NL-12-1893, Joseph M. Farley Nuclear Plant, Units 1 and 2 - Supplemental Information Needed for Acceptance of Requested Licensing Action Concerning Voluntary Fire Protection Risk Initiative Request (TAC Nos. ME9741 and ME9742)(NL-12-1893)
| ML12345A398 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 12/12/2012 |
| From: | Brown E A Plant Licensing Branch II |
| To: | Ajluni M J Southern Nuclear Operating Co |
| Brown E A | |
| References | |
| NL-12-1893, TAC ME9741, TAC ME9742 | |
| Download: ML12345A398 (5) | |
Text
UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 December 12, 2012 Mr. M. J. Nuclear Licensing Southern Nuclear Operating Company, P. O. Box Bin -Birmingham, AL JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 -
INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED ACTION CONCERNING VOLUNTARY FIRE PROTECTION RISK REQUEST (TAC NOS. ME9741 AND ME9742)
Dear Mr. Ajluni:
By letter dated September 25, 2012, the Southern Nuclear Operating Company (SNC or the licensee) submitted a license amendment request for Joseph M. Farley Nuclear Plant, Units 1 and 2. The proposed amendment requests the review and approval for adoption of a new fire protection licensing basis which complies with the requirements in Sections 50.48(a) and 50.48(c) to Title 10 of the Code of Federal Regulations (10 CFR), and the guidance in Regulatory Guide 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this [amendment/relief]
request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant. Consistent with 10 CFR 50.90 an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications.
Section 50.34 of 10 CFR addresses the content of technical information required.
This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and prinCipal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment/relief request in terms of regulatory requirements and the protection of public health and safety and the environment.
M. Ajluni -2 In order to make the application complete, the NRC staff requests that SNC supplement the application to address the information requested in the enclosure by December 26,2012. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application.
If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and associated timeframe in this letter were discussed with Mr. Ken McElroy of your staff on December 7,2012. If you have any questions, please contact me by phone (301) 415-2315 or email at Eva.Brown@nrc.gov. Sincerely, IRA! Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: Distribution via Listserv SUPPLEMENTAL INFORMATION NEEDED VOLUNTARY FIRE PROTECTION RISK INITIATIVE SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364 As discussed in Attachment A to the submittal dated September 25, 2012 (Agencywide Documents Access and Management System) Accession No. ML 12279A235), the Electrical Raceway Fire Barrier System (ERFBS) Table B-1, Element 3.11.5 states "[c]omplies" as meeting the requirements of Chapter 3. Table B-1 also states that required ERFBS is identified in Table 4-3 (Attachment C, Table C-2), but ERFBS is never identified as a required feature in this table. Clarify if ERFBS is a required fire protection feature at Joseph M. Farley Nuclear Plant, Units 1 and 2. If so, identify the fire area locations where ERFBS is being credited.
If new ERFBS modifications will be installed, then identify those as well. Recovery actions are identified as the resolution of certain variances from the deterministic requirements (VFDRs) by fire area in Attachment C Table B-3 to the submittal.
However many of the recovery actions required for VFDR resolutions do not appear to be included in Attachment G Table G-1. Clarify whether Attachment G identifies all recovery actions credited in Attachment C Table B-3 VFDR resolutions.
If not, provide the additional recovery actions. Additionally, recovery actions in Attachment G do not identify the associated VFDRs. In some cases, the recovery actions can be traced back to the associated VFDRs by searching component numbers described in the action with those in the VFDR, but in many cases the correlation between recovery action and VFDR resolution cannot be Provide a revised Table G-1 that associates the recovery actions with the appropriate VFDR being resolved. Section 4.2.1.2 of the submittal states that "safe and stable ... assumes the plant to be taken subcritical and maintained in anyone of the modes of hot standby, hot shutdown, cold shutdown, or refueling conditions." However, the performance goals listed in Attachment C Table B-3 appear to show achievement of only hot shutdown goals, not cold shutdown or refueling.
Clarify the safe and stable condition for the plant. If cold shutdown, explain why the Nuclear Safety Capability Analyses and fire risk evaluations do not include this equipment. Attachment STable S-2 Item #11 to the submittal identifies a proposed modification to "install a new code compliant fire detection system and provide a code compliance evaluation to support the new system." Provide a more explicit description of this modification.
Address whether there will only be detectors, or will it also include new local and main panels. Discuss whether this is intended to be installed throughout the plant. Provide the version of the National Fire Protection Association (NFPA)-72, Enclosure
-"National Fire Alarm and Signaling Code," will be used for this new system. It appears that Attachment C, Table C-2 (Table 4-3) identifies detection used in each fire area/zone where it is credited for NFPA 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants." Address whether this table is based on existing detection or the new detection system, or both. Address whether Table V-2 includes all supporting requirements identified as either capability category (CC)-I or not met by the peer review. In doing so, clearly identify those SRs being carried forward as CC-I (or not met), and provide justification as to why dOing so is acceptable for transition. Provide the results (i.e., core damage frequency (CDF), large early release frequency (LERF), delta CDF, and delta LERF) of an aggregate sensitivity analYSis that removes both the credit given to Very Early Warning Fire Detection Systems (VEWFDS) in the main control room as well as that associated with electrical panel factors discussed in Attachment V,Section V.2.1.2 of the submittal.
In addition, identify any additional Unreviewed Analysis Methods (UAMs) employed within the fire probabilistic risk assessment, and incorporate all such UAMs within the aforementioned aggregate sensitivity study. Provide justification of how the Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," risk acceptance guidelines are satisfied. Section 5.5 and Attachment S of the submittal proposes a completion schedule for plant modifications of November 6, 2017. Provide justification for this schedule.
M. Ajluni -In order to make the application complete, the NRC staff requests that SNC supplement the application to address the information requested in the enclosure by December 26,2012. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application.
If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and associated timeframe in this letter were discussed with Mr. Ken McElroy of your staff on December 7,2012. If you have any questions, please contact me by phone (301) 415-2315 or email at Eva.Brown@nrc.gov. Sincerely, IRA! Eva A Brown, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL2-1 Reading File RidsAcrsAcnw_MailCTR Resource RidsNrrDraAfpb Resource RidsNrrDraAPLA Resource RidsNrrDorl Resource RidsNrrDorlDpr Resource RidsNrrDorlLp2-1 Resource RidsNrrLASFigueroa Resource RidsNrrPMFarley Resource RidsOgcRp Resource RidsRg2MailCenter Resource LFields DPickett DBroaddus ADAMS Accession No ML 12345A398 OFFICE DORU2-1/PM DORULPL2-1/LA DORULPL2-1/BC NAME EBrown SFigueroa RPascarelli DATE 12/12/12 12/12/12 12112112 OFFICIAL RECORD COpy