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

NRR-PMDAPEm Resource From: Sebrosky, Joseph Sent: Monday, April 14, 2014 10:18 AM To: NRR-PMDA-ECapture Resource; Burkhardt, 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 associated with NPPDs 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 NRCs 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 NPPDs 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:

1

I. Discussion of comment and proposed disposition Draft Cooper SE Draft Cooper SE Draft Cooper SE Administrative... Editorial Comm... Technical Comm...

II. Identification of areas for future interactions III. Next steps IV. wrapup 2

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:

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 certain other areas of administrative importance.

Comment Location Comment Suggested Disposition NRC Response Number 1 Enclosure 1- The August 23, 2014, letter is characterized as a Recommend deletion of the Page 1/1.A. supplement to the LAR. In fact, this letter 8/23/2014 letter from provided acknowledgement of the terms and paragraph 1.A.

conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the application.

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

3 Enclosure 1- The 8/23/14 letter is characterized as a Recommend deletion of the Page 2/2.(4) supplement to the LAR. In fact, this letter 8/23/2014 letter from provided acknowledgement of the terms and paragraph 2.(4).

conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the application.

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

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

will only extend to Page 7.

1

Comment Location Comment Suggested Disposition NRC Response Number 6 TOC-Page Section is entitled Updated Final Safety Analysis Revise section title to Revised per comment.

i/2.4.4 Report. The CNS document is actually entitled Updated Safety Analysis Updated Safety Analysis Report. Report.

7 TOC-Page ii TOC is missing section 3.1.1.6. Incorporate section 3.1.1.6, Revised per comment.

Compliance Strategy -

Complies With Required Action, Page 37, into TOC.

8 TOC Page iii and Section 3.4.2.3.2 identifies Callaway Change to Cooper Revised per comment.

SE Page 88 9 TOC Page vi Attachment A and B tables are mis-numbered. Change "Table 3.8.3.2-1" to Revised per comment.

"Table 3.8-1," and "Table 3.8.3.2-2" to "Table 3.8-2."

10 SE Page 3/1.2- The August 23, 2014 letter is characterized as a Recommend deletion of the 1st paragraph supplement to the LAR. In fact, this letter 8/23/2014 letter from the provided acknowledgement of the terms and requested licensing action.

conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the application.

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

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

2

Comment Location Comment Suggested Disposition NRC Response Number 13 SE Page 3/1.2- The 7/12/2012 letter was made in response to an Recommend the67/21/2012 1st paragraph e-mail from Lynnea Wilkins to Ed McCutchen on e-mail be added to the second 6/21/2012. This e-mail is not reflected in the sentence of NRC letters that second sentence or in the References. Note - the prompted RAI responses, and second sentence that addresses the prompts for creation of a Reference for the other responses include e-mails. this communication.

14 SE Page 4/1st First sentence of paragraph states Updated Final Revise sentence to read Revised per comment.

paragraph Safety Analysis Report (UFSAR). The CNS Updated Safety Analysis document is actually entitled Updated Safety Report (USAR).

Analysis Report.

15 SE Page 15 SE Section 3.2.7 should be added to FAQ 07-0038. Make correction. Revised per comment.

16 SE Page 20/2nd Section 2.4.4 Heading and body of section use Replace Updated Fire Safety Revised per comment.

paragraph Updated Final Safety Analysis Report (UFSAR). Analysis Report (UFSAR) with CNS has an Updated Safety Analysis Report Updates Safety Analysis (USAR) and not an UFSAR Report (USAR) 17 SE Page 23/5th Last sentence of paragraph states See LAR Revise to read See LAR Revised per comment.

paragraph Attachment S for implementation items. Attachment S, as Attachment S has been updated in later RAI supplemented, for responses and supplements since LAR. implementation items.

Alternative, refer to the 2/18/2014 letter that provided the updated S-3 table.

18 SE Page The section title is "Modifications," but the Recommend changing title to Revised per comment.

27/Section 2.7.1 subject matter includes both modifications and "Modifications and implementation items. Implementation Items."

19 SE Page 31/Item Item 6 has a cross-reference to Section 2.9 of the Revise to cross-reference Revised per comment.

6 SE for implementation items. There is no Section Section 2.8.

2.9 of the SE.

