ML11227A257

Watts Bar, Unit 2 - Request for Additional Information (RAI) Group 6 Regarding Fire Protection Report (TAC No. ME3091)

ML11227A257
Person / Time
Site:	Watts Bar
Issue date:	08/05/2011
From:	Stinson D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME3091
Download: ML11227A257 (90)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000August 5, 201110 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555-0001Watts Bar Nuclear Plant, Unit 2NRC Docket No. 50-391

Subject:

WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 -REQUEST FORADDITIONAL INFORMATION (RAI) GROUP 6 REGARDING "FIREPROTECTION REPORT" (TAC NO. ME3091)

Reference:

1. NRC Letter to TVA dated July 21, 2011, "Watts Bar Nuclear Plant, Unit 2 -Request for Additional Information Regarding Final Safety Analysis ReportAmendment Related to Section 9.5.1 'Fire Protection System' Group 6(TAC NO. ME3091)"2. TVA Letter to NRC dated July 22, 2011, "Watts Bar Nuclear Plant (WBN), Unit 2-Corrosion Related Portion of NRC's Request for Information Regarding FinalSafety Analysis Report Amendment Related to Section 9.5.1 'Fire ProtectionSystem' Round 6 (TAC NO. ME3091)"The purpose of this letter is to respond to the remaining NRC's RAIs pertaining to WBNUnit 1/Unit 2 Fire Protection Report contained in Reference 1. At NRC's request, WVA hasalready provided responses to the corrosion related RAls in its letter dated July 22, 2011(Reference 2). This letter also responds to NRC's questions received during the July 28, 2011public meeting that was held to discuss the Group 6 Fire Protection System RAls. Newquestions received from NRC during the public meeting have been added to the correspondingRAls and identified as: "NRC Follow-up Questions provided in July 28, 2011 Public Meeting."In some cases the Reference 2 responses have been revised/amplified to provide clarificationbased on the meeting. In all of these cases, TVA's response addresses the original and thefollow-up questions. It should be noted that the revised responses to those "corrosion related"questions that were previously submitted in Reference 2 have been added such that therevised responses address the follow-up questions for those RAls.Enclosure 1 to this letter provides TVA's responses to NRC's Group 6 questions, as well asrevised responses to address NRC's follow-up questions. Enclosure 2 provides the newRegulatory Commitments contained in this letter.

U.S. Nuclear Regulatory CommissionPage 2August 5, 2011In addition, as requested by NRC, Enclosure 3 provides a summary listing of fire protectioncommitments contained in TVA's submittals. This summary listing contains a description of thecommitment, the status (open or closed), as well as pertinent references (initiating, closing,etc.,).If you have any questions, please contact William Crouch at (423) 365-2004.I declare under the penalty of perjury that the foregoing is true and correct. Executed onthe 5th day of August, 2011.Respectfully,David StinsonWatts Bar Unit 2 Vice President

Enclosures:

1. Response to NRC's Request for Information Regarding "Fire Protection Report"2. Regulatory Commitments3. Summary Listing of Fire Protection Commitmentscc (Enclosures):U. S. Nuclear Regulatory CommissionRegion IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257NRC Resident Inspector Unit 2Watts Bar Nuclear Plant1260 Nuclear Plant RoadSpring City, Tennessee 37381 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"

Reference:

1. NRC Letter to TVA dated July 21, 2011, "Watts Bar Nuclear Plant, Unit 2 -Request for Additional Information Regarding Final Safety Analysis ReportAmendment Related to Section 9.5.1 'Fire Protection System' Group 6(TAC NO. ME3091)"2. TVA Letter to NRC dated July 22, 2011, "Watts Bar Nuclear Plant (WBN), Unit 2-Corrosion Related Portion of NRC's Request for Information Regarding FinalSafety Analysis Report Amendment Related to Section 9.5.1 'Fire ProtectionSystem' Round 6 (TAC NO. ME3091)"The following provides TVA's response to the referenced NRC requests for additionalinformation (RAI) pertaining to the WBN Unit 2 Fire Protection Report (FPR).NRC's numbering system will be referenced to identify each question. Some NRC questionshave been subdivided for clarity of response. Additionally, new questions received from NRCduring the July 28, 2011 public meeting have been added to the appropriate RAI and identifiedas: "NRC Follow-up Questions provided in July 28, 2011 Public Meeting." In some cases, theReference 2 responses have been revised/amplified to provide clarification based on themeeting. In all of these cases, TVA's response addresses NRC's original RAI and the follow-upquestions.1. NRC Question (RAI FPR I-1)Identify the meaning of the "*" notation in the "Combustible Load, Fire Severity" column ofTable I-1, "Summary Compliance Fire Protection," of the as-designed FPR. One example ofthe notation is in the "676.0-A 15 -U2 Containment Spray Pump 2B-B" entry.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The following will be added at the end of the table and will be included in the next FPRsubmittal.* Combustible load fire severity is assumed to be comparable to the corresponding Unit 1room. At the completion of construction, a walkdown of these rooms will be conducted toverify the in situ combustibles located in the rooms, and the Table will be revised asnecessary.2. NRC Question (RAI FPR 1-2)A sampling review of Table I-1, "Summary Compliance Fire Protection," of the as-designedFPR has identified the following:0 Deviations /Evaluations identified in Table I-I that are not reflected in Part VI.E1-1 ENCLOSURE IResponse to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"* Examples: Fire Areas 15-1 and 15-2* Cable protection indicated in Part VI not indicated in Table I-1.* Example: Fire Area 15-2* Manual actions identified in Part VI not indicated in Table I-1.* Example: Fire Area 15-2[1] Resolve these conflicts and 2) provide assurance that other, similar conditions havebeen identified and corrected.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] FPR Part I, Table I-1 and Part VI, Sections 3.21.1 and 3.22.1 have been revised tocorrect these conflicts and will be included in the next FPR submittal.[2] Table I-1 and other applicable parts of the FPR were reviewed to ensure consistencybetween the parts of the report, and corrections have been incorporated into each partof the FPR and will be included in the next FPR submittal.3. NRC Question (RAI FPR 11-23.1)The TVA response to RAI FPR 11-23 in its letter of May 6, 2011 (Agencywide DocumentsAccess and Management System (ADAMS) Accession No. MLI 1129A 158), did not addresswhere the responsibilities of the former "General Manager, Operations Services" weremoved to when TVA Corporate Management was reorganized.These responsibilities were specifically approved by the NRC in Supplemental SafetyEvaluation Report (SSER) 18. It does not appear that these responsibilities werespecifically distributed among the remaining identified positions.Describe where each of these responsibilities will reside for Unit 2 operation.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The responsibilities delegated to the General Manager, Operations Services, by the SeniorVice President for Nuclear Operations were reassigned to the individual Site VicePresidents. The General Manager is a former corporate position that no longer exists. TheGeneral Manager was responsible for the development and assessments of the FireProtection programs at the sites. As defined in Part II, Section 7.2, the Site Vice Presidentis responsible for the development, implementation and administration of the Fire ProtectionProgram. Assessments are a part of the administration of the program and are addressedE1-2 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"by the self-assessment program addressed in NPG-SPP-02. 1, "NPG Self-Assessment andBenchmarking Program."When Unit 2 becomes operational, it will be transferred from the responsibility of the NuclearGeneration, Development and Construction Operating Group to the Nuclear Power Groupand thus to the WBN Site Vice President.TVA has determined that the FPR does not require revision.4. NRC Question (RAI FPR 11-25.1)The TVA response to RAI FPR 11-25 in its May 6, 2011 letter does not appear to addressitem 3 of the RAI, which states, in part:The following text was removed from 8. 1.c:WBN may alter specific features of the approved Fire Protection Report provided:(a) such changes do not otherwise involve a change in a license condition or thetechnical specification or result in an unreviewed safety question, and (b) suchchanges do not result in failure to complete the Fire Protection Program [FPP] asapproved by NRC.Provide a justification for this change. Is it TVA's position that may make changes asdescribed in the deleted text without NRC approval? If so, describe the regulatory basis forchanging license conditions, technical specifications, etc., without NRC approval.TVA Response:Changes to the FPR are made in accordance with License Condition F of WBN's currentoperating license, issued February 9, 1996, which states:WVA shall implement and maintain in effect all provisions of the approved fireprotection program as described in the Fire Protection Report for the facility, asapproved in Supplements 18 and 19 of the SER (NUREG-0847) subject to thefollowing provision:TVA may make any changes to the approved fire protection program without priorapproval of the Commission, only if those changes would not adversely affect theability to achieve and maintain safe shutdown in the event of a fire.This License Condition is a higher tier requirement than the FPR and thus the wording is notrequired in the FPR.The requirement to evaluate changes to a licensee's FPR under 10 CFR 50.59 wasexcluded by the amendment to the 10 CFR 50.59 rule on October 4, 1999. Therefore, FPRrevision 27 deleted the words associated with the need to evaluate in accordance withE1-3 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"10 CFR 50.59. In lieu of the 10 CFR 50.59 process, TVA adopted the evaluation process asdocumented in FPDP-3, "Management of the Fire Protection Report," which established theprocess to ensure compliance with the fire protection license condition. In addition, TVAimplemented NEI 02-03, "Guidance for Performing a Regulatory Review of ProposedChanges to the Approved Fire Protection Program," to be aligned with the rest of theindustry. This NEI has been incorporated into a corporate procedure, NPG-SPP-03.6, "FireProtection Program Change Regulatory Reviews," which is in accordance with theapplicable sections of NEI 02-03. The evaluation process ensures TVA remains compliantwith License Condition F of the WBN operating license.NRC's review of NEI 02-03 documented in letter dated August 27, 2003, indicated that theStaff had no comments, but made the following two points regarding the change process:" Changes to the Approved Fire Protection Program (AFPP) must be in accordance withthe applicable rules and the plant's specific licensing basis." The guidance may be used to evaluate changes to the AFPP, but changes that wouldresult in noncompliance with the rules require NRC approval.NRC concluded that: "Using published guidance, such as NEI 02-03, for evaluating changesto the AFPP (Approved Fire Protection Program) should ensure consistent evaluations andwill improve the efficiency and effectiveness of the regulatory process."Based on the above discussion, TVA's position remains unchanged from the LicenseCondition F contained in the initial Unit 1 Operating License (i.e., TVA would seek NRCapproval for those changes determined to require prior approval in accordance with theNEI 02-03 process).5. NRC Question (RAI FPR 11-29.1)RAI 11-29 deals with the removal of information regarding the process in place to perform firedoor modifications from Part I/, Section 12.10.4, "Fire Doors," of the as-designed FPR. Inthe letter dated May 6, 2011, TVA states, in part:The FPR was never intended to provide all of the detailed information concerning theFire Protection Program, but rather to provide detailed Information, when required,and as a roadmap to direct the user of the FPR to other controlled documents, suchsupporting calculations, procedures, drawings, etc. [emphasis added]Because detailed information was removed and no roadmap was added, there is nothingthat would "direct the user of the FPR to other controlled documents, such as supportingcalculations, procedures, etc." in