ML13281A010

Second Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805

ML13281A010
Person / Time
Site:	Nine Mile Point
Issue date:	10/09/2013
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Costanzo C Nine Mile Point
Vaidya B K, NRR/DORL/LPL1-1, 415-3308
References
TAC ME8899
Download: ML13281A010 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 October 9, 2013

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 -SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR ADOPTION OF NFPA 805 (TAC NO. ME8899)

Dear Mr. Costanzo:

By letter dated June 11, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12170A868), Nine Mile Point Nuclear Station, Unit 1 (NMP1) submitted a license amendment request (LAR) for adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) 50.48(a) and 10 CFR 50.48(c);

the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, and National Fire Protection Association 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. This LAR also follows the guidance in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2. By letters dated February 27, 2013, March 27, 2013, and April 30, 2013 (ADAMS Accession Nos. ML 13064A466, ML 13092A139, and ML 131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML 12361A050).

The NRC staff has reviewed the information provided by NMP1 in the above mentioned letters and has determined that additional information is needed to complete its review. Enclosed is the NRC staff's second round of request for additional information (RAI). Clarification conference calls were held between the NRC staff and the licensee on October 7, 8, and 9, 2013, and it was agreed that the response times for the RAis would be as follows: (a) ForRAI, Fire Protection Engineering RAI-11: December9, 2013 (b) For RAI, Safe Shutdown (SSD) RAI 08.01, January 22, 2014, Please note that review efforts on this task are being continued and additional RAis may be forthcoming.

C. Costanzo Please contact me at (301) 415-3308, if you have any questions.

Docket No. 50-220

Enclosure:

As stated cc w/encl: Distribution via Listserv Sincerely, J g ............-;.

,. Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS NINE MILE POINT NUCLEAR STATION. UNIT 1 DOCKET NUMBER 50-220 (TAC NO. ME8889) Fire Protection Engineering RAI 11 The compliance statement for License Amendment Request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12170A869)

Table B-1, Element 3.4.1(c), "On-Site Fire-Fighting Capability" is "Complies".

The associated compliance bases states "This training program also ensures that the Brigade leader and at least two members have sufficient training and knowledge of plant safety-related systems to understand the effects of fire and fire suppression on safe shutdown capability." Describe how the requirements of National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, Section 3.4.1 (c), are met, namely "the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria".

An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, "Fire Protection for Operating Nuclear Power Plants," Revision 2, (ADAMS Accession No. ML092580550)

Section 1.6.4.1, Qualifications: "The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability.

The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel.

Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems." Enclosure Safe Shutdown (SSD) RAI 08.01 In a letter dated February 27, 2013 (ADAMS Accession No. ML 13064A466), the licensee responded to SSD RAI 08 and stated that the risk of loss of power of safe shutdown loads as a result of a lack of electrical coordination was low. NFPA 805 Section 2.4.2.2.2, Other Required Circuits, Subpart (a) Common Power Supply requires that: "Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified.

This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device." Based on the licensee's response to SSD RAI 8 the staff noted that there may be situations where load circuit breakers (motor control center (MCC) 161A feeder breaker, MCC 176 feeder breaker, MCC 167 feeder breaker, MCC 171A feeder breaker, and MCC 1671 feeder breaker) are not electrically coordinated with the associated cross tie circuit breakers (R1 042 or R1 052). Two case studies were performed.

The licensee stated that the first case study "SA" used a conservative approach and all uncoordinated breaker impacts from the Breaker Coordination Study were used in the Fire PRA model. In the second case study "8B", the tie breakers were modeled as coordinated and the remaining uncoordinated breakers were left uncoordinated.

The case studies were used to determine the increase in risk due to the lack of electrical coordination between the load breakers and the tie breakers.

The licensee stated that, the results of the sensitivity analysis show that the remaining uncoordinated breakers are low risk. The failure to provide electrical coordination between the emergency supply circuit breaker and the cross tie circuit breaker does not meet the requirements for common power supply, requiring this condition to be considered a Variance from Deterministic Requirement.

Provide the risk increase as a result of failure to coordinate these circuit breakers and report the revised value of the delta risk for each fire area (and to the total fire delta risk) where fire-induced damage could cause the loss of the common power supply.

C. Costanzo Please contact me at (301) 415-3308, if you have any questions.

Docket No. 50-220

Enclosure:

RAI Sincerely, Ira/ Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNRRLAKGoldstein

RidsNrrDirsltsb Rl RidsNrrDraApla RidsNrrDraAhpb C. Candace, NRR/AHPB S. Wall, NRR/DORL/LPL3-1 LPL 1-1 RIF RidsNrrDoriDpr RidsAcrsAcnw_MaiiCTR RidsN rrDraAfpb L. Fields, NRR/AFPB J. Robinson, NRR/AFPB RidsDoriLpl1-1 RidsNRRPMNineMilePoint RidsRgn1 MaiiCenter DSchroeder, RidsNrrDssStsb J. Hyslop, NRR/APLA H. Khadijah, NRR/STSB ADAMS Accession Number.: ML 13281A010

• For AFPB NRR!DRA/AFPB/BC OFFICE LPL 1-1/PM LPL 1-1/LA 'Lead Reviewer)(2 LPLI-1/BC LPLI-1/PM NAME BVaidya KGoldstein AKiein/JRobinson RBeall BVaidya DATE 10/09/13 10/08/13 10/09/13 10/09/13 10/09/13 OFFICIAL RECORD COPY