ML13347B049: Difference between revisions

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| issue date = 12/19/2013
| issue date = 12/19/2013
| title = (VCSNS) - Request for Additional Information
| title = (VCSNS) - Request for Additional Information
| author name = Williams S A
| author name = Williams S
| author affiliation = NRC/NRR/DORL/LPLII-1
| author affiliation = NRC/NRR/DORL/LPLII-1
| addressee name = Gatlin T D
| addressee name = Gatlin T
| addressee affiliation = South Carolina Electric & Gas Co
| addressee affiliation = South Carolina Electric & Gas Co
| docket = 05000395
| docket = 05000395
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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065 December 19, 2013
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 19, 2013 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065


==SUBJECT:==
==SUBJECT:==
VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO.1 (VCSNS)-REQUEST FOR ADDITIONAL INFORMATION (TAC NO. ME7586)  
VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO.1 (VCSNS)- REQUEST FOR ADDITIONAL INFORMATION (TAC NO. ME7586)


==Dear Mr. Gatlin:==
==Dear Mr. Gatlin:==
By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805). The staff has determined that additional information is needed to continue the review as discussed in the Enclosure.
 
We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.
By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805).
Docket No. 50-395  
The staff has determined that additional information is needed to continue the review as discussed in the Enclosure. We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.
Sincerely, Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395


==Enclosure:==
==Enclosure:==
Request for Additional Information cc w/encl: Distribution via Listserv


Request for Additional Information cc w/encl: Distribution via Listserv Sincerely, Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT PERFORMANCE-BASED NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FOR FIRE PROTECTION FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395 Safe Shutdown Analysis (SSA) Request for Additional Information (RAJ) 21 License Amendment Request (LAR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 1321A172)
REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT PERFORMANCE-BASED NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FOR FIRE PROTECTION FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395 Safe Shutdown Analysis (SSA) Request for Additional Information (RAJ) 21 License Amendment Request (LAR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 1321A172) Attachment X, "Other Request for Approval" requests approval of thermoset cables in cable trays as an acceptable configuration meeting National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, (NFPA 805), Section 4.2.3.3(b) requirements for "no intervening combustible materials or fire hazards." Results of various fire testing programs (Nuclear Energy Institute/Electrical Power Research Institute (NEI/EPRI),
Attachment X, "Other Request for Approval" requests approval of thermoset cables in cable trays as an acceptable configuration meeting National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, (NFPA 805), Section 4.2.3.3(b) requirements for "no intervening combustible materials or fire hazards." Results of various fire testing programs (Nuclear Energy Institute/Electrical Power Research Institute (NEI/EPRI), Cable Response to Live Fire (CAROLFIRE), Cable Heat Release, Ignition, and Spread in Tray Installations During Fire (CHRISTI-FIRE), Direct Current Electrical Shorting in Response to Exposure Fire (DESIREE-FIRE), etc.) determined that thermoset cables are combustible.
Cable Response to Live Fire (CAROLFIRE), Cable Heat Release, Ignition, and Spread in Tray Installations During Fire (CHRISTI-FIRE), Direct Current Electrical Shorting in Response to Exposure Fire (DESIREE-FIRE), etc.) determined that thermoset cables are combustible. The NRC staff determined that this approval request is more suited to evaluation using risk-informed, performance-based methods.
The NRC staff determined that this approval request is more suited to evaluation using informed, performance-based methods. LAR Attachment X does not state whether the request applies to fire areas that credit deterministic compliance in accordance with NFPA 805 Section 4.2.3, or performance-based compliance in accordance with the fire modeling requirements of NFPA 805 Section 4.2.4.1, or performance-based compliance in accordance with the fire risk evaluation requirements of NFPA 805 Section 4.2.4.2. Provide the following:
LAR Attachment X does not state whether the request applies to fire areas that credit deterministic compliance in accordance with NFPA 805 Section 4.2.3, or performance-based compliance in accordance with the fire modeling requirements of NFPA 805 Section 4.2.4.1, or performance-based compliance in accordance with the fire risk evaluation requirements of NFPA 805 Section 4.2.4.2.
: a. For each fire area where the LAR Attachment X approval request applies: i. Identify the compliance strategy used to comply with NFPA 805 (Section 4.2.3, 4.2.4.1, or 4.2.4.2).
Provide the following:
ii. Provide a description of the physical configuration, explaining the nature and arrangement of the 20-foot separation zone, the extent of cable trays that intervene in the zone, and the potential plant impacts that could result if the zone is compromised (ie. what safe shutdown impacts would result with significant fire propagation across the zone). b. For each pair of redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met, the NRC staff determined that these should have been considered variances from deterministic requirements (VFDRs). The NRC staff also noted that if the risk is as low as stated in   the LAR based on qualitative analysis, these VFDRs should have been included in the fire area delta risk calculations analyzed using approved performance-based methods and submitted for NRC staff approval.
: a. For each fire area where the LAR Attachment X approval request applies:
Process each of the redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met as a VFDR and include on a fire area basis the delta risk calculations and plant total risk numbers in accordance with NFPA 805 Section 4.2.4.2.
: i. Identify the compliance strategy used to comply with NFPA 805 (Section 4.2.3, 4.2.4.1, or 4.2.4.2).
December 19, 2013 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065  
ii. Provide a description of the physical configuration, explaining the nature and arrangement of the 20-foot separation zone, the extent of cable trays that intervene in the zone, and the potential plant impacts that could result if the zone is compromised (ie. what safe shutdown impacts would result with significant fire propagation across the zone).
: b. For each pair of redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met, the NRC staff determined that these should have been considered variances from deterministic requirements (VFDRs). The NRC staff also noted that if the risk is as low as stated in
 