the current section.Resolve the conflict between the RAI response in the May 6, 2011, letter and the contents ofthe FPR section. Provide assurance that other, similar instances have been identified andresolved and that the level of detail in Part II is handled consistently between sections.E1-4 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"This RAI may involve an update to the FPR to incorporate the response to the RAI.NRC Follow-up Questions provided in July 28, 2011 Public Meeting:To be a roadmap the FPR needs to document references listed in FPR, Part If, Section 4.0,at the associated text write-up. Provide a roadmap of references to the associated text.TVA Response:A review of the first four sections of the FPR, Part II, provides the commitments WBN wasdesigned to, as well as, reference to some of the design level documents. These referencesinclude design input and output documents (e.g., calculations, system descriptions,drawings, etc.) which are to be used for the detailed information. These first four sectionscan be utilized as a "roadmap" to identify these commitments, as well as to the referencedspecific design details that satisfy these commitments. The other sections, like Section 12,provide an overview of how the committed documents were satisfied by the design, but werenot meant to be a point-by-point comparison similar to FPR, Part VIII, "Conformance toAppendix A to BTP 9.5-1 Guidelines."In addition, the FPR does not attempt to establish the processes by which equipment ismaintained and/or modified. These processes, such as NPG-SPP-06.1, "Work OrderProcess," for maintenance of the plant equipment in accordance with design output, andNPG-SPP-09.3, "Plant Modifications and Engineering Change Control," for modification toplant equipment under configuration control via design output, are fundamental to all plantequipment under configuration control. Plant employees are trained in the use andadherence to these processes before working on equipment under configuration control toensure safe operation of the plant.To be specific, the information removed from FPR, Part II, Section 12.10.4, "Fire Doors,"stated the following:Modifications to fire doors must be within accepted criteria or approved by a FireProtection Engineer.This information is addressing modification which is covered by NPG-SPP-09.3, "PlantModifications and Engineering Change Control." Under the modification process the designchange notice indicating that fire protection is affected will receive a review that includes aFire Protection Engineer. At the time of Unit 1 fuel load, this process to have a FireProtection Engineer review and approve every design change notice was not as defined asit has become now with the advent of guidance from the NRC and NEI. Thus, this removedstatement duplicated information that was proceduralized and required by other guidanceand was no longer needed.The remaining information of this paragraph provides the bases for special requirementsplaced in the implementing documents (e.g., NPG-SPP-06.1 and/or sub tier procedures) toensure the maintenance process achieves the committed level of review.E1-5 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Reqarding"Fire Protection Report"In conclusion, the FPR is a part of the FSAR by reference and as such there is not a directtie (e.g., cross reference) between the FPR statements to the implementing documents asthere is not a direct tie from FSAR statements and associated implementing document. Butthe unique and specific requirements needed for the Fire Protection program are stated inthe FPR to ensure maintenance of the program and provide a single source of review toensure changes to the program meet regulatory commitments.TVA has determined that the FPR does not require revision.6. NRC Question (RAI FPR 11-31.1)The TVA response to RAI FPR 11-31 in the May 6, 2011, letter states that once a piece ofinoperable equipment is placed in the corrective action program, "management attention"will drive TVA to return that piece of equipment to operable status. Reliance on a conceptsuch as "management attention," which is poorly defined and outside of an establishedprocess, does not fully address the RAI.Describe the process in place to ensure that equipment is returned to operable status in atimely manner.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The process of returning inoperable equipment, fire protection or safety related, to Operablestatus is controlled by established procedures. The process begins with the initiation of aservice request in accordance with NPG-SPP-01.14, "Service Request Initial Review" by theindividual observing the deficient condition. The service request is reviewed by a groupknowledgeable in the areas of Operations, Corrective Action Program, Work Managementand/or Engineering to determine if a work order and/or a corrective action document shouldbe initiated for the condition. The material conditions aspects of the service request will beaddressed by the work order that is initiated.The work order will then be reviewed by the work order review group which has a minimumrequired attendance of Operations, System Engineering, Maintenance, and Security. Thisgroup will determine the priority of the work order in accordance with the establishedprocedural guidelines of NPG-SPP-07.1, "On Line Work Management."Through this process, Operations will address the time out of service allowed by the FPR, aswell as the effect on protection of safe shutdown equipment.Should the equipment not be restored as Operations deems appropriate, then otherprocesses are in place to allow Operations to place emphasis on the correction of thedeficiency, including placing the work order in the Team Alignment Package, which isreviewed by the WBN management team each week day.E1-6 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"Should the deficiency not be corrected within the time specified by the FPR, then anotherservice request is initiated which will become a corrective action document to address thereportability reviews in accordance with 10 CFR 50.72 and 10 CFR 50.73. This secondservice request causes plant management, especially Operations, attention and review ofthe work order status to determine why the work was not completed within the time framerequired in the FPR.The above process is the same process for all plant equipment whether it is safety related,Tech. Spec., Fire Protection, etc., to ensure management review and to prioritize the workbased on risk.TVA has determined that the FPR does not require revision.7. NRC Question (RAI FPR 11-37.1)The TVA response to RAI FPR 11-37 in the May 6, 2011, letter states, in part: "Section 14.1.1addresses the areas outside of containment and 14.1.2 addresses the areas insidecontainment."However, section 14.1.1 applies only to accessible areas. Also, Section B. 14.1.2 stillsupports the earlier version.* [1] Confirm that no Function A fire detectors are installed in inaccessible areas outsideof containment.* [2] Correct the Basis entry to align with the correct configuration.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] There are Function A fire detectors located in inaccessible areas outside of the Unit I orUnit 2 Containments.[2] The FPR will be clarified to update the verbiage for these fire detectors and will beincluded in the next FPR submittal.8. NRC Question (RAI FPR 11-39.1)In the prior RAI FPR 11-39, the staff asked about the compensatory actions to be taken in theinitial period of inoperable status for safe shutdown equipment listed in Table 14.10. Whilethe TVA response in the May 6, 2011, letter states that the current configuration wasapproved by the NRC in SSER 18 (ADAMS No. ML070530364), Appendix A to the BranchTechnical Position (B TP) and Appendix R to Title 10 of the Code of Federal Regulation PartE1-7 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"50 require licensees to be able to achieve and maintain safe shutdown after a fire. In light ofthis, the NRC Staff has these follow-up requests:S([1] Describe the process in place that ensures the plant can achieve and maintain safeshutdown after a fire, for the scenario where one or more pieces of equipment areinoperable, and the remaining redundant piece of equipment is damaged by the fire.[2] Describe the process in place that ensures the plant can achieve and maintain safeshutdown after a fire, when all redundant equipment, as listed in Table 14. 10, isinoperable at the same time. One example would be all power operated relief valve(PORV) N2 supply tanks are concurrently depressurized.[3] Describe the process in place to take into consideration equipment inoperability whenplanning maintenance or testing activities on a piece of equipment that is redundant toone that is inoperable. Describe any expected compensatory measures for this sort ofscenario.* [4] Describe the process in place to prevent a piece of required equipment fromrepeatedly being declared inoperable. Describe the process used to identify thiscondition and to prevent reoccurrence.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The Appendix R analysis has developed a shutdown logic diagram for a postulated fireand identified the process "end devices" and instrument loops that are required for safeshutdown. The equipment is arranged in functional groups called "keys" and is logicallyinter-tied such that it supports the shutdown logic diagram. Spurious actuations and theneed to shut the plant down from the Auxiliary Control Room System have beenconsidered. A complete list of equipment and electrical cable required for safe shutdownhas been compiled. The analysis has: (1) determined the safety functions required toachieve safe shutdown following a postulated fire, and (2) identified the process systemsand devices which must operate to accomplish the safety functions or must not fail in amanner which would otherwise defeat the safety functions. The analysis for anAppendix R Fire event considers (1) no other design basis events are considered tooccur as initiating events or during the subsequent shutdown duration concurrently witha postulated fire except for the loss of offsite power, (2) all equipment is assumed to bein its normal configuration and operating within the limits provided for by the unitTechnical Specifications when the fire is postulated, (3) safe shutdown circuits,equipment, instrument sense lines, and associated circuits are assumed to be damagedif they are in the zone of influence of the fire, and (4) no equipment failures other thanthose directly attributable to the fire are considered. It is noted that the Appendix Requipment listed on Table 14.10 is required for Fire Safe Shutdown (FSSD) and shall beOperable (or in its FSSD condition) when the unit is in modes 1, 2, and 3. With one orE1-8 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"more required pieces of equipment in Table 14.10 inoperable (or not in its FSSDcondition), it must be restored to operable status (or its FSSD condition) within 30 days.Appendix R requires a plant to analyze/identify the equipment required to mitigate firesin the various areas of the plant. Based on this analysis, WBN identifies a single FSSDpath for each fire area. Consequently, for any given fire, the redundant equipment ismaintained free of fire damage. Appendix R does not require a plant toidentify/protect/compensate for a FSSD path that is temporarily out of service. If aportion of a safe shutdown path cannot perform its function, the plant enters theprocesses described in Question 6 (RAI FPR 11-31.1) above in order to restore the fireprotection capability in a timely manner. This process minimizes the risk due toequipment out of service by ensuring timely management attention.[2] See response to sub question [1] above for NRC Question (RAI FPR 11-39.1)[3] Testing and maintenance of safety-related and non-safety-related equipment isperformed on a train/channel basis. There are two trains of equipment, A train andB train, and four channels, 1, 11, 111, and IV. Equipment that is not trained or channelspecific is working in the associated train/channel week of associated equipment orarea. These break up into a 13 week rolling work week schedule of A train, Channel I;A train, Channel Ill; B train, Channel II; and B train, Channel IV. Note that the 13th weekis a non-train, non-channel week. The 13 week rolling work week schedule is reviewedperiodically starting at 26 weeks out for several aspects including risk and inoperableopposite train equipment. Inoperability of safety-related equipment relied upon for fireprotection purposes is controlled in accordance with the plant's TechnicalSpecifications. Similarly, plant process (e.g., main steam PORV nitrogen tanks that arenot Technical Specification driven but are relied upon for FSSD) and fire protectionequipment which is not addressed by the plant's Technical Specifications is controlled inaccordance with FPR Part II, Section 14.0. If Operations determines the risk is too greator if there is a concern about opposite train equipment, the work is deferred orEngineering is consulted for alternate capabilities.