ML14104A878

Phone Call with NPPD to Discussion Comments on Cooper NFPA 805 Safety Evaluation (ME8551)

ML14104A878
Person / Time
Site:	Cooper
Issue date:	04/14/2014
From:	Joseph Sebrosky Division of Operating Reactor Licensing
To:	Janet Burkhardt, Andrea George Office of Nuclear Reactor Regulation
References
ME8551
Download: ML14104A878 (29)

Text

1 NRR-PMDAPEm Resource From: Sebrosky, Joseph Sent: Monday, April 14, 2014 10:18 AM To: NRR-PMDA-ECapture Resource; Bu rkhardt, Janet; George, Andrea

Subject:

RE: phone call with NPPD to discussion comments on Cooper NFPA 805 safety evaluation (ME8551)The purpose of this email is to capture background information for a phone call that was held on 4/10/14 between NRC representatives and Nebraska Public Power District (NPPD) representatives to discuss

comments the NRC staff received on a draft of the Cooper safety evaluation associat ed with NPPD's license amendment request to transition to National Fire Protection Association 805 requirements. The agenda for the phone call can be found below.

The draft safety evaluation was provided to NPPD in an email dated March 27, 2014, and was provided to NPPD in accordance with NRC's Office of Nuclear Reactor Regulation Office Instruction COM-203, Revision 2, which states in part:

As another example, a Draft Safety Evaluation (SE) might be provided to a licensee or applicant to obtain agreement that it contains no proprietary information, in accordance with Office Instruction LIC-204. Similarly, draft SEs or selected portions thereof may be provided to a licensee or applicant to obtain agreement that factual information is accurate and complete. If these exchanges result in the discovery of new information needed for decision making, then this additional information must be appropriately submitted and preserved.

The staff binned the comments received by NPPD into three different files found below (i.e., administrative, editorial, and technical. The staff indicated that in some cases it would make changes to the safety evaluation based on NPPD's comments. The changes will be reflected in the final version of the documents.

Joe Sebrosky

Project Manager Nuclear Regulatory Commission Division of Operating Reactor Licensing joseph.sebrosky@nrc.gov 301-415-1132

---

Original Appointment-----

From: Sebrosky, Joseph Sent: Wednesday, April 09, 2014 2:37 PM To: 'Victor,, William R.- Strategic Initiatives' (wrvicto@nppd.com); Van Der Kamp, David (dwvande@nppd.com); George, Andrea; Barrett, Harold; Robinson, Jay; Wall, Scott

Cc: 'Meyer, Steve'; 'Shudak, Thomas G.'; 'Barker, Troy S.'; 'Ouellette, Paul'

Subject:

phone call with NPPD to discussion comments on Cooper NFPA 805 safety evaluation When: Thursday, April 10, 2014 12:00 PM-1:00 PM (UTC-05:00) Eastern Time (US & Canada).

Where: HQ-O-10B2 Purpose: To discuss comments received from NPPD on Cooper NFPA 805 safety evaluation, and to determine if the proposed disposition involves additional interactions

Outcome: Clear understanding of comment, disposition of comment, and path forward

Agenda:

2I. Discussion of comment and proposed disposition Draft Cooper SE Administrative...

Draft Cooper SE Editorial Comm...

Draft Cooper SE Technical Comm...

II. Identification of areas for future interactions III. Next steps

IV. wrapup Hearing Identifier: NRR_PMDA Email Number: 1223 Mail Envelope Properties (Joseph.Sebrosky@nrc.gov20140414101800)

Subject:

RE: phone call with NPPD to discussion comments on Cooper NFPA 805 safety evaluation (ME8551) Sent Date: 4/14/2014 10:18:29 AM Received Date: 4/14/2014 10:18:00 AM From: Sebrosky, Joseph Created By: Joseph.Sebrosky@nrc.gov Recipients: "NRR-PMDA-ECapture Resource" <NRR-PMDA-ECapture.Resource@nrc.gov> Tracking Status: None "Burkhardt, Janet" <Janet.Burkhardt@nrc.gov> Tracking Status: None "George, Andrea" <Andrea.George@nrc.gov>

Tracking Status: None Post Office: Files Size Date & Time MESSAGE 2652 4/14/2014 10:18:00 AM Draft Cooper SE Administrative Comments from Licensee NRC addressed.docx 920569 Draft Cooper SE Editorial Comments from Licensee NRC Addressed.docx 1425673 Draft Cooper SE Technical Comments from Licensee NRC Addressed.docx 467807 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

1 Draft SE Comment Sheet Draft SE Administrative Comments The following comments on the draft NFPA 805 Safety Evaluations relate to non-material accuracy and completeness issues, and ce rtain other areas of administrative importance.

Comment Number Location Comment Suggested Disposition NRC Response 1 Enclosure 1-Page 1/1.A. The August 23, 2014, letter is characterized as a supplement to the LAR. In fact, this letter provided acknowledgement of the terms and conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the application. Recommend deletion of the 8/23/2014 letter from paragraph 1.A.

2 Enclosure 1-Page 1/1.A. NPPD projects to be submitting a final letter on 4/11/2014 containing a requested change to the License Condition and providing clean/ retyped pages of the license. Recommend inclusion of the 4/11/2014 letter in Paragraph 1.A if the 4/11/2014 submittal date is acceptable.

3 Enclosure 1-Page 2/2.(4) The 8/23/14 letter is characterized as a supplement to the LAR. In fact, this letter provided acknowledgement of the terms and conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the

application. Recommend deletion of the 8/23/2014 letter from paragraph 2.(4).