3

Comment Location Comment Suggested Disposition NRC Response Number 20 SE Page The last two sentences refer to the analysis and Delete last two sentences Revised per comment.

33/Section rescission of exemptions under the Section regarding the performance of 3.1.1.4, 1st Compliance Strategy - Complies with Previous RI/PB analysis on exemptions, paragraph NRC Approval. However, none of these NFPA 805 and the request that they be elements on the B-1 table relied on the NRC rescinded.

exemptions to achieve NRC Approval. Rescission of exemptions is discussed in Section 2.5.

21 SE Page First sentence makes a cross-reference to SE Correct cross-reference. Revised to include SE 40/Section Section 3.1.1.6. Should be made to Section Sections 3.1.1.5 and 3.1.1.6 3.1.4.1, 1st 3.1.1.5. as both are applicable.

paragraph 22 SE Page 51 / last The corresponding NFPA 805, Section 3.3.5.2 is Correct NFPA 805 section. Revised per comment.

paragraph identified but should be Section 3.6.1 23 SE Page 65 / last Correct Fire Area RBCF to RB-CF Correct typo. Revised per comment.

paragraph 24 SE Page 68/last First sentence characterizes S-2.4 as an Revise sentence to read Revised per comment.

paragraph implementation item. Table S-2 items are "modification S-2.4."

modifications.

25 SE Page 81/top The first full sentence on page 81 states The Revise wording in this Revised per comment.

paragraph - first licensee clarified that the fire-affected equipment sentence from PRA RAI 14 full sentence in list for several transients related to PRA RAI 13 to PRA RAI 15 this paragraph and PRA RAI 14 were inappropriate and were revised; This is an incorrect reference to PRA RAI 14. It should be PRA RAI 15 26 SE Page 83/1st Second sentence reads "The licensee determined Make corrections. Revised per comment.

full paragraph via walkdowns that that sensitive equipment were located..." Should read "The licensee determined via walkdowns that sensitive equipment is located..."

4

Comment Location Comment Suggested Disposition NRC Response Number 27 SE Page 88 / 2nd Change fire zone RB-3C to 3C as RB is the Fix in both paragraphs on Revised per comment.

and 5th compartment ID. page.

paragraphs of bullet 28 SE Page 88 / 4th Move end parenthesis after foam insulation to Make correction Revised per comment.

paragraph of end of sentence as both fire zones are part of i.e.

bullet 29 SE Page 89 / 2nd Change fire areas to Fire Zones 13A and 20B Make correction Revised per comment.

bullet on page and change fire area 13A to Fire Zone 13A Last sentence change end to add and therefore, the revised analysis is acceptable.

30 SE page 99 Footnote (1) of Table 3.4.6-2 states: The footnote should be Revised per comment.

corrected to state and PRA (1) LAR dated April 24, 2012, as RAI 16e response in letter supplemented by letter dated July 12, dated February 12, 2013 2012 (References 6 and 7, respectively), (Reference 10) 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.

31 SE Page 110 / The fourth bullet, Fire area boundaries Revise to read The licensees Revised per comment.

4th bullet appears to be incomplete. analysis appropriately identified fire area boundaries...

31 SE Page 121/ Correct sections from 2.71 and 2.72 to 2.7.1 Make correction Revised to 2.7 and 2.8 Section 3.6.8 and 2.7.2 5

Comment Location Comment Suggested Disposition NRC Response Number 32 SE Page 131/ 2nd Change contractors System Failure Analysis Make correction Revised per comment.

paragraph Software (SAFE) to contractors System under 1st bullet Assurance and Fire Protection Engineering software (SAFE) 33 SE Page 137/1st The 8/23/14 letter is characterized as a Recommend deletion of the paragraph supplement to the LAR. In fact, this letter 8/23/2014 letter from the list provided acknowledgement of the terms and of LAR supplements.

conditions of the CNS NFPA 805 portal. The letter, of itself, contained no supplemental information relevant to the NRC review of the application.

34 SE Page 137, Pg. Replace highlighted text when SE report is Remove highlighted text.

139, Pg. 138 complete and date is available.

(Ref. #73) 35 SE Attachment Change ASD Aspirating smoke detector" to Make correction Revised per comment.

C (pg. C1) "ASD - alternate shutdown.

