ML13127A395

Nine Mile Point, Unit 1, License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) - Response to NRC Rai. Part

ML13127A395
Person / Time
Site:	Nine Mile Point
Issue date:	04/30/2013
From:	Costanzo C R Constellation Energy Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME8899
Download: ML13127A395 (3)

Text

This letter forwards Security-Related Information in accordance with 10 CFR 2.390. The balanceof this letter may be considered non-Security Related Information upon removal of Enclosure 6.Christopher R. CostanzoVice President-Nine Mile PointCENG.a joint venture ofOcnsear 6gyeDFP.O. Box 63Lycoming, New York 13093315.349.5200315.349.1321 FaxNINE MILE POINTNUCLEAR STATIONApril 30, 2013U.S. Nuclear Regulatory CommissionWashington, DC 20555-0001ATTENTION:

REFERENCES:

Document Control DeskNine Mile Point Nuclear StationUnit No. 1; Docket No. 50-220License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805,Performance-Based Standard for Fire Protection for Light Water Reactor ElectricGenerating Plants (2001 Edition) -Response to NRC Request for AdditionalInformation (TAC No. ME8899)(a) Letter from K. Langdon (NMPNS) to Document Control Desk (NRC), datedJune 11, 2012, License Amendment Request Pursuant to 10 CFR 50.90:Adoption of NFPA 805, Performance-Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants (2001 Edition)(b) Letter from B. Vaidya (NRC) to K. Langdon (NMPNS), dated January 3, 2013,Nine Mile Point Nuclear Station, Unit No. 1 -Request for Additional InformationRegarding License Amendment Request for Adoption of NFPA 805 (TAC No.ME8899)(c) Letter from C. R. Costanzo (NMPNS) to Document Control Desk (NRC), datedFebruary 27, 2013, License Amendment Request Pursuant to 10 CFR 50.90:Adoption of NFPA 805, Performance-Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants (2001 Edition) -Response toNRC Request for Additional Information (TAC No. ME8899)This letter forwards Security-Related Information in accordance with 10 CFR 2.390. The balanceof this letter may be considered non-Security Related Information upon removal of Enclosure 6.1Z-oI Document Control DeskApril 30, 2013Page 2Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested bythe NRC in support of a previously submitted request for amendment to Nine Mile Point Unit 1 (NMP 1)Renewed Operating License DPR-63. The initial request, dated June 11, 2012 (Reference a), proposed theadoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis whichcomplies with the requirements in 10 CFR 50.48(a) and 10 CFR 50.48(c); the guidance in RegulatoryGuide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water NuclearPower Plants," Revision 1; and National Fire Protection Association (NFPA) 805, "Performance-BasedStandard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition.The supplemental information provided in Enclosure 1 to this letter responds to the following threerequests for additional information (RAIs) documented in the NRC's letter dated January 3, 2013(Reference b): Safe Shutdown / Circuit Analysis RAI 01, RAI 03, and RAI 07. As stated in Reference (b),NMPNS agreed to provide responses to these three RAIs by April 30, 2013. Associated revisions to theoriginally submitted Transition Report, including the Attachment W Fire PRA insights and results, areprovided in Enclosures 3 through 6.The responses to Safe Shutdown / Circuit Analysis RAI 01 and RAI 03 note that NMPNS has elected tomodify its NFPA 805 transition analysis for NMP 1 to revise the approach for demonstrating the ability toreach and maintain safe and stable conditions, as specified by NFPA 805. The original Nuclear SafetyCapability Assessment (NSCA) established as its basis for demonstrating safe and stable conditions therequirement to maintain Kff < 0.99 with a reactor coolant temperature at or below the requirements forhot shutdown and then subsequently cool down and maintain the plant in a cold shutdown condition.Consistent with NFPA 805 and supplemental guidance, NMPNS is revising its basis for the NMP1 NSCAto include only the requirement to establish hot shutdown conditions, including long-term hot shutdowncapability. The Fire Probabilistic Risk Assessment (PRA) has been re-quantified and the delta riskparameters have been re-calculated to incorporate this revised safe and stable analysis basis. Alsoincluded in the Fire PRA re-quantification are the affects associated with the responses to ProbabilisticRisk Assessment RAIs (where applicable) that were previously provided in Reference (c).In addition, by letter dated February 27, 2013 (Reference c), NMPNS provided responses to requests foradditional information documented in Reference (b). In the February 27, 2013 letter, NMPNS committedto provide updates to the responses for Probabilistic Risk Assessment RAI 05 and Probabilistic RiskAssessment RAI 08 (if needed) to reflect the response to Safe Shutdown / Circuit Analysis RAI 01. Theupdated responses to these two RAIs are provided in Enclosure 2.Enclosure 6 contains security-related sensitive information and is requested to be withheld from publicdisclosure under 10 CFR 2.390 and in accordance with Regulatory Issue Summary 2005-26, "Control ofSensitive Unclassified Nonsafeguards Information Related to Nuclear Power Reactors." A redactedversion of the information in Enclosure 6 with the security-related sensitive information removed isprovided in Enclosure 5.This supplemental information does not affect the No Significant Hazards Determination analysisprovided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy ofthis supplemental information to the appropriate state representative. This letter contains no newregulatory commitments.

Document Control DeskApril 30, 2013Page 3Should you have any questions regarding the information in this submittal, please contact J. J. Dosa,Director Licensing, at (315) 349-5219.I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30, 2013.Very truly yours,CRC/DEV

Enclosures:

1. Nine Mile Point Unit 1 -Response to NRC Request for Additional InformationRegarding the Proposed Adoption of NFPA 805 (2001 Edition)2. Nine Mile Point Unit 1 -Updated Responses to Probabilistic Risk Assessment RAI05 and RAI 083. Revisions to the LAR Transition Report with Changes Highlighted4. Revisions to the LAR Transition Report, Re-Typed with Changes Incorporated5. Revisions to the Redacted Version of the LAR Transition Report, Attachment C andAttachment W6. Revisions to the Non-Redacted Version of the LAR Transition Report, Attachment Cand Attachment Wcc: Regional Administrator, Region I, NRC (w/o Enclosure 5)Project Manager, NRCResident Inspector, NRC (w/o Enclosure 5)A. L. Peterson, NYSERDA (w/o Enclosure 6)