4 Enclosure 1-Page 2/2.(4) NPPD projects to be submitting a final letter on 4/11/2014 containing a requested change to the License Condition and providing clean/ retyped pages of the license. Recommend inclusion of the 4/11/2014 letter in Paragraph 2.(4) if the 4/11/2014 submittal date is acceptable.

5 Enclosure 1-Page 3 The instruction say to insert pages 3 through 8. Attachment 2 of the LAR projects that the License will only extend to Page 7. Revise instructions to insert pages 3 through 7.

2 Comment Number Location Comment Suggested Disposition NRC Response 6 TOC-Page i/2.4.4 Section is entitled "Updated Final Safety Analysis Report." The CNS document is actually entitled "Updated Safety Analysis Report." Revise section title to "Updated Safety Analysis Report." Revised per comment. 7 TOC-Page ii TOC is missing section 3.1.1.6. Incorporate section 3.1.1.6, Compliance Strategy -

Complies With Required Action, Page 37, into TOC. Revised per comment. 8 TOC Page iii and SE Page 88 Section 3.4.2.3.2 identifies "Callaway" Change to "Cooper" Revised per comment. 9 TOC Page vi Attachment A and B tables are mis-numbered. Change "Table 3.8.3.2-1" to "Table 3.8-1," and "Table 3.8.3.2-2" to "Table 3.8-2." Revised per comment. 10 SE Page 3/1.2-1 st paragraph The August 23, 2014 letter is characterized as a supplement to the LAR. In fact, this letter provided acknowledgement of the terms and conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the

application. Recommend deletion of the 8/23/2014 letter from the requested licensing action.

11 SE Page 3/1.2-1 st paragraph NPPD projects to be submitting a final letter on 4/11/2014 containing a requested change to the License Condition and providing clean/ retyped pages of the license. Recommend inclusion of the 4/11/2014 letter in first paragraph if the 4/11/2014 submittal date is acceptable.

12 SE Page 3/1.2-1 st paragraph The 2/18/2014 letter was made in response to an NRC 2/6/2014 letter that documented the onsite audit conducted 1/24/2014-1/25/2014. That letter is not referenced in the second sentence. Recommend the 2/6/2014 letter be added to the second sentence of NRC letters that prompted RAI responses, and creation of a Reference for this letter.

3 Comment Number Location Comment Suggested Disposition NRC Response 13 SE Page 3/1.2-1 st paragraph The 7/12/2012 letter was made in response to an e-mail from Lynnea Wilkins to Ed McCutchen on

6/21/2012. This e-mail is not reflected in the second sentence or in the References. Note - the second sentence that addresses the prompts for the other responses include e-mails.

Recommend the67/21/2012 e-mail be added to the second sentence of NRC letters that prompted RAI responses, and creation of a Reference for this communication.

14 SE Page 4/1 st paragraph First sentence of paragraph states "Updated Final Safety Analysis Report (UFSAR)." The CNS document is actually entitled "Updated Safety Analysis Report." Revise sentence to read "Updated Safety Analysis Report (USAR)." Revised per comment. 15 SE Page 15 SE Section 3.2.7 should be added to FAQ 07-0038.Make correction. Revised per comment. 16 SE Page 20/2 nd paragraph Section 2.4.4 Heading and body of section use Updated Final Safety Analysis Report (UFSAR).

CNS has an Updated Safety Analysis Report (USAR) and not an UFSAR Replace Updated Fire Safety Analysis Report (UFSAR) with Updates Safety Analysis Report (USAR) Revised per comment. 17 SE Page 23/5 th paragraph Last sentence of paragraph states "See LAR Attachment S for implementation items". Attachment S has been updated in later RAI responses and supplements since LAR. Revise to read "See LAR Attachment S, as supplemented, for implementation items."

Alternative, refer to the 2/18/2014 letter that provided the updated S-3 table. Revised per comment. 18 SE Page 27/Section 2.7.1 The section title is "Modifications," but the subject matter includes both modifications and implementation items. Recommend changing title to "Modifications and Implementation Items." Revised per comment. 19 SE Page 31/Item 6 Item 6 has a cross-reference to Section 2.9 of the SE for implementation items. There is no Section

2.9 of the SE. Revise to cross-reference Section 2.8. Revised per comment.

4 Comment Number Location Comment Suggested Disposition NRC Response 20 SE Page 33/Section

3.1.1.4, 1st paragraph The last two sentences refer to the analysis and rescission of exemptions under the Section Compliance Strategy - Complies with Previous NRC Approval. However, none of these NFPA 805 elements on the B-1 table relied on the NRC exemptions to achieve NRC Approval. Rescission of exemptions is discussed in Section 2.5. Delete last two sentences regarding the performance of

RI/PB analysis on exemptions, and the request that they be rescinded. Revised per comment. 21 SE Page 40/Section

3.1.4.1, 1st paragraph First sentence makes a cross-reference to SE Section 3.1.1.6. Should be made to Section

3.1.1.5. Correct cross-reference. Revised to include SE Sections 3.1.1.5 and 3.1.1.6

as both are applicable. 22 SE Page 51 / last paragraph The "corresponding NFPA 805, Section 3.3.5.2" is identified but should be "Section 3.6.1" Correct NFPA 805 section. Revised per comment. 23 SE Page 65 / last paragraph Correct Fire Area "RBCF" to "RB-CF" Correct typo. Revised per comment. 24 SE Page 68/last paragraph First sentence characterizes S-2.4 as an implementation item. Table S-2 items are modifications. Revise sentence to read "modification S-2.4." Revised per comment. 25 SE Page 81/top paragraph - first full sentence in this paragraph The first full sentence on page 81 states "The licensee clarified that the fire-affected equipment list for several transients related to PRA RAI 13 and PRA RAI 14 were inappropriate and were revised;-"

This is an incorrect reference to PRA RAI 14. It should be PRA RAI 15 Revise wording in this sentence from "PRA RAI 14" to "PRA RAI 15" Revised per comment. 26 SE Page 83/1st full paragraph Second sentence reads "The licensee determined via walkdowns that that sensitive equipment were located..." Should read "The licensee determined via walkdowns that sensitive equipment is located..." Make corrections. Revised per comment.