36 SE Attachment Change UFSAR to USAR Updated Safety Revised per comment.

C (pg. C3) Analysis Report 6

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

Comment Location Comment Suggested Disposition NRC Response Number 1 TOC Page Section title Defense in Depth should read Include hyphens in section title. Revised per comment.

iv/3.5.1.7 and Defense-In-Depth.

SE Page 108 2 SE Page 6/2nd Should have a colon instead or period after in Make correction. Revised per comment.

paragraph accordance with 10 CFR 50.48(c)(4).

3 SE Page 6/3rd First sentence states require licensees to Revise typo. Revised per comment.

paragraph submit an LAR for NRC review The word an should be a.

4 SE Page 20/2nd Section 2.4.4 - Second sentence refers to Correct S-3 Table Revised per comment.

paragraph "Table S-3, Item S3.26." The correct designator implementation item is "S-3.26." designator to "S-3.26."

5 SE Page 36 / Last word dated should be removed from the Remove extra word dated Revised per comment.

3.6.1 discussion 3.6.1 discussion bullet bullet 6 SE Page 36 / Change license requested approval to Correct to licensee. Revised per comment.

3.10.7 licensee requested approval discussion bullet 7 SE Page 42 / Change E-136 to E136. Fix ASTM test ID. Revised per comment.

Section 3.1.4.3 and Reference 64 8 SE Page Correct line Control Building - Computer Room Correct fire zone number. Revised per comment.

45/after 1st (Fire Zone 10A) paragraph 9 SE Page 50 / 3rd Middle of paragraph - additional 50 feet of Remove the before NFPA 14. Revised per comment.

paragraph hose to the standard 100 feet of hose required by the NFPA 14 was 1

Comment Location Comment Suggested Disposition NRC Response Number 10 SE Page 58 / 3rd Correct hyphens in LAR Attachment B Table B-2 Fix title Revised per comment.

Paragraph title in 3rd paragraph 11 SE Page 58 / Capitalize Aligns with Intent in bullet (2) and Capitalize categories to match No change. Could not Bullets (2) and capitalize Not in Alignment, but No Adverse B-2 Table identify issue.

(5) Consequences in bullet (5) 12 SE Page 59 / 1st Second Sentence In SSD RAI 01 November 14, Add dated Revised per comment.

Paragraph 2012 needs to be revised to In SSD RAI 01 dated November 14, 2012 13 SE Page 59 / 1st Second Sentence Section 3.2.1.2 for post-fire Delete a. Revised per comment.

Paragraph operation of a manual rising-stem valves that have Delete a before manual rising-stem valves 14 SE page. 63 / Last Sentence of 2nd full paragraph The expert Correct typo. Revised per comment.

2nd Paragraph panelwith experience in electrical engineering; PRA, SSA Replace semicolon (;)

with comma (,)

15 SE Page 65 / 1st equipment-from should remove hyphen (-) Correct typo. Revised per comment.

full paragraph 16 SE Page. 70 / 1st Last sentence of first paragraph, change NRC Correct typo. Revised per comment.

Paragraph endorsed to NRC-endorsed 17 SE Page 74 / 1st Remove hyphen (-) in PRA RAI-12 to PRA RAI Correct typo. Revised per comment.

full paragraph 12 18 SE Page 75 / 1st Correct implementation item 3.24 to S-3.24 Correct typo. Revised per comment.

full paragraph 19 SE Page 76/ 2nd Remove hyphen (-) in NFPA-805 to NFPA Correct typo. Revised per comment.

full paragraph 805 20 SE Page. 78 / 1st 3rd to last sentence - the human failure Correct typo. Revised per comment.

full paragraph events created for the FPRA was less that the 1E-6 floor Replace that with than 21 SE Page 78 / 2nd Correct Item S3 correct to match S-3 table Correct S-3 Table Revised per comment.

full paragraph ID of S-3.19. implementation item ID to S-3.19 2

Comment Location Comment Suggested Disposition NRC Response Number 22 SE Page 78 / 3rd RAI 18 should be identified as PRA RAI 18 Make correction. Revised per comment.

full paragraph 23 SE Page 79 / 1st RAI 40 should be identified as PRA RAI 40 Make corrections Revised per comment.

partial throughout.

paragraph 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.

