ML13178A035

Fort Calhoun, Unit 1 - Email Request for Additional Information Round 3 (Afpb), Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (20

ML13178A035
Person / Time
Site:	Fort Calhoun
Issue date:	06/27/2013
From:	Joseph Sebrosky Plant Licensing Branch IV
To:	Lippy D L Omaha Public Power District
Sebrosky J M
References
TAC ME7244
Download: ML13178A035 (3)

Text

1Burkhardt, JanetFrom:Sebrosky, JosephSent:Thursday, June 27, 2013 8:29 AMTo:'LIPPY, DONNA L'Cc:'bhansher@oppd.com'; 'medwards@oppd.com'; Wilkins, Lynnea; Robinson, Jay; Fields, Leslie; Burkhardt, JanetSubject:Fort Calhoun NFPA 805, Third Round of RAIs (ME7244)Attachments:ME7244 3rd Round RAIs Rev. 0.docxDonna, By letter dated September 28, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML112760660), as supplemented by letters dated December 19 and 22, 2011, and March 20, 2012 (ADAMS Accession Nos. ML113540334, ML11363A077, and ML12083A147, respectively), Omaha Public Power District, (the Licensee), submitted a license amendment request (LAR) to transition their fire protection licensing basis at the Fort Calhoun Station, Unit 1, from Title 10 of the Code of Federal Regulations (CFR), Section 50.48(b), to 10CFR50.48(c), National Fire Protection Association Standard NFPA 805 (NFPA 805). A review team, consisting of U.S. Nuclear Regulatory Commission (NRC) staff and contractors from Pacific Northwest National Laboratory (PNNL) and the Center for Nuclear Waste Regulatory Analyses (CNWRA) participated in a regulatory audit of Fort Calhoun in Blair, NE from March 5 -9, 2012. By letter dated April 26, 2012, (ADAMs Accession No. ML12198A406) the NRC issued requests for additional information (RAls). By letters dated July 24, 2012 (ADAMs Accession No. ML12208A131), August 24,2012 (ADAMs Accession No. ML12240A151), and September 27,2012 (ADAMS Accession No. ML12276A046) the licensee provided responses to the RAls. The NRC staff reviewed the information provided by the licensee in response to the first set of RAIs and determined that additional information was needed for the staff to complete its evaluation. Consequently, the staff issued a second round of RAIs on February 22, 2013, (ADAMS Accession No. ML13053A226). The licensee responded to these RAIs in letters dated April 23, 2013 (ADAMS Accession No. ML13116A015) and May 21, 2013 (ADAMS Accession No. ML13144A814). The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your application and determined that additional information is required in order to complete its review. Based on discussions with you It was agreed that a response to this RAI (with the exception of SSA RAI 07.01, and SSA RAI 18) would be provided by July 26, 2013. Based on discussions with you, a phone call will be arranged to discuss SSA RAI 07.01 and SSA RAI 18. During the phone call the SSA RAI 07.01 and SSA RAI 18 will be clarified, necessary revisions to the RAIs identified, and an schedule for their response will be established. Regarding the RAIs for which a July 26, 2013, response date has been established, should the NRC determine that this RAI is no longer necessary prior to this date, the request will be withdrawn. If circumstances result in the need to revise the requested response date, please contact me or Lynnea Wilkins. Fire Modeling RAI 06.01 In a letter dated May 21, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13137A128), the licensee responded to Fire Modeling RAI 06.a, which asked the licensee to explain how the effect of the increased heat released rate (HRR) due to vertical propagation in cable trays on the zone of influence (ZOI), and the resulting targets selected for damage in the probabilistic risk assessment (PRA), were determined. In the response to FM RAI 06.a the licensee indicated that three damage states were considered in the FCS Fire PRA (FPRA):

1. Only the ignition source is damaged,

2. All targets within the ZOI of the ignition source are damaged, and 3. All targets in the compartment are damaged (hot gas layer (HGL) development) 2 For the second damage state the ZOI consists of a cylinder that extends from floor to ceiling. In addition, for this damage state the ZOI is expanded when the 35° upward fire propagation in cable trays spreads outside the radial dimension of the ignition source ZOI. However, based on observations from additional walkdowns, the licensee did not identify any targets that are outside the radial ZOI of the ignition source and within the 35° fire propagation angle. The response to FM RAI 06.a indicates that the licensee did not account for the effect of the additional HRR from cable trays and recalculate the radial dimension of the ZOI based on the combined HRR of the ignition source and cable trays.