[4] The process of returning inoperable equipment, fire protection or safety-related, toOperable status is controlled by established procedures. The process begins with theinitiation of a service request in accordance with NPG-SPP-01.14, "Service RequestInitial Review," by the individual observing the deficient condition. The service request isreviewed by a group knowledgeable in the areas of Operations, Corrective ActionProgram, Work Management and/or Engineering to determine if a work order and/or acorrective action document should be initiated for the condition. The material conditionsaspect of the service request will be addressed by the work order that is initiated. Thework order will then be reviewed by the work order review group which has a minimumrequired attendance of Operation, System Engineering, Maintenance, and Security.This group will determine the priority of the work order in accordance with theestablished procedural guidelines of NPG-SPP-07.1, "On Line Work Management."Throughout this process, the appropriate System Engineer will be addressing theequipment reliability via the System Health Report required by NPG-SPP-09.16.1,E1-9 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report""System, Component and Program Health." Such a condition could result in a concernin several different areas on the System Health Report such as:1. Operator Work Arounds2. Control Room Deficiencies3. Auxiliary Unit Operator (AUO) Round Deficiencies4. Disabled Annunciators5. Top Equipment Issues6. Recurring Equipment Problems7. Critical Component Failures8. Deferred Preventative MaintenanceAnother method is Operations could enter the activity in the Team Alignment Packagethat the site management reviews every week day.TVA has determined that the FPR does not require revision.9. NRC Question (RAI FPR 11-41.1)RAI FPR 11-41 noted that there is no information in Part II, Section 12.2 "Standpipes, HoseStations, and Hydrants," of the as-designed FPR, regarding the seismic qualification of thestandpipes and hose stations installed to protect areas containing Unit 2 safe shutdownequipment.The TVA response to RAI FPR 11-41 (in the June 7, 2011, TVA letter) does not fully coverthe seismic requirements for standpipes and hose stations.These seismic requirements are in place not only to ensure that no required equipment isdamaged by water leaks, but also to ensure that fire-fighting capability is maintained after anearthquake.Provide details regarding the seismic qualification of the standpipe and hose stationsystems, as well as the water supply system that supplies it, that are installed in areascontaining Unit 2 safe shutdown equipment.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:Piping located in Category I structures has been analyzed to meet the requirement ofpressure boundary requirements during a seismic event and thus would be capable ofsupplying water for firefighting following a seismic event.El-10 ENCLOSUREIResponse to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"10. NRC Question (RAI FPR 11-43)In Part I of the as-designed FPR, the key of the "Inaccessible Areas" Table has beenreversed.Revision 41 of the FPR [pg. I/-I 1]:* Inaccessible only during resin transfer.(FPR-Preparer)**Refer to Part VII for engineering evaluation.As-designed FPR [pg 11-12]:** Inaccessible only during resin transfer.*Refer to Part VII for engineering evaluation.The instances or "*" or .... in the body of the table were not changed.In the March 31, 2011, letter, TVA described this change as "Corrected the application of thenotes. No effect on FSSD [Fire Safe Shutdown]." Examination of the balance of the FPRindicates that the original configuration was correct. For example, it is clear that the roomsmarked with "**" in the as-designed version are inaccessible permanently, not just duringresin transfer.The reviewers are concerned about this change since it appears unrelated to any NRCquestion. Additionally, if the change is correct, this indicates that the current Unit I FPR isin error.Justify the change (including the current FPR configuration for Unit 1) or correct the error.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The information from Revision 41 of the FPR is correct. The rooms that are "Inaccessibleonly during a resin transfer" should have a single "*." The rooms that are "Refer to Part VIIfor engineering evaluations," should have a double "*." This has been corrected and willshow the correct information in the next "As-Designed" FPR submittal.11. NRC Question (RAI FPR 11-44)Part II, Section B. 14.2.f of the as-designed FPR, states, in part: "Flow test are made atflows representative of those expected during a fire..."Provide information regarding how full flow testing of the Train A and Train B high pressurefire protection system headers is accomplished.El-11 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"This RAI may involve an update to the FPR to incorporate the response to the RAI.NRC Follow-up Questions provided in July 28, 2011 Public Meeting:Part II, Section B. 14.2.f of the as-designed FPR states flow tests are made at flowsrepresentative of those expected during a fire. Sprinkler system hydraulic calculationsinclude an allowance for fire hose flow with the sprinkler system flow. How does the flowtest account for the additional flow for the fire hose?TVA Response:The HPFP system is designed to be common to all areas of the site to support fighting anyfire that was to occur onsite. Thus, the HPFP system is interconnected in several locationsresulting in multiple loops to ensure proper operation of the system. To test this commonsystem, individual flow points have been selected on the HPFP system, which results in flowthrough the Train A and Train B HPFP headers.Part II, Section B.14.2.f provides additional information to the testing requirements providedin the Testing and Inspection Requirements (TIR) 14.2.f. The testing of TIR 14.2.f requiresflow tests of the system. The TIR bases, B.14.2.f, calls for this testing to compare the frictionloss characteristics of the piping to previous tests. To address B.14.2.f, WBN uses multiplerepresentative flow points in different areas of the HPFP system to give an indication of thecondition of the HPFP system piping.The allowance for fire hose flow is not addressed in the flow tests for sprinkler systems withinstalled test headers that are tested as a part of TIR 14.2.f. The hose station flow pathsfrom the main header are hydraulically separate from the main header to sprinkler flowpaths and thus the hose stations do not impose hydraulic loads on the sprinkler paths. Dueto the relative size of the main header compared to the branches for the hose station and/orsprinklers, operation of the sprinklers and hose stations does not challenge the flowcapability of the main header.A more detailed discussion is provided in TVA's letter to the NRC dated July 22, 2011, titled"Watts Bar Nuclear Plant (WBN) Unit 2 -Corrosion Related Portion Of NRC's Request ForAdditional Information (RAI) Round 6 Regarding 'Fire Protection Report' (TAC No.ME3091)." Specifically, TVA's response to NRC Question (RAI FPR VII-2.2) addressed howthe system is tested and trended to determine the status of the system/piping.TVA has determined that the FPR does not require revision.12. NRC Question (RAI FPR 11-45)Based on the presentation at the June 30, 2011, public meeting, there was some confusionfor both the reviewers and the TVA participants regarding the specific configuration of theWBN fire water system.El-12 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"[1] Provide a detailed description of the high pressure fire protection system configuration.The description should include, but not be limited to the following:* Both safety-related and nonsafety-related portions of the system.* The piping materials that comprise the various system sections.* Typical flows experienced by the main sections of the system (for example the commonheader, yard loop, A and B train headers, etc.).* Interconnections between the A and B train safety-related headers.* Nonfire protection loads on the fire water system and from which portion of the systemthey are fed.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The FPR, Part II, Section 12 and Figures II-1A to 11-24A provides the design overview of theHPFP system including relative position of equipment, set points, pump capacity, logic, etc.,to support the following operational discussion. Additional details are provided in the FPR,Part II, Reference 4.2.4.Attached is a simplified sketch of the majority of the HPFP system. This sketch does notshow the loop that serves the Training Center and the warehouses to the north of theProtected Area. The A train, the B train, and the main common headers are shown. Inaddition, there is a loop inside the Turbine Building and a loop inside the Auxiliary Building.The Turbine and Auxiliary Building loops are intertied in two diverse locations at theinterface of the Turbine and Auxiliary Buildings. The Turbine Building loop is connected tothe yard loops at two locations and has one connection to the Service Building. Duringnormal operation, the system is interconnected with all sectionalizing valves open.Unlined carbon steel piping is used for the buried trained headers and all interior piping. Theburied carbon steel piping is provided with an exterior coating to protect from corrosion. Theburied common headers use cement lined ductile iron piping.During the design bases flood, sectional valves are closed to ensure the Train A and Bheaders are established to support the safety function of the fire protection system toprovide Auxiliary Feedwater. The buried trained headers enter the Auxiliary Building onopposite sides and connect to the Auxiliary Build HPFP header loop. When the sectionalvalves are closed for flood mode, the ties to the Turbine Building are isolated and the supplyfrom the buried trained headers is sectionalized to A train and B train and both can supplyAuxiliary Feedwater.El-13 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"During normal day-to-day operation, there are select service water flows to specificequipment such as HVAC chillers, the demineralized water purification process equipment,auxiliary boiler feed pump seal cooler, and water treatment equipment. The larger users areautomatically isolated on a fire pump start so that the maximum raw service water demandduring a fire with two electric fire pumps started is 105 GPM. In addition, there are servicewater connections located in several buildings such as the Turbine Building, CondenserCirculating Water Pumping Station, Intake Pumping Station (IPS), Security Backup PowerBuilding and Hypochlorite Building. These connections are used on as-needed bases (e.g.,temporary cooling for plant equipment), and are controlled via the fire protection impairmentpermit process, NPG-SPP-18.4.6, "Control of Fire Protection Impairments."The electric fire pumps start based on a signal from the fire detection system, a manual startfrom the MCR or associated 480V shutdown board, a signal from the reactor building hosestations, or a signal from the transformer deluge systems' electrical circuit. The electric firepumps draw water directly from the Tennessee River via the IPS. The treatment of thiswater is discussed in RAI FPR VII-2.1. The diesel fire pump starts based on low systemheader pressure and draws water from the Unit 1 Cooling Tower basin. The normal pressureof the system with a fire pump running is about 135 PSI at elevation 729.The normal make-up (in lieu of a jockey pump) for the HPFP system when a fire pump is notrunning is the Raw Cooling Water (RCW) system normally at about 80-90 PSI atelevation 729. This system also has pumps at the IPS and the water is treated as discussedin RAI FPR VII-2.1. The intertie is between the HPFP Turbine Building loop and the RCWsystem on elevation 685 in the Turbine Building. When a fire pump starts, two check valvesin series between the HPFP and RCW systems close to prevent over pressurization of theRCW system by the HPFP system.During normal operation with HPFP fed by the RCW system in the Turbine Building, theloads are:1. The demineralized water purification process (shown on the Figure 11-45.A as "ADDWTP") is located in the yard such that the feed is via Turbine Building to yard to ADDWT-P.2. The main HVAC loads are in the Service Building and the Main Office Building, andthe feed is via Turbine Building to Service Building.3. One HVAC load in the Control Building is fed by the Turbine Building loop.4. The auxiliary boiler feed pump seal cooler is fed by the Turbine Building loop.5. The as-needed service water connections are fed via the Turbine Building throughthe yard loops to the individual buildings.