24 SE Page 80 / 1st RAI 40 should be identified as PRA RAI 40 Make corrections Revised per comment.

paragraph 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.

25 SE Page 80 / 2nd Remove hyphen (-) in post-NFPA-805 to read Make correction Revised per comment.

Paragraph post-NFPA 805 26 SE Page 80 / 2nd RAI 36 should be identified as PRA RAI 36. Make correction Revised per comment.

Paragraph 27 SE Page 81 / 1st Correct Item S3 correct to match S-3 table Make corrections Revised per comment.

partial ID of S-3.19.

paragraph 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 3

Comment Location Comment Suggested Disposition NRC Response Number 28 SE Page 81 / 1st Add the before Auxiliary Relay Room in 1st Revised per comment.

full paragraph 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.

29 SE Page 82 / 1st RAI 40 should be identified as PRA RAI 40 Revised per comment.

partial paragraph Correct Item S3 correct to match S-3 table ID of S-3.19.

30 SE page 82 / 1st RAI 40 should be identified as PRA RAI 40 Revised per comment.

full paragraph Correct Item S3 correct to match S-3 table ID of S-3.19.

31 SE Page 82 / 2nd Correct PRA RAI-05 to PRA RAI 05 Revised per comment.

full paragraph 32 SE Page 82/ last RAI 40 should be identified as PRA RAI 40 Revised per comment.

paragraph Correct Item S3 correct to match S-3 table ID of S-3.19.

4

Comment Location Comment Suggested Disposition NRC Response Number 33 SE Page 83 / 1st Remove for from sentence For the critical Make correction Revised per comment.

partial switchgear rooms, the response notes that fire paragraph 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 />.

34 SE Page 83 / 1st Lowercase Fire Zones in 1st sentence. Make corrections Revised per comment.

full paragraph 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 35 SE Page 83 / 3rd sentence revise to The licensee also Make corrections. Revised per comment.

last paragraph 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.

36 SE Page 84 / 2nd RAI 40 should be identified as PRA RAI 40 Make corrections Revised per comment.

paragraph Correct Item S3 correct to match S-3 table ID of S-3.19.

37 SE Page 86 / 1st Change FDTS to FDTs Make corrections Revised per comment.

paragraph Validation and Verification should be reversed to Verification and Validation 38 SE Page 86 / 2nd Add comma (,) in reference - Sprinkler Make correction Revised per comment.

group of bullets Activation Correlation (Reference 32, Chapter 10) 5

Comment Location Comment Suggested Disposition NRC Response Number 39 SE Page 87 / Change HGL Study to HGL study Make correction Revised per comment.

last bullet under CFAST 40 SE Page 88 / 4th Move end parenthesis after foam insulation to Make correction Revised per comment.

paragraph of end of sentence as both fire zones are part of bullet i.e.

41 SE Page 93 / 1st paragraph - Change NFPA-805 to NFPA Make correction Revised per comment.

Section 3.4.2.4 805 2nd paragraph - Correct Item S3 correct to match S-3 table ID of S-3.19.

42 The second sentence has a typo: ... acceptable Make corrections Revised per comment.

SE Section 3.4.3 alternative to comply...

Page 93/1st Should be ... acceptable alternatives to Paragraph comply...

43 The second sentence has a typo: None of the Revised per comment.

RAs listed in LAR Table G-1 was found to have SE Section 3.4.4 an adverse impact on the FPRA.

Page 95/4th Should be: None of the RAs listed in LAR Table Paragraph G-1 were found to have any adverse impacts on the FPRA.

44 SE Page 95 / 4th 1st paragraph - Change NFPA-805 to NFPA Make correction Revised per comment.

full paragraph 805 Delete stray period at end of paragraph.

45 SE Section 3.4.4 Remove the second period at the end of this Make correction Revised per comment.

Page 95/5th paragraph.

Paragraph 46 SE Page 99 / 2nd Correct Item S-3 correct to match S-3 table Make correction Revised per comment.

paragraph ID of S-3.30.

47 SE Page 99 / 3rd Correct PRA RAI-13 to PRA RAI 13 Make correction Revised per comment.

paragraph 6

Comment Location Comment Suggested Disposition NRC Response Number 48 SE Page 100 / Change NFPA-805 to NFPA 805 Make correction Revised per comment.

last bullet 49 SE Page 101 / Change comma (,) to colon (:) Make correction Revised per comment.

