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| | number = ML13281A010 | | | number = ML13281A010 |
| | issue date = 10/09/2013 | | | issue date = 10/09/2013 |
| | title = 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) | | | title = Second Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805 |
| | author name = Vaidya B K | | | author name = Vaidya B |
| | author affiliation = NRC/NRR/DORL/LPLI-1 | | | author affiliation = NRC/NRR/DORL/LPLI-1 |
| | addressee name = Costanzo C | | | addressee name = Costanzo C |
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| | docket = 05000220 | | | docket = 05000220 |
| | license number = | | | license number = |
| | contact person = Vaidya B K, NRR/DORL/LPL1-1, 415-3308 | | | contact person = Vaidya B, NRR/DORL/LPL1-1, 415-3308 |
| | case reference number = TAC ME8899 | | | case reference number = TAC ME8899 |
| | document type = Letter, Request for Additional Information (RAI) | | | document type = Letter, Request for Additional Information (RAI) |
| | page count = 5 | | | page count = 5 |
| | | project = TAC:ME8899 |
| | | stage = RAI |
| }} | | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2013 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 |
| | |
| | ==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. ML12170A868), 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. ML13064A466, ML13092A139, and ML131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML12361A050). |
| | 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. |
| | Sincerely, |
| | ~--~- g J "- |
| | Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220 |
| | |
| | ==Enclosure:== |
| | |
| | As stated cc w/encl: Distribution via Listserv |
| | |
| | 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. ML12170A869) 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. ML13064A466), 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. |
| | Sincerely, Ira/ |
| | Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220 |
| | |
| | ==Enclosure:== |
| | |
| | RAI cc w/encl: Distribution via Listserv DISTRIBUTION: |
| | PUBLIC LPL 1-1 RIF RidsNRRPMNineMilePoint RidsNRRLAKGoldstein RidsNrrDoriDpr RidsRgn1 MaiiCenter RidsNrrDirsltsb RidsAcrsAcnw_MaiiCTR DSchroeder, Rl RidsNrrDraApla RidsN rrDraAfpb RidsNrrDssStsb RidsNrrDraAhpb L. Fields, NRR/AFPB J. Hyslop, NRR/APLA C. Candace, NRR/AHPB J. Robinson, NRR/AFPB H. Khadijah, NRR/STSB S. Wall, NRR/DORL/LPL3-1 RidsDoriLpl1-1 ADAMS Accession Number.: ML13281A010 *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}} |
Letter Sequence RAI |
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MONTHYEARML12170A8692012-06-30030 June 2012 Transition to 10 CFR 50.48(c) - NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Project stage: Request ML12221A0152012-08-0808 August 2012 Issuance of Amendments License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. Project stage: Approval ML12222A0292012-08-0909 August 2012 Correction to Acceptance Letter - Nine Mile Point Nuclear Station, Unit No. 1 - License Amendment Request Pursuant to 10CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generat Project stage: Acceptance Review ML12319A2632012-11-13013 November 2012 ME8899 Draft RAIs License Amendment Request to Adopt NFPA-805 Project stage: Draft RAI ML13064A4662013-02-27027 February 2013 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC RAI Project stage: Response to RAI ML13092A1392013-03-27027 March 2013 Response to NRC Request for Additional Information on License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants Project stage: Response to RAI ML13127A3952013-04-30030 April 2013 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 1 of 3 Project stage: Response to RAI ML13127A3972013-04-30030 April 2013 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 2 of 3 Project stage: Response to RAI ML13127A3982013-04-30030 April 2013 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part 3 of 3 Project stage: Response to RAI ML13282A6292013-10-0909 October 2013 ME8899, Second Round of Request for Additional Information (Rais) License Amendment Request (LAR) to Adopt NFPA-805 Project stage: RAI ML13281A0102013-10-0909 October 2013 Second Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805 Project stage: RAI ML13347B1872013-12-0909 December 2013 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to Nrc...... Project stage: Request ML14024A4162014-01-22022 January 2014 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Ed.) - Response to NRC Request for Additional.. Project stage: Request ML14030A3772014-02-12012 February 2014 Third Round of Request for Additional Information Regarding License Amendment Request for Adoption of NFPA 805 Project stage: RAI ML14085A1612014-03-14014 March 2014 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Request For.. Project stage: Request ML14087A2742014-03-28028 March 2014 ISFSI, Nine Mile Point Units 1 & 2 and R. E. Ginna - Pending NRC Actions Requested by Constellation Energy Nuclear Group, LLC Project stage: Request ML14113A1752014-04-15015 April 2014 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC RAI Project stage: Response to RAI ML14132A1992014-05-0909 May 2014 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to Nrc. Project stage: Request ML14149A3562014-05-23023 May 2014 License Amendment Request, Per 10CFR50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)-Supplemental Information Regarding Fire PRA Mode Project stage: Supplement ML14181B0862014-06-30030 June 2014 (NMP1), ME8899, Email from Licensee to Confirm the Change from Nine Mile Point Nuclear Station LLC, to Exelon Generation LAR to Adopt NFPA 805 Project stage: Other ML14126A0032014-06-30030 June 2014 Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) Project stage: Approval 2013-04-30