5 Comment Number Location Comment Suggested Disposition NRC Response 27 SE Page 88 / 2 nd and 5th paragraphs of

bullet Change fire zone "RB-3C" to "3C" as RB is the compartment ID. Fix in both paragraphs on page. Revised per comment. 28 SE Page 88 / 4 th paragraph of bullet Move end parenthesis after foam insulation to end of sentence as both fire zones are part of i.e. Make correction Revised per comment. 29 SE Page 89 / 2 nd bullet on page Change "fire areas" to "Fire Zones 13A and 20B" and change "fire area 13A" to "Fire Zone 13A"

Last sentence change end to add "and therefore, the revised analysis is acceptable.

Make correction Revised per comment. 30 SE page 99 Footnote (1) of Table 3.4.6-2 states:

(1) LAR dated April 24, 2012, as supplemented by letter dated July 12, 2012 (References 6 and 7, respectively),

and RAI response letter dated February 18, 2014 (Reference 15)

Footnote (1) references RAI response letter 2/18/14. Fire Area RB-FN results were revised in PRA RAI 16e in letter dated 2/12/13 not in the response dated 2/18/14. The NRC appears to have referenced the wrong RAI response letter here. The footnote should be corrected to state "-and PRA RAI 16e response in letter dated February 12, 2013 (Reference 10)" Revised per comment. 31 SE Page 110 /

4 th bullet The fourth bullet, "Fire area boundaries-" appears to be incomplete.

Revise to read "The licensee's analysis appropriately identified fire area boundaries..." Revised per comment. 31 SE Page 121/ Section 3.6.8 Correct sections from "2.71 and 2.72" to "2.7.1 and 2.7.2" Make correction Revised to 2.7 and 2.8 6 Comment Number Location Comment Suggested Disposition NRC Response 32 SE Page 131/ 2 nd paragraph under 1 st bullet Change "contractor's System Failure Analysis Software (SAFE)" to "contractor's System Assurance and Fire Protection Engineering software (SAFE)" Make correction Revised per comment. 33 SE Page 137/1 st paragraph The 8/23/14 letter is characterized as a supplement to the LAR. In fact, this letter provided acknowledgement of the terms and conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the

application. Recommend deletion of the 8/23/2014 letter from the list of LAR supplements.

34 SE Page 137, Pg.

139, Pg. 138 (Ref. #73) Replace highlighted text when SE report is complete and date is available. Remove highlighted text. 35 SE Attachment C (pg. C1) Change "ASD Aspirating smoke detector" to "ASD - alternate shutdown." Make correction Revised per comment. 36 SE Attachment C (pg. C3) Change "UFSAR" to "USAR Updated Safety Analysis Report" Revised per comment.

1 Draft SE Editorial Comments The following comments on the draft Safety Evaluation relates to editorial/grammatical enhancements.

Comment Number Location Comment Suggested Disposition NRC Response 1 TOC Page iv/3.5.1.7 and

SE Page 108 Section title "Defense in Depth" should read "Defense-In-Depth." Include hyphens in section title. Revised per comment. 2 SE Page 6/2 nd paragraph Should have a colon instead or period after "in accordance with 10 CFR 50.48(c)(4)." Make correction. Revised per comment. 3 SE Page 6/3 rd paragraph First sentence states "-require licensees to submit an LAR for NRC review-" The word "an"

should be "a." Revise typo. Revised per comment. 4 SE Page 20/2 nd paragraph Section 2.4.4 - Second sentence refers to "Table S-3, Item S3.26." The correct designator is "S-3.26." Correct S-3 Table implementation item designator to "S-3.26." Revised per comment. 5 SE Page 36 /

3.6.1 discussion

bullet Last word "dated" should be removed from the 3.6.1 discussion bullet Remove extra word "dated" Revised per comment. 6 SE Page 36 /

3.10.7 discussion

bullet Change "license requested approval" to "licensee requested approval" Correct to licensee. Revised per comment. 7 SE Page 42 /

Section 3.1.4.3 and Reference

64 Change "E-136" to "E136." Fix ASTM test ID. Revised per comment. 8 SE Page 45/after 1 st paragraph Correct line "Control Building - Computer Room (Fire Zone 10A) Correct fire zone number. Revised per comment. 9 SE Page 50 / 3 rd paragraph Middle of paragraph - "additional 50 feet of hose to the standard 100 feet of hose required by the NFPA 14 was" Remove "the" before NFPA 14. Revised per comment.