the LAR based on qualitative analysis, these VFDRs should have been included in the fire area delta risk calculations analyzed using approved performance-based methods and submitted for NRC staff approval. Process each of the redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met as a VFDR and include on a fire area basis the delta risk calculations and plant total risk numbers in accordance with NFPA 805 Section 4.2.4.2.
 
December 19, 2013 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065


==SUBJECT:==
==SUBJECT:==
VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 (VCSNS)-REQUEST FOR ADDITIONAL INFORMATION REGARDING THE NFPA-805 LICENSE AMENDMENT REVIEW (TAC NO. ME7586)  
VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 (VCSNS)- REQUEST FOR ADDITIONAL INFORMATION REGARDING THE NFPA-805 LICENSE AMENDMENT REVIEW (TAC NO. ME7586)


==Dear Mr. Gatlin:==
==Dear Mr. Gatlin:==
By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805). The staff has determined that additional information is needed to continue the review as discussed in the Enclosure.
 
We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.
By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805).
Docket No. 50-395 Sincerely, IRA/ Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation  
The staff has determined that additional information is needed to continue the review as discussed in the Enclosure. We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.
Sincerely, IRA/
Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395


==Enclosure:==
==Enclosure:==
 
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC                             LPL2-1  RJF                        RidsAcrsAcnw_MaiiCTR Resource RidsNrrDoriDpr Resource            RidsNrrDoriLpl2-1 Resource          RidsRgn2MaiiCenter Resource RidsNrrLASFigueroa Resource        RidsNrrDe Resource                  RidsNrrPMSummer Resource AKiein, NRR                        JRobinson, NRR ADAMS Access1on. No.: ML13347B049                                        *B'jyema1 OFFICE             LPL2-1/PM         LPL2-1/LA            NRR/AFPB            LPL2-1/BC        LPL2-1/PM NAME                SWilliams        SFigueroa           JRobinson*           RPascarelli        SWilliams DATE                12/18/13           12/18/13             12/12/13            12/18/13           12/19/13 OFFICIAL RECORD COPY}}
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDoriDpr Resource RidsNrrLASFigueroa Resource AKiein, NRR ADAMS . N ML 13347B049 Access1on o.: OFFICE LPL2-1/PM NAME SWilliams DATE 12/18/13 LPL2-1 RJF RidsNrrDoriLpl2-1 Resource RidsNrrDe Resource JRobinson, NRR LPL2-1/LA NRR/AFPB SFigueroa JRobinson*
12/18/13 12/12/13 OFFICIAL RECORD COPY RidsAcrsAcnw_MaiiCTR Resource RidsRgn2MaiiCenter Resource RidsNrrPMSummer Resource *B 'jyema1 LPL2-1/BC LPL2-1/PM RPascarelli SWilliams 12/18/13 12/19/13}}

Latest revision as of 11:28, 4 November 2019

(VCSNS) - Request for Additional Information
ML13347B049
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 12/19/2013
From: Shawn Williams
Plant Licensing Branch II
To: Gatlin T
South Carolina Electric & Gas Co
Williams, Shawn NRR/DORL 415-1009
References
TAC ME7586
Download: ML13347B049 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 19, 2013 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO.1 (VCSNS)- REQUEST FOR ADDITIONAL INFORMATION (TAC NO. ME7586)

Dear Mr. Gatlin:

By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805).