Clarify if the guidance provided in NUREG-CR/6850 Appendix-R was used to calculate vertical fire propagation through a stack of cable trays and to determine ignition of and propagation through an adjacent cable tray stack. Also clarify, if additional targets were identified for damage due to vertical and horizontal propagation through one or more cable tray stacks. In case additional targets are identified, re-quantify the risk (core damage frequency (CDF), large early release frequency (LERF), delta () CDF and LERF) to account for damage to these targets. Fire Protection Engineering (FPE) RAI 08.01 The compliance statement for LAR Table B-1, Element 3.4.1 (c) [On-Site Fire-Fighting Capability] is "Complies, with Required Action". The associated implementation item REC-009 (LAR Attachment S) will revise the current configuration of the fire brigade leader and one other member from operations, and three members from security. In a letter dated July 24, 2012, (ADAMS Accession No. ML12208A131) the licensee responded to Fire Protection Engineering RAI 08 by stating that the new configuration "will ensure the brigade leader and two other members will have sufficient knowledge and training of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria. Operations personnel would complete Equipment Operator - Nuclear Auxiliary non-license classroom training."

However, this response does not clarify full compliance with NFPA 805, Section 3.4.1(c), specifically with regards to the fire brigade leader maintaining sufficient knowledge and training.

Describe how the requirements of NFPA 805 Section 3.4.1(c) are met, namely "the brigade leader...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, Revision 2, 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." FPE RAI 21.01 a. In a letter dated April 23, 2013, (ADAMS Accession No. ML13116A015) the licensee's response to FPE RAI 21.a stated that "'commonly available equipment as referred to in LAR, Attachment L, Approval Request 1, includes wood that is an integral part of portable tools, equipment, pallets, or other apparatus." The NRC staff does not believe pallets or other apparatus containing untreated wood represents a similar amount of wood as a hand tool (e.g., screw driver with wooden handle). Provide further justification for these items or modify the request to only include small hand tools and portable equipment. As necessary, clarify how station order SO-G-91, Revision 28, Section 5.2.12, will be revised to reflect these changes. b. In the licensee's response to FPE RAI 21.b.i, station order SO-G-91, Rev 28, Section 5.2.13, states in part that "wood (including that treated with flame retardant) shall not be retained in the containment, auxiliary building, or intake structure for longer than necessary to support an activity."

3 However, NFPA 805, Section 3.3.1.2 (1) requires controls on wood throughout the power block. Provide justification for not applying these controls throughout the power block. c. NFPA 805, Section 3.3.1.2(3) states that "waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first." Provide justification for SO-G-91 not requiring "...or at the end of the shift, whichever comes first" as stated in NFPA 805.

FPE RAI 29 LAR Table B-1, Section 3.11.4(b), indicates a compliance statement of "Complies, with Required Action." However, based on the references to existing engineering equivalency evaluations (EEEEs) in the compliance bases section and the lack of an implementation item assigned to this element, it appears that the appropriate compliance statement should be "Complies with Use of EEEEs." Clarify the correct compliance statement. If "Complies, with Required Action" is correct, revise the compliance bases section and provide the applicable required action (i.e., implementation item). Safe Shutdown Analysis (SSA) RAI 07.01 In a letter dated July 24, 2012, (ADAMS Accession No. ML12208A131) the licensee responded to SSA RAI 07 and indicated that the service building (SB) was excluded from the power block in order to prevent having to meet NFPA 805 chapter 3 requirements for this low fire risk structure. However, because the fuel oil transfer pump for the diesel driven auxiliary feedwater (AFW) pump is in the SB and the pump is identified as a component necessary to achieve the NFPA 805 performance goals, the response to SSA RAI 07 is considered insufficient justification for excluding this facility from the power block.

LAR Attachment I, Page I-3, states that "the service building (NFPA 805 fire area 45-identified for the service building in EA-FC-97-001) is excluded from the power block on the basis that it contains only the fuel oil transfer pump (and its associated power cable) for diesel driven AFW pump, FW-54." The NRC staff finds the justification to exclude the SB is not sufficient to warrant exclusion from the controls of the power block from NFPA 805.

Provide a revised Table I-1 - "Power Block Definition" to include the appropriate portions of the SB applicable to the fuel oil transfer pump for AFW pump FW-54. The appropriate portions of the SB should be considered only those locations in the SB in which any part of the fuel oil transfer pump, power cables, power supplies, or control circuits would be located. SSA RAI 18 Provide the following pertaining to non-power operations (NPO) discussions provided in Section 4.3 and

Attachment

D of the LAR:

a. Identify and describe the changes to outage management procedures, shutdown risk management tools, work control, and any other document resulting from incorporation of KSF identified as part of NFPA 805 transition.

b. Provide a description of any actions, including pre-fire staging actions, being credited to minimize the impact of fire-induced spurious actuations on power operated valves (e.g., air operated valves (AOVs) and motor operated valves (MOVs)) during NPO (e.g., pre-fire rack-out, "pinning" valves, or isolation of air supply).

c. Identify those recovery actions relied upon in NPO by physical analysis unit (PAU) and describe how recovery action feasibility is evaluated. Include in the description whether these have been or will be factored into operator procedures supporting these actions.