(Note the routes suggested are the most hydraulically direct path from the supply to theload. Since the system has multiple loops, there could be minor flow via other paths.) Theseloads are summarized in the FPR, Part II, Section 12, and the details of the demands ofthese loads are provided in a calculation referenced in the System Description.TVA has determined that the FPR does not require revision.E1-14 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"13. NRC Question (RAI FPR 111-15)Part Ill, Section 7.4, "Multiple High Impedance Faults," of the as-designed FPR, states inpart:Sustained high impedance faults, on even one power cable, are consideredhighly improbable. However, simultaneous Multiple High Impedance Faults(MHIF) has been considered in the evaluation of the electrical power system'scapability to supply power to the required fire safe shutdown loads. Thisevaluation is documented in "Appendix R -Multiple High Impedance FaultAnalysis" (reference Calculation WBPEVAR9509001).[(] Add the above calculation to the FPR Part II, Section 4.0, "References."[2] Ensure that an extent of condition review has been performed to ensure that othersimilar instances have been identified and added, if necessary.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] FPR Part II, Section 4.2, "TVA Documents," has been revised to reference thefollowing:4.2.66 WBPEVAR9509001 -"Appendix R-Multiple High Impedance Fault Analysis"This reference, as well as adding a sentence to the text of the FPR to refer to thisreference will be included in the next "As-Designed" FPR submittal.[2] No other similar instances of references not being listed in Part II, Section 4 wereidentified. Additional reviews and updates of the FPR are currently being performed,and if additional references are used, they will be included in a future FPR submittal.14. NRC Question (RAI FPR 111-16)Part Ill, Section 7.5, "Current Transformer Secondaries," of the as-designed FPR, states inpart:When a secondary circuit of a Current Transformer (CT) opens due to a fire at aremote location, ionized gases and/or additional fires in other locations could begenerated, resulting in fire propagation to additional fire areas. Fire hazards dueto a fire-induced open circuit in the secondary of CTs installed in high energypanels (i.e., 6.9kV switchgear) of the required Power systems have beenevaluated. Three types of CT circuits used in the auxiliary power system haveEl-15 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"been evaluated: ground fault, differential relaying, and protective relaying.[emphasis added][1] Confirm that the fire hazards due to a fire-induced open circuit in the secondary of CTsinstalled in high energy panels (i.e., 6.9kV switchgear) of the nonrequired power systemshave been evaluated.[2] Describe the specific methods used for the fire hazards analysis.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The evaluation of fire hazards due to a fire-induced open circuit in the secondary of CTsinstalled in high energy panels (i.e., 6.9kV switchgear) included non-required as well asrequired power systems as may be seen by the content of other paragraphs ofSection 7.5. The CT circuits associated with boards being placed in service as part ofUnit 2 completion have the same design features to prevent secondary fires from opencircuits as those already in service for Unit 1. The sentence containing the subjectstatement will be revised to provide clarification as follows: "Fire hazards due to a fire-induced open circuit in the secondary of CTs installed in high energy panels (i.e., 6.9kVswitchgear) of the required and non-required power systems have been evaluated."This revision will be included in the next FPR submittal.[2] The methodology used for the fire hazards analysis for CTs as a potential source ofsecondary fires due to open circuiting of the secondary circuit generally consists ofperforming an evaluation to identify CTs that are constructed such that an opensecondary circuit could cause ignition of the transformer and to further identify thoseCTs susceptible to ignition which have secondary circuits extending outside of the firearea to verify they are either isolated or protected. The evaluation includes but is notlimited to review of the design configurations of CT circuits as follows:(a) Verify by review of design documentation the CT secondary circuit is containedwholly within the fire area containing the switchgear, or(b) Verify by review of design documentation those CT circuits which extend beyondthe fire area containing the switchgear are isolated by transducers such that anopen circuit downstream of the isolation device would not cause failure of the CT, or(c) Verify by review of design documentation that the CT is used in a differentialprotective relay circuit such that an open circuit condition would initiate a protectiverelay actuation to trip the feeder breaker for the power circuit and thereby removecurrent to the CT.This information will be incorporated into Part IIl, Section 7, and included in the nextFPR submittal.El-16 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"15. NRC Question (RAI FPR 111-17)Part Ill, Section 7.2, 'Associated Circuits by Common Power Supply and CommonEnclosures FPR," of the as-designed FPR, states in part:These original electrical design practices provided confidence that no associatedcircuits of concern by common power supply (Type I) or by common enclosure(Type Ill) exist. As an additional check, a review was conducted of the existingelectrical protection and coordination for the safe shutdown power supplies. Asexpected, most of the circuit protective devices reviewed had been properlyselected and were coordinated. Design changes have been initiated to correctthe few remaining deficiencies identified during the review.[1] Provide a list of the design changes with the actual or scheduled completion dates.[2] Confirm that all design changes have been completed or will be completed prior to theUnit 2 fuel load.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The following is a list of the design change packages that have been issued to ensurethat the Unit 2 circuits are adequately protected with fuses/breakers that prevent acircuit from being an associate circuit (Type 1-Common Power Supply or Type Ill-Common Enclosure) of concern:EDCR No. Title/Work Scope53217 Replace the Technical Support Center Regulating Voltage Transformer53287 Replace Safety Related Class 1 E Motor Control Center (MCC) Buckets (i.e.,Motor Starters, Circuit Breakers, Relays, Internal Wiring and OtherComponents) and Feeder Breakers in the Existing Compartments of 480REAC MOV BD 2A1-A (2-MCC-213-A1 -A)53288 Replace Safety Related Class 1 E Motor Control Center (MCC) Buckets (i.e.,Motor Starters, Circuit Breakers, Relays, Internal Wiring and OtherComponents) and Feeder Breakers in the Existing Compartments of 480REAC MOV BD 2A2-A (2-MCC-213-A2-A)53290 Replace Safety Related Class 1 E Motor Control Center (MCC) Buckets (i.e.,Motor Starters, Circuit Breakers, Relays, Internal Wiring and OtherComponents) and Feeder Breakers in the Existing Compartments of 480 VCNTL & AUX BLDG VENT BDS 2A1-A, 2A2-A, 2B1-B & 2B2-B.53291 Replace Quality Related Motor Control Center (MCC) Starter Buckets, FeederBreakers and Internal Wiring in the Existing MCC Components for CommonBoard MCCsEl-17 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"EDCR No. Title/Work Scope53292 Replace Safety Related Class 1 E Motor Control Center (MCC) StarterBuckets Feeder Breakers, Relays, Internal Wiring and Other Components inthe Existing Compartments of 480 REAC MOV BD 2B1-B (2-MCC-213-B1-B)53293 Replace Safety Related Class 1 E Motor Control Center (MCC) Buckets (i.e.,Motor Starters, Circuit Breakers, Relays, Internal Wiring and OtherComponents) and Feeder Breakers in the Existing Compartments of 480 VREAC MOV BD 2B2-B (2-MCC-213-B2-B)53296 Replace Safety Related Class 1E Motor Control Center (MCC) Buckets (i.e.,Motor Starters, Circuit Breakers and Internal Wiring) and Feeder Breakers inthe Existing Compartments of 480V REAC VENT BD 2A (2-MCC-232-A-A)and 480V REAC VENT BD 2B54103 Replace Obsolete RCP UV Time Delay Relays In (4) RCP Relay Panels WithATC Model 3280. Relays 2-62-068-0008, 2-62-068-0031, 2-62-068-0050 And2-62-068-0073 Located in Panels 2-PNL-202-2/1A, 2-PNL-202-2/1B, 2-PNL-202-2/2A And 2-PNL-202-2/2B, Respectively52606 (DCN) Move the Safety-related Unit 1/Unit 2 Interface Points in 125V DC BatteryBoards 1, 11, 111 and IV from the Load Side of the Breakers to the BreakersThemselves54795 Install 480 Non-Safety Related Fuses in the Turbogenerator Control System;6.9KV Unit Power; 480V Unit Power; Turbine Building Motor Operated ValvePower; Turbine Building Vent Power and Local Instrument Control Panel54796 Install fuses for the Heater Drains and Vent; Air-Conditioning (Cooling-Heating); Sample and Water Quality; Generator Bus Cooling; Ice CondenserWaste Disposal; Spent Fuel Pit Cooling; Fuel Handling and Storage; RadiationMonitoring; 6.9KV Reactor Cooling Pump Power and Auxiliary Building Power;24 kV Power (Includes Main Transformer); Process Computer Systems54797 Install fuses for the Control Rod Drive System; Auxiliary Building CommonMotor Control; 6.9KV Shutdown Power; 480V Shutdown Power; ReactorMotor Operated Valve Power; Control and Auxiliary Vent Power; Heat Trace;and Permanent Hydrogen Mitigation System.54798 Install fuses for the Fuel and Waste Handling Power; Chemical and VolumeControl Power; CCW Pump Station Power; Reactor Vent Power; YardLighting; 120-V AC Vital Power; 125-V DC Vital Power; 120-V AC InstrumentPower; 120V AC Computer Power54799 Install Fuses for the Main Relay Boards; Code Call, Paging, Intercom, &Evacuation Alarm; Communications Room; Balance of Plant Instrument (All"R" Panels); Local Instrument Control Panel (All "L" Panels Except Those inSystem 13); Main & Auxiliary Control (All "M" panels); Control BuildingConduit & Cable Trays; Auxiliary Building Conduit & Cable Trays; DieselGenerator Building Conduit & Cable Trays.54819 Install Fuses for the Generator Cooling; Station Drainage; Feedwater Control;Turbogenerator Control; Primary Makeup Water; Reactor Protection andCondenser Tube Cleaning Systems.El-18 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"Each of these design change packages will be implemented in accordance with theirassociated system turnover schedule.[2] The design changes in the above list will be implemented prior to the associated systembeing declared operable to support Unit 2 fuel load or startup, as applicable.TVA has determined that the FPR does not require revision.16. NRC Question (IV-4.1)RAI FPR IV-4 asked TVA to detail the assumptions that support the abandonment of theMain Control Room (MCR) and transfer of control to the Auxiliary Control Room (A CR)during a fire event. The TVA response (in the May 26, 2011 TVA letter) stated, in part: "It isassumed that a single spurious equipment actuation or signal may occur prior to controlroom abandonment and transfer to the Auxiliary Control System [A CS]."For a control building fire, the reviewers expect the WBN Unit 2 analysis to consider thefollowing conditions simultaneously:* when offsite power is available and when offsite power is not available;* the loss of all automatic function (signals, logic) from the circuits located in the fire areain conjunction with one worst case spurious actuation or signal;* a fire that results in spurious actuation of the redundant valves in any one high-lowpressure interface line prior to transfer of control to the ACR.Provide an explanation for any of the above assumptions that are not part of the WBN Unit 2analysis for a control building fire and MCR abandonment prior to transfer of control to theACR.