The staff has determined that additional information is needed to continue the review as discussed in the Enclosure. We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.

Sincerely, Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT PERFORMANCE-BASED NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FOR FIRE PROTECTION FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395 Safe Shutdown Analysis (SSA) Request for Additional Information (RAJ) 21 License Amendment Request (LAR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 1321A172) Attachment X, "Other Request for Approval" requests approval of thermoset cables in cable trays as an acceptable configuration meeting National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition, (NFPA 805), Section 4.2.3.3(b) requirements for "no intervening combustible materials or fire hazards." Results of various fire testing programs (Nuclear Energy Institute/Electrical Power Research Institute (NEI/EPRI),

Cable Response to Live Fire (CAROLFIRE), Cable Heat Release, Ignition, and Spread in Tray Installations During Fire (CHRISTI-FIRE), Direct Current Electrical Shorting in Response to Exposure Fire (DESIREE-FIRE), etc.) determined that thermoset cables are combustible. The NRC staff determined that this approval request is more suited to evaluation using risk-informed, performance-based methods.

LAR Attachment X does not state whether the request applies to fire areas that credit deterministic compliance in accordance with NFPA 805 Section 4.2.3, or performance-based compliance in accordance with the fire modeling requirements of NFPA 805 Section 4.2.4.1, or performance-based compliance in accordance with the fire risk evaluation requirements of NFPA 805 Section 4.2.4.2.

Provide the following:

a. For each fire area where the LAR Attachment X approval request applies:
i. Identify the compliance strategy used to comply with NFPA 805 (Section 4.2.3, 4.2.4.1, or 4.2.4.2).

ii. Provide a description of the physical configuration, explaining the nature and arrangement of the 20-foot separation zone, the extent of cable trays that intervene in the zone, and the potential plant impacts that could result if the zone is compromised (ie. what safe shutdown impacts would result with significant fire propagation across the zone).

b. For each pair of redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met, the NRC staff determined that these should have been considered variances from deterministic requirements (VFDRs). The NRC staff also noted that if the risk is as low as stated in

the LAR based on qualitative analysis, these VFDRs should have been included in the fire area delta risk calculations analyzed using approved performance-based methods and submitted for NRC staff approval. Process each of the redundant components that share a 20-foot separation zone where the intervening combustible/fire hazard requirement cannot be met as a VFDR and include on a fire area basis the delta risk calculations and plant total risk numbers in accordance with NFPA 805 Section 4.2.4.2.

December 19, 2013 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 (VCSNS)- REQUEST FOR ADDITIONAL INFORMATION REGARDING THE NFPA-805 LICENSE AMENDMENT REVIEW (TAC NO. ME7586)

Dear Mr. Gatlin:

By letters dated November 15, 2011, January 26 and October 10, 2012, the South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a license amendment request (LAR) to revise Facility Operating License Number NPF-12 for the Virgil C. Summer Nuclear Station, Unit No. 1. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805).

The staff has determined that additional information is needed to continue the review as discussed in the Enclosure. We request that SCE&G respond to these RAis by February 25, 2014. Please note that the staff's review is continuing and further RAis may be developed.

Sincerely, IRA/

Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC LPL2-1 RJF RidsAcrsAcnw_MaiiCTR Resource RidsNrrDoriDpr Resource RidsNrrDoriLpl2-1 Resource RidsRgn2MaiiCenter Resource RidsNrrLASFigueroa Resource RidsNrrDe Resource RidsNrrPMSummer Resource AKiein, NRR JRobinson, NRR ADAMS Access1on. No.: ML13347B049 *B'jyema1 OFFICE LPL2-1/PM LPL2-1/LA NRR/AFPB LPL2-1/BC LPL2-1/PM NAME SWilliams SFigueroa JRobinson* RPascarelli SWilliams DATE 12/18/13 12/18/13 12/12/13 12/18/13 12/19/13 OFFICIAL RECORD COPY