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Category:Letter
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Guarantees of Payment of Deferred Premiums IR 05000220/20234202023-11-0101 November 2023 Security Baseline Inspection Report 05000220/2023420 and 05000410/2023420 ML23305A0052023-11-0101 November 2023 Operator Licensing Examination Approval IR 05000220/20230032023-10-25025 October 2023 Integrated Inspection Report 05000220/2023003 and 05000410/2023003 IR 05000220/20235012023-10-17017 October 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000220/2023501 and 05000410/2023501 IR 05000220/20230112023-10-16016 October 2023 Comprehensive Engineering Team Inspection Report 05000220/2023011 and 05000410/2023011 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans NMP1L3554, Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases2023-10-0606 October 2023 Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases C IR 05000220/20233032023-09-20020 September 2023 Retake Operator Licensing Examination Report 05000220/2023303 ML23250A0822023-09-19019 September 2023 Regulatory Audit Summary Regarding LARs to Adopt TSTF-505, Rev. 2, and 10 CFR 50.69 ML23257A1732023-09-14014 September 2023 Requalification Program Inspection IR 05000220/20230052023-08-31031 August 2023 Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2023005 and 05000410/2023005) RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - 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[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23264A7992023-09-21021 September 2023 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1 ML23205A2432023-07-19019 July 2023 NRC Staff Follow-up Question on Audit Question 18 TSTF-505 and 50.69 Regulatory Audit (E-mail Dated 7/19/2023) (EPIDs L-2022-LLA-0185 and L-2022-LLA-0186) ML23087A2912023-03-28028 March 2023 Request for Additional Information (3/28/2023 E-mail) - Proposed Emergent I5R-11 Alternative Associated with a Weld Overlay on RPV Recirculation Nozzle N2E DM Weld ML23061A0522023-03-0202 March 2023 Request for Additional Information (3/2/2023 E-mail) - Proposed Alternative Associated with a Weld Overlay Repair to the Torus ML23012A2002023-01-13013 January 2023 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000220/2023401 and 05000410/2023401 ML22207A2162022-07-26026 July 2022 Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000220/2022010 and 05000410/2022010 ML22194A9412022-07-13013 July 2022 Request for Additional Information Relief Request CS-PR-02 (7/13/2022 e-mail) ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21320A3472021-11-16016 November 2021 Request for Additional Information LAR to Revise TSs to Adopt TSTF-582, Revision 0 ML21306A3312021-11-0202 November 2021 Request for Additional Information Alternative Request GV-RR-10 (11/2/2021 e-mail) ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21117A0342021-05-0505 May 2021 Request for Additional Information Regarding Proposed Alternative to Use ASME Code Case N-893 ML21125A1282021-05-0404 May 2021 OPC Document Request - Feb 2021 ML21110A5112021-04-20020 April 2021 Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt TSTF-582 ML21088A2682021-03-30030 March 2021 Notification of Conduct of a Fire Protection Team Inspection ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML20365A0092020-12-30030 December 2020 Request for Additional Information Concerning Review of License Amendment Request and Relief Request to Change Excess Flow Check Valve Testing Frequency (EPIDs L-2020-LLA-0188 and L-2020-LLR-0114) ML20358A2602020-12-28028 December 2020 Changes to Draft Request for Additional Information Regarding License Amendment Request and Relief Request to Change Excess Flow Check Valve Testing Frequency ML20272A2802020-09-28028 September 2020 Withdrawal and Replacement of Request for Additional Information to Support Review of License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times ML20248H5192020-09-28028 September 2020 Changes to Draft Request for Additional Information Regarding Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times ML20246G6362020-09-0202 September 2020 Request for Additonal Information to Support Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times NMP2L2739, Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22020-08-28028 August 2020 Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 ML20239A7982020-08-25025 August 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2 ML20212L8702020-07-30030 July 2020 Request for Additonal Information Review of License Amendment Requests Regarding Riskinformed Categorization and Treatment of Structures, Systems and Components (L-2019-LLA-0290) ML20213A9352020-07-30030 July 2020 Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times ML20153A7042020-06-0101 June 2020 NRR E-mail Capture - Preliminary RAI for Fleet Request to Use Alternative OMN-26 ML20135H1972020-05-14014 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Extend Safety Relief Valve Test Interval ML20045E3582020-02-14014 February 2020 Draft Request for Additional Information Regarding License Amendment Request to Increase Allowable MSIV Leakage Rates ML19296A1862019-10-23023 October 2019 Request for Additional Information Regarding License Amendment Request to Increase Allowable MSIV Leakage Rates (L-2019-LLA-0115) ML19275H1362019-10-0202 October 2019 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Use ASME Code Case N-879 ML19179A0612019-07-19019 July 2019 Three Mile Point 1 - Supplemental Information Needed to Proposed Alternative to Use ASME Code Case N-879 ML19151A8132019-05-31031 May 2019 Licensed Operator Positive Fitness-For-Duty Test ML19025A1572019-01-25025 January 2019 Request for Additional Information Regarding Primary Containment Oxygen Concentration License Amendment Request ML19025A1202019-01-24024 January 2019 NRR E-mail Capture - Calvert Cliffs, Fitzpatrick, and Nine Mile Point - Request for Additional Information Regarding License Amendment Request to Revise Emergency Response Organization Staffing ML18341A2212018-12-0707 December 2018 Request for Additional Information Regarding Emergency Tech Spec Change Re HPCS Completion Time (EPID -L-2018-LLA-0491) ML18228A6932018-08-15015 August 2018 Request for Additional Information Regarding Reactor Pressure Vessel Water Inventory Control License Amendment Request (L-2017-LLA-0426) ML18205A3922018-07-24024 July 2018 Request for Additional Information Regarding Reactor Pressure Vessel Water Inventory Control License Amendment Request (L-2017-LLA-0426) ML18184A2882018-07-0303 July 2018 Request for Additional Information Regarding Removal of Boraflex Credit from Spent Fuel Pool License Amendment Request(L-2018-LLA-0039) ML18102A2372018-04-12012 April 2018 NRR E-mail Capture - Calvert Cliffs, Ginna, and Nine Mile Point - Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Schemes (EPID-L-2017-LLA-0237) ML17331B1342017-12-12012 December 2017 2, and R.E. Ginna Nuclear Power Plant - Request for Additional Information - Regarding ML17285B1962017-10-27027 October 2017 Request for Additional Information Regarding Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools. ML17272A0112017-10-10010 October 2017 Request for Additional Information Regarding License Amendment Concerning Reactor Pressure Vessel Water Inventory Control ML17234A3592017-08-30030 August 2017 Request for Additional Information Regarding Relief Request NMP-RR-001 to Utilize Code Case N-702 ML17241A2752017-08-29029 August 2017 Request for Additional Information Response MSA (MF7946,7) and FE (MG0087,8) E-mail Attachment ML17240A3102017-08-15015 August 2017 NRR E-mail Capture - Nine Mile Point MSA and FE RAI ML17172A0842017-06-27027 June 2017 Request for Additional Information Regarding Relief Request to Utilize ASME Code Case N-702 ML17065A1622017-03-14014 March 2017 Request for Additional Information Regarding Proposed Alternative to Perform Pressure Isolation Valve Leakage Testing at Frequencies Consistent with 10 CFR Part 50, Appendix J 2023-09-21
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2013 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
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. ML12170A868), 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. ML13064A466, ML13092A139, and ML131270405, respectively), the licensee submitted its responses to the U.S. Nuclear Regulatory Commission's (NRC) RAis dated January 3, 2013 (ADAMS Accession No. ML12361A050).
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.
Sincerely,
~--~- g J "-
Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
As stated cc w/encl: Distribution via Listserv
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. ML12170A869) 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. ML13064A466), 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.
Sincerely, Ira/
Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
RAI cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL 1-1 RIF RidsNRRPMNineMilePoint RidsNRRLAKGoldstein RidsNrrDoriDpr RidsRgn1 MaiiCenter RidsNrrDirsltsb RidsAcrsAcnw_MaiiCTR DSchroeder, Rl RidsNrrDraApla RidsN rrDraAfpb RidsNrrDssStsb RidsNrrDraAhpb L. Fields, NRR/AFPB J. Hyslop, NRR/APLA C. Candace, NRR/AHPB J. Robinson, NRR/AFPB H. Khadijah, NRR/STSB S. Wall, NRR/DORL/LPL3-1 RidsDoriLpl1-1 ADAMS Accession Number.: ML13281A010 *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