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:For a control building fire, the WBN Unit 2 analysis considers the following conditionsconcurrently after the operators transfer control from the control room to the auxiliary controlsystem:* when offsite power is available and when offsite power is not available;* the loss of all automatic function (signals, logic) from the circuits located in the fire areain conjunction with one worst case spurious actuation or signal;* a fire that results in spurious actuation of the redundant valves in any one high-lowpressure interface line.Before control of the plant is achieved through the auxiliary control system, the analysisconsiders one spurious actuation or signal may occur. The analysis does not consider a fireE1-19 ENCLOSURE IResponse to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"that results in spurious actuation of the redundant valves in any one high-low pressureinterface line nor does it consider loss of all automatic functions (signals, logic) prior totransfer of control to the ACR.As described in the response to RAI FPR IV-1 (TVA letter dated 5 2011) and in theresponse to RAI FPR IV-4 (TVA letter dated 5-26-2011), the control building is consideredan "alternative shutdown" area and the FSSD analysis is in accordance with section 5.4 ofRegulatory Guide (RG) 1.189, Rev. 2, "Fire Protection for Nuclear Power Plants."Accordingly, for the time period between fire initiation and transfer of control to the auxiliarycontrol system a single spurious actuation or signal is considered, but after plant control istransferred to the ACS, single and multiple spurious actuations and loss of all automaticfunctions (signals, logic) are considered. The analysis conforms to RG 1.189, Section 5.4.1(next to last paragraph) which states,"The licensee should consider one spurious actuation or signal to occur before control ofthe plant is achieved through the alternative of dedicated shutdown system for fires inareas that require alternate or dedicated shutdown. After the operators transfer controlfrom the control room to the alternative or dedicated shutdown system, single or multiplespurious actuations that could occur in the fire-affected area should be considered, inaccordance with the plant's approved FPP" (emphasis added).17. NRC Question (RAI FPR V-13)Part V, Section 2.2.2 "Operator Locations Prior to Initiating Manual Actions and t=ODefinition, " of the as-designed FPR, states, in part: "The time requirements for completion ofmanual operator actions are based on defining the initiating time t = 0 as the time when thereactor is tripped from the Main Control Room (MCR)."[11 Describe any differences in the t=O definition for fires that cause an automatic reactor trip(that is where the reactor is not tripped from the MCR). [2] Provide a technical justificationfor any differences between the two cases.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] There are no differences in the t=0 definition for the two cases. This is because a firethat could grow to the point of causing damage that results in an automatic reactor tripwould have been assessed by plant personnel as a challenging fire with the potential todamage structures, systems, or components necessary for safe shutdown. The decisionto trip the reactor manually would have been reached prior to or about the same time asfire damage actually causing automatic reactor trip.This is supported by Section E.6 of NEI-00-01 Revision 2, which states that fire damageto safe shutdown components or circuits is not expected to occur for at least 10 minutesafter confirmation by plant personnel that the plant is experiencing a challenging fire.E1-20 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"Additionally, industry test data discussed in Appendix E of NEI-00-01 Revision 2indicates that fire induced circuit failures will not occur immediately upon exposingcables to fire effects. The test data indicates the average time to failure exceeded30 minutes for thermoset cables and 15 minutes for thermoplastic insulated cables.Fire locations subject to high energy rapidly developing fires (e.g. electrical board roomsand transformer rooms) do not contain cables or equipment whose failure could initiateautomatic reactor trip. As described in FPR Part V, Section 2.2, "Safe ShutdownProcedures," the plant operators' response to a fire is governed by AOI 30.1, "PlantFires." The control room is alerted of a fire in its early stages either by the fire detectionsystem or as a result of visual observation by plant personnel. The operator's initialresponse includes:A. Initiate plant fire alarmB. Notify Fire BrigadeC. Announce fire location over PA systemD. Ensure fire pumps are runningE. Assemble AUOs in the control room in case the fire cannot be controlled and unitshutdown becomes necessary.In the unlikely event that fire damage initiated automatic reactor trip, the AUOs wouldhave been assembled with procedure in hand and ready to perform the preventativeoperator manual actions with no significant delay.[2] N/A.TVA has determined that the FPR does not require revision.18. NRC Question (RAI FPR V-14)Part V, Section 2.4 "Access Routes to Manual Action Locations," of the as-designed FPRdiscusses reentry into large fire areas, but does not include a discussion of timeliness.Part V, Section 2.1.2.2.d, states: "OMAs to be performed in the fire affected room in aboutan hour or less are specifically evaluated and documented in FPR Part VII."[1) Explain the relationship between Sections 2.1.2.2.d and 2.4 of Part V. [2) Also, providean explanation of which manual actions are governed by Section 2.1.2.2.d and which aregoverned by Section 2.4 of Part V.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] FPR Part V, Section 2.1.2.2.d is one of several acceptance criteria for operator manualactions (OMAs) feasibility and reliability evaluations. This criterion requires that OMAsEl-21 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"to be performed in the fire affected room in about an hour are to be specificallyevaluated and documented in FPR Part VII, Section 8.FPR Part V, Section 2.4, "Access Routes to Manual Action Locations," is a generalstatement that there are multiple access routes through large plant areas (e.g., 737-Al).The additional routes are to provide flexibility and assurance that the OMA location canbe reached with the fire in any location in a large area.[2] All OMAs are evaluated to the criteria in Section 2.1.2.2. Section 2.4 does not governany OMAs. It is a general statement that access routes have been evaluated for allOMA locations and there are multiple access routes through the large plant areas.TVA has determined that the FPR does not require revision.19. NRC Question (RAI FPR V-15)Part V, Section 2.1.2 "Acceptance Criteria," of the as-designed FPR states, in part: "OMAsfor important to safe shutdown components require no further detailed evaluation."This section also contains a list of the assumptions that may apply to the manual actionFeasibility and Reliability analysis. The third assumption states: "Operator Manual Actionswith a required completion time (allowable time) of 120 minutes or greater are consideredfeasible and reliable and do not require further evaluation."The FPR provides references to evaluations and criteria that apply to OMAs. [1] Confirmthat the evaluations have been performed. [2] If evaluations have been performed but notincluded in the FPR, provide an explanation of why they are not needed in the FPR.If evaluations were not performed, provide a justification for not performing any evaluations.TVA Response:[1] FPR Part V, Section 2.1.2 is revised to remove the ambiguous statement "OMAs forimportant to safe shutdown components require no further detailed evaluation."Feasibility and reliability evaluations are performed for both important to safe shutdownand required for safe shutdown path component OMAs. The OMA evaluations for therequired components are contained in FPR Part VII, Section 8.3, while the important tosafe shutdown evaluations are contained in a separate calculation. This split of thedocumentation was suggested by the NRC reviewers.Assumption number 3 (also in Section 2.1.2) will be revised to read as follows:"Operator Manual Actions with a required completion time (allowable time) of120 minutes or greater have adequate time for feasible and reliable performance andcan be excluded from performance validation demonstrations."These changes will be included in the next FPR submittal.E1-22 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"[2] Feasibility and reliability evaluations of OMAs involving components in the safeshutdown success path with an allowable completion time less than 120 minutes areincluded in FPR Part VII, Section 8, for staff review. This change will be included in thenext FPR submittal. Feasibility and reliability of important to safe shutdown OMAs andnon-time critical (120 minutes or greater) required for safe shutdown OMAs areevaluated using the methodology and criteria of FPR Part V, Section 2.1, and aredocumented in engineering calculations, but are not included in the FPR. Thelikelihood of failure of OMAs that do not have to be performed for at least two hours andthe consequences of such failure is considered to be very low. Within two hours,additional staffing can be called in to assist the onsite staff, environmental effects due tothe fire and fire brigade activities would be under control to have minimal impact, andtime would be available to resolve any unexpected equipment operability oraccessibility issues. RG 1.189 allows important to safe shutdown OMAs without priorNRC approval; therefore, the associated evaluations are not included in the FPR.20. NRC Question (RAI FPR V-16)In Part V, Section 2.3 "Manual Actions Prior to Main Control Room Abandonment,"of the as-designed FPR, credit is taken for, "automatic detection and suppression systems, whichwould also result in detection of the fire in its early stages." However, some areas of thecontrol building, such as some battery board rooms and the relay room, do not havesuppression.Deviation 2.3 in Part V1I of the as-designed FPR discusses alternative shutdown areas thatlack suppression, but does not specifically justify that components (such as the PORV)wouldn't be damaged or spuriously operate for a fire in these areas before effectivesuppression could be applied.Provide a technical justification that demonstrates that, for areas without automaticsuppression in the control building, a fire would not damage or spuriously operateequipment important to safe shutdown. For example, justify that the PORVs will not open,prior to closing the PORV block valves from the MCR for a fire in the areas of the controlbuilding that lack automatic suppression.TVA Response:The circuits required for FSSD of the PORVs and associated block valves are only routedthrough the Cable Spreading Room (CSR) and into control cabinets in the MCR. The CSRis provided with detection and automatic suppression. Circuits terminating in panels in theMCR are provided with adequate circuit fault protection (breakers/fuses) that will clear thefault before the insulation reaches its auto-ignition temperature. In addition, the combinationof detectors in the panels and the smell of hot wires that would be detected by the MCRstaff, the probability of an unlikely fault becoming a fire is considered to be insignificant.The circuits on elevation 692.0 of the Auxiliary Building that are routed into the ControlBuilding are from rooms 692.0-A29 and -A30 into 692.0-C9. Room 692.0-C9E1-23 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"(Communications Room) is provided with detection and automatic suppression. Thesecircuits do not enter the rooms (692.0-C4, -C5 and -C8) without automatic suppression.These circuits either terminate in room 708.0-C4 (Unit 2 Auxiliary Instrument Room) orcontinue to the CSR (729.0-Al). Both of these rooms are provided with detection andautomatic suppression.There are circuits on Auxiliary Building elevation 757.0 (room 757.0-A21) that are routed intothe Control Building (rooms 755.0-C13 and -C20) in conduits that turn down into the CSR.The CSR is provided with detection and automatic suppression. The rooms on 755.0 areprovided with