1st bullet 50 SE Page 103 / Fix hyphen in Title of LAR Section 4.2.4 to Fire Make correction Revised per comment.

2nd paragraph Area - Transition 51 SE Page 104 / Correct description of RB-M to (/) instead of (I) Make correction Revised per comment.

Table Reactor Building North / East Side, RHR Heat Exchanger Room A 52 SE Page 107 / Remove stray character after The NRC Staffs Make correction Revised per comment.

last paragraph in last sentence.

53 SE Page 108 / Add missing of in second sentence between Make correction Revised per comment.

last paragraph installation and these fire protection features.

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

Section 3.5.1.10 55 SE Page 114 / Change (complete bum-out) to (complete Make correction Revised per comment.

1st full burn-out) paragraph 56 SE Page Under NFPA 805 Section 1.4.2 (1) the Make correction Revised per comment.

116/Section parenthesis within the end bracket is not 3.6.1 necessary.

57 SE Page 117 / Add in to text the methodology given NEI 04- Make correction Revised per comment.

1st paragraph 02 to read the methodology given in NEI 04-under indented 02 text 7

Comment Location Comment Suggested Disposition NRC Response Number 58 SE Page 117 / Change dry well to drywell Make correction Revised per comment.

last paragraph 59 SE Page 120 / Change Enclosure E, Table E-1 to read LAR Make correction Revised per comment.

1st paragraph Attachment E, Table E-1 under Section 3.6.7 60 SE Page 123 / Revise to read exceeded in order to bring Make correction Revised per comment.

3rd bullet performance 61 SE Page 123 / Correct implementation items to S-3.1 and S- Make correction Revised per comment.

1st paragraph 3.23 62 SE Page 125 / Add of in the following engineering Make correction Revised per comment.

Section 3.8.3 analyses used to support transition of the CNS FPP 63 SE Page 128 / Remove space between 10 and °C Make correction Revised per comment.

2nd bullet 64 SE Page 129 / Correct implementation item to S-3.8 Make correction Revised per comment.

1st partial sentence 65 SE Page 130 / Correct implementation items to S-3.8 and S- Make correction Revised per comment.

Section 3.27 3.8.3.3.3 66 SE Page 131 / Add FM in front of RAI in clarify its Make correction Revised per comment.

Section responses to an FM RAI.

3.8.3.4.2 Replace (.) with (:) at end of 1st paragraph 67 SE Page 133 / Delete extra FM in front of FM RAI 05(a) Make correction Revised per comment.

1st bullet 68 SE Page 134 Change NUREG 1824 to NUREG-1824 Make correction Revised per comment.

and Pg. 135 /

2nd paragraph Change FDTs to FDTs throughout open under closed bullets on pages 134 and 135 bullet 8

Comment Location Comment Suggested Disposition NRC Response Number 69 SE Page 135 / Change last sentence to uncertainty analysis Make correction Revised per comment.

Section is in identified LAR Table S-3 to 3.8.3.5.3 uncertainty analysis is identified in LAR Table S-3 Change implementation item 8 to implementation item S-3.8.

9

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 Location Comment Suggested Disposition NRC Response Number 1 SE Pages 13 and On these pages the NRC cites the use of NFPA Add note or clarification i n No change. The 34 101, Life Safety Code. NPPD is not committed Section 3.1.1.5, bullet 3.3.3 that referenced standard is to that standard, except to the degree it is provides a disclaimer that NFPA listed in Section 2.2 of the reflected in NFPA 805 requirements, as 101 is not an endorsed standard SE which is titled:

evaluated in the B-1 table. NPPD is concerned for NFPA 805. Applicable Staff that the wording in the SE could be construed in Guidance. There is no the future to constitute a commitment in total wording in the SE that to that standard. It is additionally noted that indicates the licensee is the NRC has not endorsed this standard, as part committed to the use of of NFPA 805, as it does not have a nexus to this standard or that the nuclear safety. NRC requires compliance with this standard.

