (Slide 9)                                           consistent with the Generic meet 2.7.3 (specific concerns over post                                                                                 Template and other LAR transition qualifications)                                                                                              submittal with respect to the discussion of Quality requirements.
This item is new and not officially on the NRC Generic RAI list at this time. No action taken to change LAR approach as NRC expectations are not entirely clear at this point.
This item is still developing, therefore an RAI may be expected.
30   Clarification needed on risk and delta risk                 6/27/12 Public    Need additional discussion with NRC on    Modifications were criteria related to credit for modifications,               Meeting PRA       this topic. Candidate for LAR template    included in the analysis to additional risk of recovery actions                         Slides (Slide 5)  revision after clarification obtained and decrease the cumulative agreed upon.                              total risk and the total delta risk to ensure that the acceptance criteria defined by RG 1.174 is met. The additional risk of recovery actions are included in Aft W.
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