2 Comment Number Location Comment Suggested Disposition NRC Response 10 SE Page 58 / 3 rd Paragraph Correct hyphens in LAR Attachment B Table B-2 title in 3 rd paragraph Fix title Revised per comment. 11 SE Page 58 / Bullets (2) and (5) Capitalize "Aligns with Intent" in bullet (2) and capitalize "Not in Alignment, but N o A dverse Consequences" in bullet (5) Capitalize categories to match B-2 Table No change. Could not identify issue. 12 SE Page 59 / 1 st Paragraph Second Sentence "In SSD RAI 01 November 14, 2012" needs to be revised to "In SSD RAI 01 dated November 14, 2012" Add "dated" Revised per comment. 13 SE Page 59 / 1 st Paragraph Second Sentence "Section 3.2.1.2 for post-fire operation of a manual rising-stem valves that have-" Delete "a" before manual rising-stem

valves Delete "a". Revised per comment. 14 SE page. 63 /

2 nd Paragraph Last Sentence of 2 nd full paragraph "The expert panel-with experience in electrical engineering; PRA, SSA-" Replace semicolon (;)

with comma (,) Correct typo. Revised per comment. 15 SE Page 65 / 1 st full paragraph "equipment-from" should remove hyphen (-) Correct typo. Revised per comment. 16 SE Page. 70 / 1 st Paragraph Last sentence of first paragraph, change "NRC endorsed" to "NRC-endorsed" Correct typo. Revised per comment. 17 SE Page 74 / 1 st full paragraph Remove hyphen (-) in "PRA RAI-12" to "PRA RAI 12" Correct typo. Revised per comment. 18 SE Page 75 / 1 st full paragraph Correct implementation item "3.24" to "S-3.24" Correct typo. Revised per comment. 19 SE Page 76/ 2 nd full paragraph Remove hyphen (-) in "NFPA-805" to "NFPA 805" Correct typo. Revised per comment. 20 SE Page. 78 / 1 st full paragraph 3 rd to last sentence - "-the human failure events created for the FPRA was less that the 1E-6 floor-" Replace "that" with "than" Correct typo. Revised per comment. 21 SE Page 78 / 2 nd full paragraph Correct Item S3 correct to match S-3 table ID of S-3.19. Correct S-3 Table implementation item ID to

S-3.19 Revised per comment.

3 Comment Number Location Comment Suggested Disposition NRC Response 22 SE Page 78 / 3 rd full paragraph "RAI 18" should be identified as "PRA RAI 18" Make correction. Revised per comment. 23 SE Page 79 / 1 st partial paragraph "RAI 40" should be identified as "PRA RAI 40" throughout.

Correct "PRA RAI-02.f-01" to "PRA RAI 02.f.01" Correct Item S3 correct to match S-3 table

ID of S-3.19. Make corrections Revised per comment. 24 SE Page 80 / 1 st paragraph "RAI 40" should be identified as "PRA RAI 40" throughout.

"RAI 14" should be identified as "PRA RAI 14".

"RAI 14.01" should be identified as "PRA RAI

14.01".

Correct Item S3 correct to match S-3 table ID of S-3.19. Make corrections Revised per comment. 25 SE Page 80 / 2 nd Paragraph Remove hyphen (-) in "post-NFPA-805" to read "post-NFPA 805" Make correction Revised per comment. 26 SE Page 80 / 2 nd Paragraph "RAI 36" should be identified as "PRA RAI 36".

Make correction Revised per comment. 27 SE Page 81 / 1 st partial paragraph Correct Item S3 correct to match S-3 table ID of S-3.19.

"RAI 40" should be identified as "PRA RAI 40" "RAI-36, RAI-11, and RAI-16e" should be "PRA RAI 36, PRA RAI 11, and PRA RAI 16.e" Make corrections Revised per comment.

4 Comment Number Location Comment Suggested Disposition NRC Response 28 SE Page 81 / 1 st full paragraph Add "the" before Auxiliary Relay Room in 1 st sentence "-for modeling transient fires with Auxiliary Relay Room-"

Remove hyphens (-) from RAI title PRA RAI-04 to PRA RAI 04

Correct RAI 4.1 or PRA RAI 04-01 to read "PRA RAI 04.01" throughout Correct RAI-04-02 to "PRA RAI 04.02"

"RAI 40" should be identified as "PRA RAI 40"

Correct Item S3 correct to match S-3 table ID of S-3.19. Revised per comment. 29 SE Page 82 / 1 st partial paragraph "RAI 40" should be identified as "PRA RAI 40"

Correct Item S3 correct to match S-3 table

ID of S-3.19. Revised per comment. 30 SE page 82 / 1 st full paragraph "RAI 40" should be identified as "PRA RAI 40" Correct Item S3 correct to match S-3 table ID of S-3.19. Revised per comment. 31 SE Page 82 / 2 nd full paragraph Correct "PRA RAI-05" to "PRA RAI 05" Revised per comment. 32 SE Page 82/ last paragraph "RAI 40" should be identified as "PRA RAI 40"

Correct Item S3 correct to match S-3 table

ID of S-3.19. Revised per comment.

5 Comment Number Location Comment Suggested Disposition NRC Response 33 SE Page 83 / 1 st partial paragraph Remove "for" from sentence "For the critical switchgear rooms, the response notes that fire barriers exist for with a rating of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />." Make correction Revised per comment. 34 SE Page 83 / 1 st full paragraph Lowercase "Fire Zones" in 1 st sentence.

Add full title of "NUREG/CR" to "NUREG/CR-6850" Correct "PRA RAI-02f-01" to "PRA RAI 02.f.01"

Item 2) revise from "abandonment conditions are reached" to "abandonment conditions being reached" Make corrections Revised per comment. 35 SE Page 83 / last paragraph 3 rd sentence revise to "The licensee also discussed the COP timing analysis as it related to HRA of containment isolation and all components associated with containment isolation pathways were selected and subsequently cable traced." Make corrections. Revised per comment. 36 SE Page 84 / 2 nd paragraph "RAI 40" should be identified as "PRA RAI 40"

Correct Item S3 correct to match S-3 table

ID of S-3.19. Make corrections Revised per comment. 37 SE Page 86 / 1 st paragraph Change "FDTS" to "FDT s" Validation and Verification should be reversed to "Verification and Validation" Make corrections Revised per comment. 38 SE Page 86 / 2 nd group of bullets Add comma (,) in reference - Sprinkler Activation Correlation (Reference 32, Chapter

10) Make correction Revised per comment.