2 SE Page 14/Table FAQ 07-0030 references SE Sections 3.2.2 and Delete reference in FAQ 07-0030 Revised per comment.

2.3-1 3.4.3. There is no reference to FAQ 07-0030 in to SE Section 3.2.2 and 3.4.3.

these sections. Also, SE Section 3.2.5 references this FAQ, but it not an SE Section Add 3.2.5 to SE Table 2.3-1 cited in Table 2.3-1.

3 SE Page 17/Table FAQ 12-0062, regarding USAR updates was used Add FAQ 12-0062 to the FAQ Revised per comment.

2.3-1 in the LAR (S-3.26 Implementation Item) and is table. Note that FAQ 12-0062 discussed in the SE, but missing from the FAQ was not included in LAR table Attachment H.

1

Comment Location Comment Suggested Disposition NRC Response Number 4 SE Page 17/Table FAQ 12-0064, "Hot Work/Transient Fire Delete of FAQ 12-0064 from Revised per comment.

2.3-1 Frequency Influence Factors," is included in the Table.

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.

5 SE Page21 The 5th bulleted exemption describes the Delete elevation of the Control Revised per comment.

Control Building Basement as being at 903'-6". Building Basement.

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.

6 SE Page 22/3rd Section 2.6.1, second sentence, states: "The Revise to read: "The licensee Revised per comment.

paragraph license developed a change process that is developed will develop a change based on ..." This change process has not been process that is based on..."

developed yet.

7 SE Page The paragraph does not discuss the specific Include discussion of bullets on Revised per comment.

22/Section 2.6.1, bullets from the NPPD LAR specific to screening. page 48 of the NPPD LAR such 3rd paragraph Without these bullets this SE appears to only that screening is also recognized apply screening to address changes that are as a process that is used to only administrative in nature. This would not identify changes that have less recognize the other purposes of screening that than minimal impacts to risk.

include screening for changes that would have less than minimal impacts to risk.

8 SE Section 2.6.1 Response to RAIs (Ref. NLS2013011 response to Include discussions to recognize Revised per comment.

Programmatic RAI 05) is not included in the that NPPD will incorporate the discussion for the plant change evaluation change evaluation process process. detailed in FAQ 12-0061.

2

Comment Location Comment Suggested Disposition NRC Response Number 9 SE Page 22/last SE states that the screening process was Reword to reflect use of NEI 02- Revised per comment.

full paragraph modeled after NEI 02-03 Rev. 0. Revision 1 to 03 Rev. 1 and revise Reference NEI 02-03 was actually used. No reference to a 52.

revision number was made in the LAR.

10 SE Page The safety evaluation states The licensee Revise statement to read The No change. SE states 22/Section 2.6.1, stated that the screening is followed by licensee stated that the what was stated in the last paragraph engineering evaluations. This statement screening will identify when a LAR.

could be interpreted as all change evaluations change will require additional is would include an engineering evaluation. followed by engineering However, some changes may not require evaluations."

engineering evaluations in that the change would be screened as trivial or having a less than minor risk impact.

11 SE Page 23/5th First sentence makes reference to "Non-Power Revise to read "Non-Power Revised per comment and paragraph Mode NSCA Treatment." CNS does not have a Mode reviews, etc.." per LAR.

document of this type.

12 SE Page 27/1st Excerpt "...may be used after transition to NFPA Revise excerpt to the following: Revised per comment.

paragraph 805 as a part of the FREs conducted to ..." may be used after transition determine the change in risk associated with to NFPA 805 as a part of the FREs proposed plant changes. " details that Cooper Plant change Evaluations Nuclear Station will continue to perform FREs conducted to determine the after transition. However, FREs were used to change in risk associated with evaluate VFDRs and therefore will not be used proposed plant changes.

after transition.

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Comment Location Comment Suggested Disposition NRC Response Number 13 SE Page 27/last Section 2.7.1 - Item S-3.30 states will be in Revise statement indicate that S- Revised per comment.

paragraph place 6 months after completion of 3.30 will be completed by May modifications. This does not match the 31, 2017..

proposed licensee implementation 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.