detection, but do not have automatic suppression. These two rooms have alow fire severity rating (755.0-C13 has -26,200 Btu/ft2 and 755.0-C20 has -29,300 Btu/ft2).The combustible loading is miscellaneous class A combustibles (desk, chairs, tables, relayboards, control panels, etc.) that are dispersed throughout the rooms. There are no credibleignition sources present which make it highly unlikely that a fire could occur; however, if afire were to occur, it would be detected by the detection system, and MCR staff would beable to confirm it and either quickly extinguish it with portable extinguishers or control it untilthe fire brigade responds. Portable extinguishers are readily available, and there is astandpipe and hose station available from the stairwell #2 (adjacent to 755.0-C20) for firebrigade use. This provides a high degree of confidence that in the highly unlikely event afire were to occur, it would be quickly detected and extinguished before it could impact anyof the FSSD required circuits, all of which are routed in conduit.21. NRC Question (RAI FPR VI-6.1)RAI VI-6 deals with whether two analyses were performed for exactly the same plant areasin two locations in Fire Area 1. In a letter dated June 17, 2011, TVA confirmed that this wasthe case and identified changes to be made to the description of the analysis methodologyand to the descriptions of the involved analysis volumes.Confirm that no other instances of this situation exist in the WBN analysis, or make thesame changes for other instances.TVA Response:TVA is reviewing the WBN analysis, and as necessary, will make similar changes to Part VIfor any additional analysis volumes exhibiting a similar condition in the next FPR revision.22. NRC Question (RAI FPR VI-7.1)RAI VI-7 deals with the partitioning of containment (Fire Area 77) into analysis volumes. Inits letter dated June 17, 2011, TVA confirmed that the lower containment was intended to bedivided into quadrants for the analysis. Lower containment is also divided into inside andoutside the crane wall portions. TVA's response states, in part:The division of the Reactor Buildings into quadrants allowed WBN to determine thepostulated fire's impact on the steam generators (one steam generator per quadrant)El-24 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"and associated valves and instrumentation to ensure that redundant componentsare, by using the separation criteria of Appendix R, Section /II.G.2.d, e or f, kept freeof fire damage.Using this methodology, it would be expected that the following analysis volume divisionswould be created for the lower containment (based on Figure 11-40A of the as-designedFPR):1. Unit 2 Accumulator Room (2RA) 4, Unit 2 Fan Room (2RF) 1, Lower Containment (inneror Outer) Quadrant (270-360 degrees)2. 2RFI, 2RA 1, Unit 2 Instrument Room (2RIR), Lower Containment (Inner or Outer)Quadrant (0-90 degrees)3. 2RIR, 2RA2, 2RF2, Lower Containment (Inner or Outer) Quadrant (90-180 degrees)4. 2RF2, 2RA3, Lower Containment (Inner or Outer Quadrant (180-270 degrees)This results in four pairs of analysis volumes.However, the actual division of lower containment appears to deviate from the conceptpresented in the RAI response. The NRC staff identified the following issues:" Analysis Volume 118C: 2RA3 does not appear to be adjacent to either 2RA4 orQuadrant (270-360 degrees);" Analysis Volume 118D: 2RA4 is not adjacent to Quadrant (0-90 degrees);" Analysis Volume 118E: A Lower Containment Quadrant is not identified in the FPR:although the interaction is identified in Part VI, Section 3.84.3.6, of the as-designed FPR:* Analysis Volume 118F: This analysis volume consists solely of the Instrument Room.However, no rated fire barriers are identified in the FPR to justify such isolation. TheInstrument Room is also not a part of any of the other analysis volumes.Reconcile the differences between the methodology described in the RAI response andabove identified issues.TVA Response:The original response to RAI FPR VI-7 confirmed that the Unit 2 reactor building lowercompartment area outside the crane wall (2RO) and inside the crane wall (2RI) are in factsubdivided into 900 quadrants, but did not clarify how the quadrants are analyzed with eachanalysis volume within Fire Area 77. The FSSD analysis evaluates the individual reactorbuilding rooms and the 2RO and 2RI quadrants that communicate with the selected roomsvia unprotected openings. This method is very conservative and results in two RO/RIEl-25 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"quadrants being evaluated in each analysis volume except 2RIR, which is a closed roomwith no unprotected openings. The room and quadrant combinations for each analysisvolume are as follows:AV Rooms/Quad rants118-A 2RA2, 2RF2, 2RO-2 (90°-1800), 2RO-3 (180-2700)118-B 2RA3, 2RF2, 2RO-2 (900-180), 2RO-3 (180°-270°)118-C 2RA3, 2RA4, 2RO-4 (2700%360°), 2RO-3 (1800-270°)118-D 2RA4, 2RF1, 2RO-1 (00-90°), 2RO-4 (2700-360°)118-E 2RA1, 2RF1, 2RO-1 (0°-90°), 2RO-4 (270%3600)118-F 2RIR118-G Upper containment118-H 2RA2, 2RF2, 2RI-2 (90o-180°), 2RI-3 (1800-270°)118-J 2RA3, 2RF2, 2RI-2 (90°-180°), 2RI-3 (180°-2700)118-K 2RA4, 2RF1, 2R1-1 (00-900), 2RI-4 (2700-360°)118-L 2RA1, 2RF1, 2R1-1 (0°-900), 2RI-4 (2700-360°)FPR Part III, Table 3-3 and Part VI, Sections 3.84.3.2 thru 3.84.3.12 will be updated toclarify the 2RO and 2RI quadrants included in each analysis volume and these changes willbe included in the next FPR submittal.The specific issues identified by the staff are addressed as follows:* Analysis Volume 11BC: 2RA3 and 2RA4 communicate with 2RO on the north andsouth side of 2RO azimuth 2700 respectively, and 2RO-3 (1800 -2700) and 2RO-4(270' 3600) are connected by a small passage below the fuel transfer canal onelevation 702. An "Appendix R fire" in that small passage could theoretically affectcomponents in both 2RA3 and 2RA4. Such a fire is not a practical concern, but it isconsidered in accordance with Appendix R rules.* Analysis Volume 118D: We agree, 2RA4 is not adjacent to Quadrant (0-90 degrees).2RA4 is analyzed with 2RF1 which does communicate with 2RO-1 (0-90 degrees).* Analysis Volume 118E: We agree, Table 3-3 will be revised as shown above to identifythe appropriate 2RO quadrants." Analysis Volume 118F: 2RIR is a separate room with no unprotected openings. Theconcrete walls are more than adequate radiant energy shields.23. NRC Question (RAI FPR VI-9)Part VI, Section 3.67.3. 1 of the as-designed FPR is the safe shutdown analysis for theUnit 1 annulus (Analysis Volume AV-091). The reviewers did not expect to find Unit 2equipment affected by a fire in this Analysis Volume, which they expected to be Unit I onlyarea since it is part of the Unit I reactor building.E1-26 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"Provide more detail on and an explanation for this configuration.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The FSSD analysis postulated an Appendix R fire that very conservatively assumes loss ofall FSSD components within the Analysis Volume. There are some Auxiliary Control AirSystem (ACAS) end users (none of which are required for FSSD) in the Unit 1 Annulus (AV-091) that were assumed to be damaged by the postulated fire and result in loss of the ACASfor both units. As a result of this conservative assumption, all ACAS end users wereassumed to be lost (including those in the Unit 2 Reactor Building). Additional evaluationsof the Annulus identified the specific locations of the end users and the isolation valves forthe ACAS headers and determined that there is no credible fire that could cause failure ofthe end users and the ability to close (from the MCR) the isolation valves (they areseparated by at least 30 feet [horizontal distance] and multiple layers of automaticsuppression and detection). Therefore, the ACAS is no longer considered to be lost, andthe references to the Unit 2 components being affected are being removed. This will beincluded in the next FPR submittal. Calculation WBPEVAR9602001 will also be revised todocument this evaluation.24. NRC Question (RAI FPR VI-lO)The reviewers did not expect to find opposite unit OMAs identified for a fire in other unit'sreactor building, which they expected to be single unit areas. For example, Unit I OMAs forfires in the Unit 2 reactor building.In other instances, the text description identified potential damage to opposite unit systemsfor a fire in the other unit's primary containment. For example Part VI, Section 3.67.3.4,states, in part: "A fire in Analysis Volume 92C could potentially affect systems andcomponents necessary to maintain the Unit I and Unit 2 steam generator inventory controlfunctions..."Analysis Volume Description Opposite Unit Item091 Unit 1 Annulus OMAs092C Unit 1 Primary Containment Potential System Damage092D Unit I Primary Containment Potential System Damage117 Unit 2 Annulus OMAsProvide more detail on and an explanation for these configurations.This RAI may involve an update to the FPR to incorporate the response to the RAI.E1-27 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"TVA Response:See response to RAI FPR VI-9 above. The assumed loss of the ACAS resulted in themanual action to operate the valves necessary to maintain steam generator inventorycontrol. The evaluation for the Unit 2 Annulus is documented in calculationWBNEEBEDQ00099920110005.A fire inside primary containment is assumed to damage ACAS end users creating a fewsmall leakage paths. However, since the ACAS is supplied from both the large station aircompressors and the ACAS compressors, these leaks will not depressurize the opposite unitACAS headers. These manual actions are no longer required and will be removed from theassociated analysis volumes in the next FPR submittal. There are no fires in one unit thatrequire an OMA for the other unit.25. NRC Question (RAI FPR VI-11)[1] Provide a level of detail concerning the repair procedure for 2-FCV-74 B (found in PartVI, Section 3.19.5.1 of the as-designed FPR [Analysis Volume A V-036]) similar to that foundin the description of the repair procedures for 1 -MTR-30-176-B (found in the same section).[2] Provide this level of detail for all other repair procedures that currently lack this detail inPart V1.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The details for the repair of the RHR valves for Unit I and Unit 2 will be documented inFPR Part V, Section 3.3, and will be included in the next FPR submittal.[2] Part VI was reviewed and will be revised as necessary in the next revision to the FPR toensure the references to "repair procedure" contain a consistent level of detail, and thiswill be included in the next FPR submittal. During this review, TVA also noted thatseveral references were made to "See Remarks." These references have also beencorrected to provide the relevant information.26. NRC Question (RAI FPR VII-2. 1)The TVA response to RAI FPR VII-2 part 6 (in the May 26, 2011 TVA letter) does not fullyanswer the question regarding the additional service life caused by the late licensing ofUnit 2.Provide [1] a technical justification and [2] summary evaluation that demonstrates that thefire water system will maintain functionality for all hose stations and suppression systems forthe lifetime of the Unit 2 license.El-28 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"The technical justification should include, but not be limited to:" The testing to be performed to identify where microbiologically induced corrosion (MIC) orother corrosion is a concern" The frequency of the testing" The acceptance criteria used to determine when pipe replacement is required" How operational experience regarding corrosion is incorporated into the pipe corrosionprogram.This RAI may involve an update to the FPR to incorporate the response to the RAI.NRC Follow-up Questions provided in July 28, 2011 Public Meeting:* "The corrosion control program also has selected some of the HPFP piping to bereplaced."o Provide a description of the criteria used for preventative replacement.o Is the "corrosion control program" the same as the "pipe corrosion program" or arethere two programs?* On page E-3, are the numbered items aspects of procedure NPG-SPP-09.15 or NPG-SPP-09. 