6 Comment Number Location Comment Suggested Disposition NRC Response 39 SE Page 87 / last bullet under CFAST Change "HGL Study" to "HGL study" Make correction Revised per comment. 40 SE Page 88 / 4 th paragraph of

bullet Move end parenthesis after foam insulation to end of sentence as both fire zones are part of

i.e. Make correction Revised per comment. 41 SE Page 93 /

Section 3.4.2.4 1 st paragraph - Change "NFPA-805" to "NFPA 805" 2 nd paragraph - Correct Item S3 correct to match S-3 table ID of S-3.19. Make correction Revised per comment.

42 SE Section 3.4.3 Page 93/1 st Paragraph The second sentence has a typo: "... acceptable alternative to comply..."

Should be "... acceptable alternatives to comply..." Make corrections Revised per comment.

43 SE Section 3.4.4 Page 95/4 th Paragraph The second sentence has a typo: "None of the RAs listed in LAR Table G-1 was found to have an adverse impact on the FPRA."

Should be: "None of the RAs listed in LAR Table

G-1 were found to have any adverse impacts on the FPRA." Revised per comment. 44 SE Page 95 / 4 th full paragraph 1 st paragraph - Change "NFPA-805" to "NFPA 805" Delete stray period at end of paragraph. Make correction Revised per comment. 45 SE Section 3.4.4 Page 95/5 th Paragraph Remove the second period at the end of this paragraph. Make correction Revised per comment. 46 SE Page 99 / 2 nd paragraph Correct Item S-3 correct to match S-3 table ID of S-3.30. Make correction Revised per comment. 47 SE Page 99 / 3 rd paragraph Correct "PRA RAI-13" to "PRA RAI 13" Make correction Revised per comment.

7 Comment Number Location Comment Suggested Disposition NRC Response 48 SE Page 100 / last bullet Change "NFPA-805" to "NFPA 805" Make correction Revised per comment. 49 SE Page 101 /

1 st bullet Change comma (,) to colon (:) Make correction Revised per comment. 50 SE Page 103 /

2 nd paragraph Fix hyphen in Title of LAR Section 4.2.4 to "Fire Area - Transition" Make correction Revised per comment. 51 SE Page 104 / Table Correct description of RB-M to (/) instead of (I) "Reactor Building North / East Side, RHR Heat Exchanger Room A" Make correction Revised per comment. 52 SE Page 107 / last paragraph Remove stray character after "The NRC Staff's" in last sentence. Make correction Revised per comment. 53 SE Page 108 / last paragraph Add missing "of" in second sentence between "installation" and "these fire protection features."

Replace "addition" with "additional" in 3 rd sentence "including any additional fire protection systems" Make correction Revised per comment. 54 SE Page 109 / Section 3.5.1.10 Add space between "SSD RAI 08" and "dated" Make correction Revised per comment. 55 SE Page 114 /

1 st full paragraph Change "(complete bum-out)" to "(complete burn-out)" Make correction Revised per comment. 56 SE Page 116/Section

3.6.1 Under NFPA 805 Section 1.4.2 (1) the parenthesis within the end bracket is not

necessary. Make correction Revised per comment. 57 SE Page 117 /

1 st paragraph under indented text Add "in" to text "the methodology given NEI 04-02" to read "the methodology given in NEI 04-02" Make correction Revised per comment.

8 Comment Number Location Comment Suggested Disposition NRC Response 58 SE Page 117 / last paragraph Change "dry well" to "drywell" Make correction Revised per comment. 59 SE Page 120 /

1 st paragraph under Section

3.6.7 Change "Enclosure E, Table E-1" to read "LAR Attachment E, Table E-1" Make correction Revised per comment. 60 SE Page 123 /

3 rd bullet Revise to read "-exceeded in order to bring performance-" Make correction Revised per comment. 61 SE Page 123 /

1 st paragraph Correct implementation items to "S-3.1 and S-3.23" Make correction Revised per comment. 62 SE Page 125 / Section 3.8.3 Add "of" in the following "-engineering analyses used to support transition of the CNS FPP-" Make correction Revised per comment. 63 SE Page 128 /

2 nd bullet Remove space between "10" and "°C" Make correction Revised per comment. 64 SE Page 129 /

1 st partial sentence Correct implementation item to "S-3.8" Make correction Revised per comment. 65 SE Page 130 / Section 3.8.3.3.3 Correct implementation items to "S-3.8 and S-3.27" Make correction Revised per comment. 66 SE Page 131 / Section 3.8.3.4.2 Add "FM" in front of RAI in "-clarify its responses to an FM RAI."

Replace (.) with (:) at end of 1 st paragraph Make correction Revised per comment. 67 SE Page 133 /

1 st bullet Delete extra "FM" in front of "FM RAI 05(a)" Make correction Revised per comment. 68 SE Page 134 and Pg. 135 /

2 nd paragraph under closed bullet Change "NUREG 1824" to "NUREG-1824"

Change "FDTs" to "FDT s" throughout open bullets on pages 134 and 135 Make correction Revised per comment.

9 Comment Number Location Comment Suggested Disposition NRC Response 69 SE Page 135 / Section 3.8.3.5.3 Change last sentence to "-uncertainty analysis is in identified LAR Table S-3-" to

"-uncertainty analysis is identified in LAR Table S-3-" Change "implementation item 8" to "implementation item S-3.8." Make correction Revised per comment.

1 Draft SE Technical Comments The following comments on the draft NFPA 805 Safety Evaluations relate to material accuracy and completeness issues, and certain other areas of higher importance.