14 SE Page The wording in the License Condition could Add a statement at the end of No change. Upon 28/Section 2.7.1 legally be construed that once the S-2 and S-3 Section 2.7.1 stating: completion of part c of are complete, no further changes to these the license condition, configurations or processes could be made "Once compliance has been changes are made in without violating the license condition. NPPD achieved with the Table S-2 accordance with parts a proposed to add words to the license condition Modifications and Table S-3 and b of the license to make it clear that once compliance was Implementation Items, future condition.

achieved, future changes could be made changes to those affected utilizing the protocols of the license condition, configurations, processes, and but was told by the NRC via e-mail that was procedures may be made using unnecessary. the self-approval process of the Fire Protection license condition."

15 SE Page The second sentence describes Implementation Revise statement indicate that S- Revised per comment.

28/Section 2.7.2, Item S-30 as being completed within 6 months 3.30 will be completed by May 1st paragraph after completion of the modifications described 31, 2017..

in the S-2 table. This does not match the proposed licensee implementation 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.

4

Comment Location Comment Suggested Disposition NRC Response Number 16 SE Page 61/first The bullet states that the plant staff will Make correction. Revised per comment.

bullet 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..

17 SE Page 68/2nd First sentence indicates that the post-transition Revise to read "... compensatory No change. The full paragraph period commences with the issuance of the measures necessary in the licensees understanding Safety Evaluation. This is not NPPDs period between transition(12 is not correct. The post understanding. For purposes of the response to months after issuance of this SE) transition period begins FPE RAI 10, the post-transition period was and completion of the upon issuance of the intended to mean after the 12-month modification." license amendment.

implementation period after receiving the SE.

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

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."

5

Comment Location Comment Suggested Disposition NRC Response Number 19 SE Page 72 last Excerpt "In PRA RAI 12, the licensee Delete the three bullets Revised. The three paragraph quantitatively defines the term: potentially risk following the excerpt. Replace bullets with quantitative significant fire scenarios. Potentially risk the excerpt with "In PRA RAI 12, guidelines were not significant fire scenarios for the purpose of it is recognized that during some deleted as they form an evaluating the need for DID are defined as..." DID evaluations, it may become integral part of the SE and requires further clarification to detail its necessary to consider the are consistent with past application as detailed in PRA RAI 12. Also, it is potential for risk significant fire SEs.

recommended that the specific threshold be scenarios to impact VFDRs. In excluded from the SE as these are guidelines these cases, the licensee provide developed by Cooper Nuclear Station and not quantitative results from the mandated by NFPA 805 requirements. FPRA for the purpose of evaluating the DID for VFDRs.

20 SE Page The excerpt "Also, CNS has removed A reference to the documents Revised. The identified 74/Section unacceptable methods or committed to (i.e., as described in PRA RAI 40) sentence was deleted.

3.4.1.2 last updating the FPRA." does not provide the that specify actions required for paragraph required specificity to define what is meant by updating the FPRA should be "updating" the FPRA. provided in this paragraph.

21 SE Page The excerpt "Therefore, the NRC staff concludes Recommend replacing "FRE" Revised per comment.

75/Section 3.4.2 that the PRA should be capable of supporting with "Plant Change Evaluations".

last paragraph 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.

23 SE Page 81/1st Paragraph lists Fire Zones 8B, 8C, 8E, 8G, and Add Fire Zone 8F. Revised per comment.

full paragraph 8H from PRA-RAI 04.02, but does not include Fire Zone 8F, as described in PRA RAI 04.02.

24 SE Page 83/1st To better reflect the response to PRA RAI Make revision. Revised per comment.

full paragraph 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.

6

Comment Location Comment Suggested Disposition NRC Response Number 25 SE Page 86 / 2nd Fire Modeling Database should be replaced Correct throughout SE Revised per comment.

paragraph with Fire Modeling Workbook throughout and FMDB replaced with FMWB throughout SE.

26 SE Page 87 / The bullet Suppression activation time Remove bullet Suppression Revised per comment.

bullets under FDS calculation in specific fire areas was not used activation time calculation in at Cooper. specific fire areas 27 SE Page 91 / last Change transient height to 2 feet based on Make correction Revised per comment.

paragraph of SDP guidance.

page 28 SE Page 99/Table Fire Area TB-A Description contains buildings Remove Off Gas Building and Revised per comment.

3.4.6-2 (Off Gas Building and Optimum Water Optimum Water Chemistry from Chemistry) that are considered part of Fire Area the TB-A description as these YD, as described in the LAR B-3 Table for these buildings are considered part of Fire Areas. the YD. A revision to Attachment I of the LAR will be made to provide this clarification.