7?TVA Response:[1] The corrosion aspects of carbon steel piping and raw water usage is a known industryissue and is addressed by the implementation of a WBN Raw Water Corrosion programthat includes engineering design and evaluation, chemical treatment, testing, and pipereplacement.The HPFP design calculations performed for Unit 1 startup addressed raw watercorrosion based on a TVA study issued in 1979 documenting the effects on carbon steelraw water piping used at TVA fossil plants on the Tennessee River system. This studyincluded piping that had been in service for 5 to 25 years when studied in 1979. Thestudy resulted in TVA Mechanical Design Standard DS-M3.5.1, "Pressure DropCalculations for Raw Water Piping and Fittings." For assumed 40-year life, the designstandard can be summarized as reducing the internal pipe diameter by 0.8 inches andusing a corrosion resistance (C=55) for carbon steel pipe normally wetted with rawwater. This is still the design criteria for TVA plants.The selection of chemicals to treat the water and maintain the system metalliccomponents to the maximum extent possible are reviewed by Engineering, Chemistryand Environmental personnel to maximize these goals. These responsibilities aredefined in TVA Nuclear Power Group Standard Programs and Processes, NPG-SPP-09.7, "Corrosion Control Program." This procedure requires the HPFP system as well asE1-29 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"the other raw water systems to meet the requirements of the FSAR and subsequentSSERs. Some of the aspects of this procedure to address systems that use raw waterinclude:1. Program oversight by Corporate Engineering including subject matter expertise;2. Establishment of site Chemistry as the owner of the raw water treatment program;3. Site Engineering to identify potential MIC problem areas, consider and recommendchanges in plant design to reduce MIC susceptibility, and review and evaluate NDEdata observations;4. Specific, defined, and documented internal inspections for opened raw watersystems;5. Specific criteria for initiation of a corrective action document such as a thru wall leak,failure to treat system areas as planned, excessive deposits, etc.;6. Engineering evaluation of equipment which does not receive treatment;7. Monitor raw water system for biological activity by system inspection results;8. Engineering ensuring raw water system maintenance and inspection and repairs areperformed at the minimum frequency specified; and9. Periodic meetings of a site raw water team (including Design Engineering, SystemEngineering, Chemistry, Environmental, Maintenance, and Operations as aminimum) to address issues and changes to the program.Presently, the chemical treatment program injects chemicals to the Essential RawCooling Water (ERCW), RCW, and HPFP raw water systems at the IPS pits such thatany pump on these systems that is running picks up the chemical. The program adds anoxidizing biocide (e.g., chlorine) year-round to the IPS pits a selected number of hoursper day and days per week based on river water temperature, except when non-oxidizing biocide is being injected. This treatment is for slime, MIC, and clams. Thisoxidizing biocide will remain in solution for a short period of time and will treat pipingbased on any water use by the piping during this treatment. When the river temperaturerises to the 60-70 degree F range, a nonoxidizing biocide is added to the IPS pits, andsystem specific flushes are undertaken to ensure this non-oxidizing chemical reaches asmuch of these three systems as possible. This treatment controls Asiatic Clams, ZebraMussels, and MIC. This non-oxidizing chemical is expected to remain effective forapproximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in flowing areas and for approximately 3 months in stagnantareas. The non-oxidizing biocide is added for 2 to 3 days for each train. Thesetreatments are repeated no more than 9 weeks apart until the river temperature fallsbelow 60 degrees F. For the HPFP system, the first (spring) and last (fall) non-oxidizingtreatments are used to treat the entire system. These two flushes, in accordance withthe chemistry program, are specified by the testing and inspection requirements of theFPR. The other non-oxidizing treatments between the spring and fall treatment onlytreat the parts of HPFP that are using water during this time.Normally, when the river water temperature is 60 degrees F or greater phosphate isadded to sequester iron from existing mounds of corrosion products and zinc is addedas a mild steel corrosion inhibitor on a continuous basis.E1-30 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"The criteria for replacing failed piping are:1. When the piping has a thru wall leak.2. When minimum flow requirements cannot be obtained.3. When pipe wall thickness have reached minimum allowable thickness.The criteria for replacing piping that has not failed are:1. When pipe wall thickness is approaching minimum allowable thickness based onthe critical nature of the pipe (e.g., ease of access and impact of associatedoutage).2. Cost effectiveness of pipe replacement vs. repair.The Corrosion Control Program also has selected some of the HPFP piping to bereplaced before failure (e.g, thru wall leak). Some HPFP piping has been replacedand/or is scheduled for replacement due to it approaching minimum wall thickness.Other HPFP piping was identified to be replaced not based on physical characteristics(e.g., approaching minimum wall or a thru wall leak) but as not having been replaced in aspecified period of time and was thus replaced as a preventative measure. The internalinspections of the piping replaced due to time and not degraded physical characteristicsrevealed less, smaller MIC nodules than expected and the determination thatreplacement was not warranted at this time.WBN has replaced 1,715 feet of HPFP piping, which included 1,625 feet of the HPFPTrain B header that was replaced in 2005. This replacement was due to the excessivecosts the multiple repairs on this piping. The original length HPFP Train B header was> 5,000 feet, but was rerouted to provide a more direct route.NPG-SPP-09.15, "Buried Piping Integrity Program," addresses the HPFP system as wellas other buried piping systems. This program was established in 2009. Some of theaspects of this program as provided by this procedure are:1. Implementation of the NEI Nuclear Strategic Issues Advisory CommitteeUnderground Piping and Tank Integrity Initiative;2. Identifies governance and oversight with the corporate program manager;3. Perform a risk ranking of buried piping including HPFP based on soil samples, pipingmaterial, installation methods, consequences of breaks, and failure modes;4. Provisions for direct inspection technologies such as guided wave technology whenburied piping is exposed; and5. Establishment of an assessment management plan to address repair and/orreplacement as appropriated based on conditions, risk, environmental impact, etc.HPFP is a part of the Buried Pipe Integrity Program, and portions of the HPFP Train Aheader were recently examined using guided wave technology as a screening tool toidentify locations of possible external degradation.E1-31 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"WBN Buried Piping Plan has been established in support of NEI 09-14, "Guideline forthe Management of Underground Piping and Tank Integrity." This plan established thenumber of locations to evaluate the integrity of the HPFP piping. This plan providesreasonable assurance of structural and/or leakage integrity of buried piping through theresults of both indirect inspections and direct examinations. Currently, WBN is in theprocess of excavating another section of the HPFP Train A header to be proactive andto determine the structural integrity of this portion of HPFP buried piping.When HPFP piping is opened, a trained person is required to review the piping interiorand document the as-found condition of the piping as specified by NPG-SPP-09.7. Thisdocumentation includes as a minimum the material and equipment type, interiorcondition (e.g., silt, turbercles, debris/slime/biomass, shells, and corrosion and pitting).Testing of fire protection systems includes the following:1. Sprinkler systems are tripped once per six months as a part of the testing of the firedetection system. This verifies the trim piping is clear to allow automatic actuation ofthe associated valve.2. Grids have been established on select sections of HPFP piping, and twice a yearnon-destructive testing is performed to determine the wall thickness of the piping inthe grid area. This data is trended to address wall thinning rates.3. Two times per year the end hose stations on a riser are flushed to achieve chemicaltreatment using a non-oxidizing biocide, as described above, to the associatedpiping. Selected points are tested for residual concentration of the non-oxidizingbiocide.4. Once every three years, selected areas of the HPFP system are flow tested todetermine the hydraulic capability of the associated piping. These flow tests includesprinkler systems and hose stations as well as yard fire hydrants. The results of thistesting are trended.5. When repairs are made, piping sections on each side of the repair are examined forwall thinning, corrosion, etc. The results of this examination ensure that the scope ofthe repair is adequate.Presently, the program to address exterior corrosion is also addressed byNPG-SPP-09.7. The exterior corrosion of non-buried carbon steel piping is addressedby the use of protective coatings and has not been seen as an extensive problem atWBN. Operating experience has been incorporated into the Corrosion Control Program(note in the previous submittal this was referred to as the Pipe Corrosion Program) asevidenced by:1. The evolution of the Chemical Treatment Program discussed in the TVA response toRAI FPR VII-1, part 1,2. The establishment of the additional Buried Piping Program in 2009, and3. The replacement of the B train header due to multiple leaks in a short period of time.E1-32 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"[2] The HPFP piping can perform its design function for the 40 year life of Unit 2 since theChemical Treatment Program prolongs service life, the Buried Piping Program monitorsto assist in replacement prediction as required, testing to design requirements isperformed, and degradation trending is performed to assist in replacement prediction.The Corrosion Control Program identifies piping that needs to be replaced prior to thepiping becoming an issue for WBN. While the system design is based on a 40 year lifewith full required flow capability, the maintenance/testing/replacement programdescribed above ensures the system will meet its fire protection functional requirementsthroughout the life of the plant.TVA has determined that the FPR does not require revision.27. NRC Question (RAI FPR VII-2.2)The TVA response to RAI FPR VII-2 parts 3 and 4 (in the May 26, 2011 TVA letter)describes the current pipe corrosion testing program as focused on the three hose stationsidentified by the initial calculation as failing before the initial fire water system service lifeexpired.[1] Describe the actual trending results and acceptance criteria being used to determineacceptability of the three hose stations which are expected to fail prematurely.[2] Describe the testing being performed to identify where MIC or other corrosion is aconcern, the frequency of testing, the trending results, and the acceptance criteria used todetermine when pipe replacement is required.[3] Identify the additional piping and hose stations added to service for Unit 2 operation, orconfirm that no new piping or hose stations have been added for Unit 2 operation.[4] Describe how the additional service life (caused by the later licensing of Unit 2) will affectthe scope of the pipe corrosion testing program. If the scope will be unchanged, provide ajustification for the unchanged scope.This RAI may involve an update to the FPR to incorporate the response to the RAI.NRC Follow-up Questions provided in July 28, 2011 Public Meeting:" Trending of the fire protection system appears to be limited to achieving the acceptancecriteria. Provide a discussion of TVA's trending program.* The trending program does not have criteria that specify when piping is to be replacedsuch as 10% degradation in performance results in replacement. Provide a discussionof the criteria used by the trending program for piping replacement recommendations.E1-33 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"-/The trending program is trending old pipe (A-train header) and new pipe (B-train header)together and not distinguishing between the different flow tests relative to when the B-train header was replaced. An example is the DGB piping is being trended based on thesame piping for the 1995 and the 2010 tests but the Control Building is being trendedbased on old piping in 1995 and new piping in 2010. Discuss the above effect on thetrending program." What flushing will be done for the currently wet Unit I piping that will supply the Unit 2systems that will be brought into service for two unit operation.