Comment Number Location Comment Suggested Disposition NRC Response 1 SE Pages 13 and 34 On these pages the NRC cites the use of NFPA 101, "Life Safety Code." NPPD is not committed to that standard, except to the degree it is

reflected in NFPA 805 requirements, as evaluated in the B-1 table. NPPD is concerned that the wording in the SE could be construed in the future to constitute a commitment in total to that standard. It is additionally noted that the NRC has not endorsed this standard, as part of NFPA 805, as it does not have a nexus to nuclear safety. Add note or clarification i n Section 3.1.1.5, bullet 3.3.3 that provides a disclaimer that NFPA 101 is not an endorsed standard for NFPA 805. No change. The referenced standard is listed in Section 2.2 of the SE which is titled:

"Applicable Staff Guidance". There is no wording in the SE that indicates the licensee is committed to the use of this standard or that the NRC requires compliance with this standard. 2 SE Page 14/Table 2.3-1 FAQ 07-0030 references SE Sections 3.2.2 and 3.4.3. There is no reference to FAQ 07-0030 in these sections. Also, SE Section 3.2.5 references this FAQ, but it not an SE Section

cited in Table 2.3-1. Delete reference in FAQ 07-0030 to SE Section 3.2.2 and 3.4.3.

Add 3.2.5 to SE Table 2.3-1 Revised per comment. 3 SE Page 17/Table 2.3-1 FAQ 12-0062, regarding USAR updates was used in the LAR (S-3.26 Implementation Item) and is discussed in the SE, but missing from the FAQ table Add FAQ 12-0062 to the FAQ table. Revised per comment. Note that FAQ 12-0062 was not included in LAR Attachment H.

2 Comment Number Location Comment Suggested Disposition NRC Response 4 SE Page 17/Table 2.3-1 FAQ 12-0064, "Hot Work/Transient Fire Frequency Influence Factors," is included in the table. However, this FAQ was finalized after submittal of the LAR, an thus, the LAR did not include any reference to FAQ 12-0064. SE Sections 3.4.2.2 and 3.4.7 referenced in the table do not mention it. Delete of FAQ 12-0064 from Table. Revised per comment. 5 SE Page21 The 5th bulleted exemption describes the Control Building Basement as being at 903'-6".

The actual elevation is below the grade level of 903'-6". The 9/21/83 Safety Evaluation does not include any elevation information. Page 23 of the LAR erroneously included this elevation information, and will be deleted in the follow-

up 4/11/2014 letter. Delete elevation of the Control Building Basement. Revised per comment. 6 SE Page 22/3rd paragraph Section 2.6.1, second sentence, states: "The license developed a change process that is based on ..." This change process has not been developed yet. Revise to read: "The licensee developed will develop a change process that is based on..." Revised per comment. 7 SE Page 22/Section 2.6.1, 3rd paragraph The paragraph does not discuss the specific bullets from the NPPD LAR specific to screening.

Without these bullets this SE appears to only apply screening to address changes that are only administrative in nature. This would not recognize the other purposes of screening that include screening for changes that would have less than minimal impacts to risk. Include discussion of bullets on page 48 of the NPPD LAR such that screening is also recognized as a process that is used to identify changes that have less than minimal impacts to risk. Revised per comment. 8 SE Section 2.6.1 Response to RAIs (Ref. NLS2013011 response to Programmatic RAI 05) is not included in the discussion for the plant change evaluation process. Include discussions to recognize that NPPD will incorporate the change evaluation process detailed in FAQ 12-0061. Revised per comment.

3 Comment Number Location Comment Suggested Disposition NRC Response 9 SE Page 22/last full paragraph SE states that the screening process was modeled after NEI 02-03 Rev. 0. Revision 1 to NEI 02-03 was actually used. No reference to a revision number was made in the LAR. Reword to reflect use of NEI 02-03 Rev. 1 and revise Reference

52. Revised per comment. 10 SE Page 22/Section 2.6.1, last paragraph The safety evaluation states "The licensee stated that the screening is followed by engineering evaluations-". This statement could be interpreted as all change evaluations would include an engineering evaluation.

However, some changes may not require engineering evaluations in that the change would be screened as trivial or having a less than minor risk impact. Revise statement to read "The licensee stated that the screening will identify when a change will require additional is followed by engineering evaluations." No change. SE states what was stated in the LAR. 11 SE Page 23/5th paragraph First sentence makes reference to "Non-Power Mode NSCA Treatment." CNS does not have a document of this type. Revise to read "Non-Power Mode reviews, etc.." Revised per comment and per LAR. 12 SE Page 27/1 st paragraph Excerpt "...may be used after transition to NFPA 805 as a part of the FREs conducted to determine the change in risk associated with proposed plant changes. " details that Cooper Nuclear Station will continue to perform FREs after transition. However, FREs were used to evaluate VFDRs and therefore will not be used after transition. Revise excerpt to the following: ..." may be used after transition to NFPA 805 as a part of the FREs Plant change Evaluations conducted to determine the

change in risk associated with proposed plant changes. Revised per comment.