29 SE Page 104/ Fire Area TB-A Area Description contains Remove Off Gas Building and Revised per comment.

able 3.5-1 buildings (Off Gas Building and Optimum Water Optimum Water Chemistry from Chemistry) that are considered part of Fire Area the TB-A description as these YD, consistent with the LAR B-3 table. buildings are considered part of the YD. A revision to Attachment I of the LAR will be made to provide this clarification.

30 SE Page 109/1st First sentence indicates shielding for Fire Areas Correct sentence to include fixed Revised per comment.

partial paragraph CB-D and RB-m is for transient fires assumed in sources as adequate for the these fire areas. In Fire Area CB-D, the shielding fire duration of the transient and that has been installed is for fixed sources fixed source fires assumed (electrical panels). This is currently being installed.

31 SE Page 122/2nd For consistency with FAQ 10-0059, under Make addition Revised per comment.

paragraph under discussion of the scope of the monitoring indented text program add FPRA equipment.

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Comment Location Comment Suggested Disposition NRC Response Number 32 SE Page CNS does not use a Fire Modeling Database. Revise to read: "...were Revised per comment.

126/bullet at end Fire Modeling Database should be replaced implemented in a database and of page with Fire Modeling Workbook. workbook referred to as the Fire Modeling WorkbookDatabase (FMDBFMWB).

Replace FMDB with FMWB throughout SE.

33 SE Attachments Fire Modeling Database should be replaced Needs to be corrected Revised per comment.

A and B with Fire Modeling Workbook throughout and throughout both Attachments A FMDB. and B.

34 SE Attachment A Application at CNS - Second sentence does not Make corrections Revised per comment.

(pg. A2) Radiant read correctly. Revise to read "The correlation Heat Flux was used to determine the horizontal separation distance..."

V&V Basis for NUREG-1805 is Chapter 5 not Chapter 3 35 SE Attachment A V&V Basis for NUREG-1805 is Chapter 2 not Make correction Revised per comment.

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

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

(pg. A3) Hot Gas Chapter 3 Layer FPA 38 SE Attachment A V&V Basis for NUREG-1824 is Volume 4 not Make correction Revised per comment.

(Pg. A4) Ceiling Volume 3 Jet Temperature 8

Comment Location Comment Suggested Disposition NRC Response Number 39 SE Attachment A V&V Basis for NUREG-1805 is Chapter 10 not Make correction Revised per comment.

(Pg. A4) Sprinkler Chapter 3 Activation Correlation 40 SE Attachment A V&V Basis for NUREG-1805 is Chapter 11 not Make correction Revised per comment.

(Pg. A5) Heat Chapter 3 Detector Actuation V&V Basis for NUREG-1824 is Volume 4 not Correlation Volume 3 Remove SFPE Handbook discussion from the V&V Basis as this is related to smoke detector actuation.

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

9

Comment Location Comment Suggested Disposition NRC Response Number 41 SE Attachment A The smoke detector correlation is based on the Make correction Revised per comment.

(pg. A6) Smoke ceiling jet correlation of Alpert and the 10°C rise Detector is the Method of Heskestad and Delichatsios.

Actuation 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 2nd bullet to The correlation is validated in authoritative publications of the NFPA and SFPE Handbooks.

42 SE Attachment B V&V Basis for NUREG-1824 is Volume 7 not Make correction Revised per comment.

(pg. B1) FDS for Volume 3 MCR NRC Staff Evaluation - Add is between abandonment time calculations and acceptable. in last sentence.

43 SE Attachment B V&V Basis for NUREG-1824 is Volume 7 not Make correction Revised per comment.

(pg. B2) Volume 3 Temperature Sensitive Equipment ZOI 10

Comment Location Comment Suggested Disposition NRC Response Number 44 SE Attachment B V&V Basis for NUREG-1824 is Volume 7 not Make correction Revised per comment.

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

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

(pg. B4) Volume 3 Temperature sensitive hot gas Application at CNS - Change equipments to layer equipment.

47 SE Attachment C CNS does not use a Fire Modeling Database Replace duplicated FMDB Revised per comment.

(FMDB) (see Comments32 and 33) acronyms with FMWB (Fire Modeling Workbook).

11