4 Comment Number Location Comment Suggested Disposition NRC Response 13 SE Page 27/last paragraph Section 2.7.1 - Item S-3.30 states "will be in place 6 months after completion of modifications". This does not match the proposed licensee implem entation period of "implementation by May 31, 2017." The basis for the May 31, 2017, date was to allow six months after the projected end of Refueling Outage RE29, but that does not subsume that committed implementation date. Revise statement indicate that S-3.30 will be completed by May

31, 2017.. Revised per comment. 14 SE Page 28/Section 2.7.1 The wording in the License Condition could legally be construed that once the S-2 and S-3 are complete, no further changes to these configurations or processes could be made without violating the license condition. NPPD proposed to add words to the license condition to make it clear that once compliance was achieved, future changes could be made utilizing the protocols of the license condition, but was told by the NRC via e-mail that was unnecessary. Add a statement at the end of Section 2.7.1 stating:

"Once compliance has been achieved with the Table S-2 Modifications and Table S-3 Implementation Items, future changes to those affected configurations, processes, and procedures may be made using the self-approval process of the

Fire Protection license condition." No change. Upon completion of part c of the license condition, changes are made in accordance with parts a and b of the license condition. 15 SE Page 28/Section 2.7.2, 1 st paragraph The second sentence describes Implementation Item S-30 as being completed within 6 months after completion of the modifications described in the S-2 table. This does not match the proposed licensee implem entation period of "implementation by May 31, 2017." The basis for the May 31, 2017, date was to allow six months after the projected end of Refueling Outage RE29, but that does not subsume that date. Revise statement indicate that S-3.30 will be completed by May

31, 2017.. Revised per comment.

5 Comment Number Location Comment Suggested Disposition NRC Response 16 SE Page 61/first bullet The bullet states that the plant staff will endeavor to achieve a hot standby condition.

This is not applicable to BWR Technical Specifications. "hot standby" should be "hot shutdown (Mode 3)" for consistency with CNS Technical Specifications, and consistency with the later words "-cold shutdown (MODE 4) if necessary.". Make correction. Revised per comment. 17 SE Page 68/2nd full paragraph First sentence indicates that the post-transition period commences with the issuance of the Safety Evaluation. This is not NPPD's understanding. For purposes of the response to FPE RAI 10, the post-transition period was intended to mean after the 12-month implementation period after receiving the SE. Revise to read "... compensatory measures necessary in the period between transition(12 months after issuance of this SE) and completion of the modification." No change. The licensee's understanding is not correct. The post transition period begins upon issuance of the license amendment.

18 SE Page 69/1st paragraph First sentence implies that a continuous fire watch will be in place until the modifications are in place. The fire watch will be put in place after the 12-month implementation period. See Comment 17. Revise the sentence to read "The licensee further stated that compensatory measures during times when the incipient detection is out of service, including prior to completion of the modification, plant procedures will provide a continuous fire watch with hand-held incipient detection in the Auxiliary Relay Room after the 12-month implementation period." No change. See response to Comment 17. The post transition period begins upon issuance of the license amendment.

6 Comment Number Location Comment Suggested Disposition NRC Response 19 SE Page 72 last paragraph Excerpt "In PRA RAI 12, the licensee quantitatively defines the term: 'potentially risk significant fire scenarios.' Potentially risk significant" fire scenarios for the purpose of evaluating the need for DID are defined as..." requires further clarification to detail its application as detailed in PRA RAI 12. Also, it is recommended that the specific threshold be excluded from the SE as these are guidelines developed by Cooper Nuclear Station and not mandated by NFPA 805 requirements. Delete the three bullets following the excerpt. Replace the excerpt with "In PRA RAI 12, it is recognized that during some DID evaluations, it may become necessary to consider the potential for risk significant fire scenarios to impact VFDRs. In these cases, the licensee provide quantitative results from the FPRA for the purpose of evaluating the DID for VFDRs." Revised. The three bullets with quantitative guidelines were not deleted as they form an integral part of the SE and are consistent with past

SEs. 20 SE Page 74/Section

3.4.1.2 last paragraph The excerpt "Also, CNS has removed unacceptable methods or committed to updating the FPRA." does not provide the required specificity to define what is meant by "updating" the FPRA. A reference to the documents (i.e., as described in PRA RAI 40) that specify actions required for updating the FPRA should be provided in this paragraph. Revised. The identified sentence was deleted. 21 SE Page 75/Section 3.4.2 last paragraph The excerpt "Therefore, the NRC staff concludes that the PRA should be capable of supporting post-transition FREs to support,..." use of the term FRE is incorrect. Cooper's risk based evaluations after transition to NFPA 805 will not include FREs as these were done to evaluate transition. Recommend replacing "FRE" with "Plant Change Evaluations". Revised per comment. 23 SE Page 81/1 st full paragraph Paragraph lists Fire Zones 8B, 8C, 8E, 8G, and 8H from PRA-RAI 04.02, but does not include Fire Zone 8F, as described in PRA RAI 04.02. Add Fire Zone 8F. Revised per comment. 24 SE Page 83/1 st full paragraph To better reflect the response to PRA RAI 02f.01, Item 3) needs to be revised to "3) MCB cabinet walls protect sensitive equipment for a sufficient period such that the likelihood of not suppressing the fire prior to damage is low." Make revision. Revised per comment.

7 Comment Number Location Comment Suggested Disposition NRC Response 25 SE Page 86 / 2 nd paragraph "Fire Modeling Database" should be replaced with "Fire Modeling Workbook" throughout and "FMDB" replaced with "FMWB" throughout SE. Correct throughout SE Revised per comment. 26 SE Page 87 / bullets under FDS The bullet "Suppression activation time calculation in specific fire areas" was not used

at Cooper. Remove bullet "Suppression activation time calculation in specific fire areas" Revised per comment. 27 SE Page 91 / last paragraph of page Change transient height to "2 feet" based on SDP guidance. Make correction Revised per comment. 28 SE Page 99/Table 3.4.6-2 Fire Area TB-A "Description" contains buildings (Off Gas Building and Optimum Water Chemistry) that are considered part of Fire Area YD, as described in the LAR B-3 Table for these Fire Areas. Remove Off Gas Building and Optimum Water Chemistry from the TB-A description as these buildings are considered part of the YD. A revision to Attachment I of the LAR will be made to provide this clarification. Revised per comment. 29 SE Page 104/ able 3.5-1 Fire Area TB-A "Area Description" contains buildings (Off Gas Building and Optimum Water Chemistry) that are considered part of Fire Area YD, consistent with the LAR B-3 table. Remove Off Gas Building and Optimum Water Chemistry from the TB-A description as these buildings are considered part of the YD. A revision to Attachment I of the LAR will be made to provide this clarification. Revised per comment. 30 SE Page 109/1 st partial paragraph First sentence indicates shielding for Fire Areas CB-D and RB-m is for transient fires assumed in these fire areas. In Fire Area CB-D, the shielding that has been installed is for fixed sources (electrical panels). This is currently being installed. Correct sentence to include fixed sources as "-adequate for the fire duration of the transient and fixed source fires assumed-" Revised per comment. 31 SE Page 122/2 nd paragraph under indented text For consistency with FAQ 10-0059, under discussion of the scope of the monitoring program add "FPRA equipment." Make addition Revised per comment.

8 Comment Number Location Comment Suggested Disposition NRC Response 32 SE Page 126/bullet at end of page CNS does not use a Fire Modeling Database.

"Fire Modeling Database" should be replaced with "Fire Modeling Workbook." Revise to read: "...were implemented in a database and workbook referred to as the Fire Modeling Workbook Database (FMDB FMWB).

Replace "FMDB" with "FMWB" throughout SE. Revised per comment. 33 SE Attachments A and B "Fire Modeling Database" should be replaced with "Fire Modeling Workbook" throughout and

"FMDB." Needs to be corrected throughout both Attachments A and B. Revised per comment. 34 SE Attachment A (pg. A2) Radiant Heat Flux Application at CNS - Second sentence does not read correctly. Revise to read "The correlation was used to determine the horizontal separation distance..."

V&V Basis for NUREG-1805 is "Chapter 5" not Chapter 3 Make corrections Revised per comment. 35 SE Attachment A (pg. A2) Hot Gas Layer MQH V&V Basis for NUREG-1805 is "Chapter 2" not Chapter 3 Make correction Revised per comment. 36 SE Attachment A (pg. A3) Hot Gas Layer Beyler V&V Basis for NUREG-1805 is "Chapter 2" not Chapter 3 Make correction Revised per comment. 37 SE Attachment A (pg. A3) Hot Gas

Layer FPA V&V Basis for NUREG-1805 is "Chapter 2" not Chapter 3 Make correction Revised per comment. 38 SE Attachment A (Pg. A4) Ceiling Jet Temperature V&V Basis for NUREG-1824 is "Volume 4" not Volume 3 Make correction Revised per comment.

9 Comment Number Location Comment Suggested Disposition NRC Response 39 SE Attachment A (Pg. A4) Sprinkler

Activation

Correlation V&V Basis for NUREG-1805 is "Chapter 10" not Chapter 3 Make correction Revised per comment. 40 SE Attachment A (Pg. A5) Heat Detector Actuation

Correlation V&V Basis for NUREG-1805 is "Chapter 11" not Chapter 3 V&V Basis for NUREG-1824 is "Volume 4" not Volume 3

Remove SFPE Handbook discussion from the V&V Basis as this is related to smoke detector actuation.

Revise NRC Staff Evaluation 2 nd bullet to "The correlation is validated in authoritative publication of the NFPA Handbook.

" Make correction Revised per comment.

10 Comment Number Location Comment Suggested Disposition NRC Response 41 SE Attachment A (pg. A6) Smoke

Detector Actuation The smoke detector correlation is based on the ceiling jet correlation of Alpert and the 10°C rise is the Method of Heskestad and Delichatsios.

This correlation needs to be revised to include discussion of the Alpert Ceiling Jet correlation.

V&V Basis for NUREG-1805 is "Chapter 11" not

Chapter 3

V&V Basis for NUREG-1824 is "Volume 4" not Volume 3

Add SFPE Handbook Chapter 4-1 to the V&V

Basis for Smoke Detector Actuation.

Revise NRC Staff Evaluation 2 nd bullet to "The correlation is validated in authoritative publications of the NFPA and SFPE Handbooks.

" Make correction Revised per comment. 42 SE Attachment B (pg. B1) FDS for MCR V&V Basis for NUREG-1824 is "Volume 7" not Volume 3 NRC Staff Evaluation - Add "is" between "-abandonment time calculations" and "acceptable." in last sentence. Make correction Revised per comment.

43 SE Attachment B (pg. B2)

Temperature Sensitive Equipment ZOI V&V Basis for NUREG-1824 is "Volume 7" not Volume 3 Make correction Revised per comment.

11 Comment Number Location Comment Suggested Disposition NRC Response 44 SE Attachment B (pg. B3)

Plume/Hot Gas

Layer Interaction V&V Basis for NUREG-1824 is "Volume 7" not Volume 3 Make correction Revised per comment. 45 SE Attachment B (pg. B3) Hot Gas Layer CFAST V&V Basis for NUREG-1824 is "Volume 5" not Volume 3 Make correction Revised per comment. 46 SE Attachment B (pg. B4)

Temperature sensitive hot gas

layer V&V Basis for NUREG-1824 is "Volume 5" not Volume 3

Application at CNS - Change "equipments" to "equipment". Make correction Revised per comment. 47 SE Attachment C CNS does not use a Fire Modeling Database (FMDB) (see Comments32 and 33) Replace duplicated FMDB acronyms with FMWB (Fire Modeling Workbook). Revised per comment.