* Are the buried ASME headers being flushed as required by the ASME code?" What sprinkler systems provide protection for safety related equipment at the highestelevations of the WBN buildings?TVA Response:[1] The acceptance criteria for the three sets of hose stations are:Location Flow PressureAuxiliary Bldg Roof (0-ISV-26-654 & -655) > 500 GPM -65 PSIGDGB Roof (0-ISV-26-565 & -566) -500 GPM > 65 PSIGIPS (0-ISV-26-1710 & -1711) -> 200 GPM >65 PSIGThe following table provides the flow test information for the three sets of hose stationsthat the calculations predict will not meet the acceptance criteria for the 40 year life ofplant. Shown is the data for the first performance of the test procedure to test the flow atthese three locations before fuel load of Unit 1 and also is the data for the most recentperformance of this same test.Valves 1995 1995 2010 2010Flow Pressure Flow (GPM) Pressure(GPM) (PSI) Auxiliary Bldg Roof (0-ISV-26-654 & -560 65.3 450 64.3655)DGB Roof (0-ISV-26-565 & -566) 560 77.6 500 81.1IPS (0-1SV-26-1710 & -1711) 395 65 230 95A -This test has been determined to have been invalid due to the use of a measurementand test equipment (M&TE) flow measuring device number E23394 that was readingabout 45 GPM low when the calibration was verified after the testing. It is unknownwhen and by how much this M&TE was out of tolerance when used on this test. Due tothe age of the M&TE, the vendor did not support its repair, so the M&TE was retired andthe failure mechanism is unknown. Without knowing how the M&TE failed, there is noway of determining if the amount of out of tolerance was variable and/or when itEl-34 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"happened. To accurately determine the capability of the HPFP system, this section ofthe test will be re-performed summer 2011.These three sets of hose stations depict the condition of the piping in the Auxiliary Building,Diesel Generator Building (DGB), and IPS structure. The Auxiliary Building hose stationsalso provide an indication of the condition of the fire protection in the Control Building sincethe Control Building fire protection is fed from the Auxiliary Building HPFP header loop. Inaddition to the three sets of hose stations listed above, there is additional testing data thatprovides additional indications of the condition of the HPFP piping in the following locations:1. Auxiliary Building has two sprinkler systems in the Auxiliary Building and one in theControl Building. The highest elevation in the Auxiliary Building where sprinklerprotection is provided for the protection of safety-related equipment is served by thesetwo Auxiliary Building sprinkler systems. The highest elevation in the Control Buildingwhere sprinkler protection is provided for safety-related equipment is served by thisControl Building sprinkler system.2. DGB has a hydrant on the same supply piping and a sprinkler system on adjacentpiping. The highest elevation in the DGB where sprinkler protection is provided forsafety-related equipment is served by this sprinkler system.3. The IPS has very limited combustible loading to protect against and the roof is wellventilated to prevent heat build-up if there is a fire. (The entire roof is made of wideflange structural members [W shape beams] mounted on edge, which protects frommissiles, but allows smoke removal.)E1-35 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"None of the following collaborative points have acceptance criteria, and the data collected isfor trending only. The following data is for the first performance and the most recentperformance of the flow test:Valves 1995 1995 2010 2010Flow Pressure Flow (GPM) Pressure(GPM) (PSI) -(PSI)Auxiliary Bldg sprinkler system 564 78 665 590-FCV-26-143 and -322Auxiliary Bldg sprinkler system 576 76 696 500-FCV-26-151 and -326Control Building sprinkler system 725 109 600 1050-FCV-26-211DGB hydrant 0-HYD-26-819 560 124 500A 117___DGB sprinkler system 0-FCV-26-167 600 84 617 72A -This test has been determined to have been invalid due to the use of a measurementand test equipment (M&TE) flow measuring device number E23394 that was readingabout 45 GPM low when the calibration was verified after the testing. It is unknownwhen and by how much this M&TE was out of tolerance when used on this test.The trending program does not have specified criteria to determine when the trend isnegative enough to invoke piping replacement. Typical damage caused by MIC cannotbe detected by pressure and flow trending. This type of damage is identified byinspection. Testing ensures that HPFP is capable of performing its design function.Trending provides early identification of degradation which may impact the ability toperform the design function in the future. A negative trend is expected based on thedesign calculations, as documented in the FPR. At present, the trending program for theHPFP system is looking at the entire system, buried trained headers, buried commonheaders, as well as the interior piping. Thus, when piping is replaced (e.g., B trainheader), the results are trended in all sections of the test, as well as the assurance thatthe HPFP system will continue to be capable of performing its design function.[2] Question 1 (RAI FPR VII-2.1) above provides the testing being performed to identifywhere MIC and other corrosion is a concern, the trending results, the frequency oftesting, and the acceptance criteria used to determine when pipe is replaced.The flow test, O-FOR-26-2, "3 Year High Pressure Fire Protection Hydraulic PerformanceVerification," is written to perform the testing like a typical municipal water system flowtest where the water supply is established. The difference is during the flow test, thesystem is set up to reflect fire operation and controlled to ensure those conditions remainvalid unlike a municipal water supply that may vary based on unknown water uses.The following is a summary of this flow test.Before the flow test begins, one of the preliminary actions is to verify that thevalves in the flow paths are open. This is to ensure the headers, trained andE1-36 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"common, are all interconnected as per design to ensure continuity of testing.Thus the individual flow points test the ability of the HPFP system piping toprovide design flow.The test uses two electric fire pumps for each section except one section. Forone section the diesel fire pump is used to verify the header that connects thediesel fire pump to the common yard header. The electric fire pumps were usedfor the normal water supply because under normal conditions, a fire detectionsystem activation would automatically start two electric fire pumps (see FPR,Part II, reference 4.2.4 and Section 12.1). The verbal report of a fire to the MCRwould normally result in the starting of two electric fire pumps in accordance withAOI-30.1, "Plant Fires." The four electric fire pumps have the same capacity andare tested separately every 18 months to ensure they still meet their pump curve.When the two electric fire pumps are started for the test, the system pressurecontrol valve would limit system pressure to 135 PSI automatically. So, as loadsare added and removed from the system, the pressure control valve will adjust toattempt to maintain 135 PSI.There are service water loads that automatically isolate, and some loads that donot isolate when the electric fire pumps are started for the test. To account for thenon-isolated service water loads during the test, an equivalent surrogate flow isestablished on the system at a hydraulically remote location in the loopssupplying the flow test points. Thus, the surrogate load ensures the demand is inplace during the test, and should the actual non-isolated service water loadscause increased demand during the flow test, it results in an added conservatismto the flow test.With the water supply established, the flow test is conducted by measuring thestatic pressure, residual pressure and partial flow, residual pressure and full flow,and static pressure. The results are then plotted on semi-log graph paper to the1.85 power.The ASME program does not have a requirement to perform periodic flushes. TheASME piping is chemically treated as described in RAI FPR VII-2.1 and is a part of theHPFP piping testing described in this RAI response.[3] Additional piping and hose stations will be added in the following areas for Unit 2operation:1. Two sprinkler systems in the Unit 2 Reactor Building. These are pre-action sprinklersystems, normally dry with an air supervision of the piping.2. Two sets of hose stations in the Unit 2 Reactor Building. These hose stations arefed from a sprinkler system type deluge valve, thus they will normally be dry but willnot have air supervision.E1-37 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"3. Sprinkler system for the protection of the charcoal beds in the Unit 2 ContainmentPurge Air filter housing. This will be a pre-action sprinkler system, but will not haveair supervision.The Unit 2 completion project has a plan in place that will flush the five areas listedabove before transfer to Operations as discussed in the FPR, Part X, for compliancewith NFPA 13-1975, Section 1-11.1 thru 1-22.4.In addition, existing Unit 1 hose stations that are presently not required by the FPR toprovide protection to operating equipment will be re-classified to providing protection foroperating equipment when Unit 2 goes on line. These re-classified hose stations are inthe scope of the present Corrosion Control Program for raw water systems for Unit 1equipment and are being maintained as Unit 1 equipment. This reclassification hasbeen addressed in the as-designed dual unit FPR.[4] As evidenced by industry and WBN experience, carbon steel piping is subject to failuremechanisms such as MIC within the 40 year life of the plant. Thus, the CorrosionControl Program is designed to address prevention by chemical treatment, test forworsening conditions using different test methods, and repair problems found regardlessof the age of the piping. So, the same program elements are applied to the B trainheader that was replaced in 2005 as well as the A train header that is still the originalpiping with the exception of some code piping repairs that have been made. As leaksare found, a determination will be made as to whether the piping continues to meetASME requirements (inoperable or degraded/non-conforming), and repairs will be madein accordance with ASME code requirements.The piping to support Unit 2 operation is maintained under the programs describedabove (Letter Item 1. NRC Question [RAI FPR VII-2.1]) and thus will be capable offulfilling its design function for the full 40 year life of Unit 2.TVA has determined that the FPR does not require revision.28. NRC Question (RAI FPR V11-2.3)[1] Describe the conditions necessitating the replacement of the B train high pressure fireprotection header identified in TVA's response to RAI FPR VII-2 (in the May 26, 2011 TVAletter). [2] Also, identify the length of pipe replaced, the pipe material that was replaced,and what material it was replaced with. [3] Explain the conditions that would prevent thesame problem from affecting the A train header or the common (nonsafety) header, thusnecessitating its replacement as well.TVA Response:[1] The replacement of the entire B train HPFP header was not a requirement but wasinstead performed based on a cost/benefit analysis. The conditions that lead to thereplacement of the B train HPFP header was the identification of five leaks within aE1-38 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"17-month time frame. The location of some of these leaks was approximately 20 feetbelow grade. The expense and the location of the leaks made it less advantageous tomake the repairs in comparison to the re-route and replacement of the line. Thisresulted in the decision to replace a majority of the buried B train header.At the time (August 2002) the decision was made to replace a majority of the buriedB train header, there was not a buried pipe program, and guided wave testing was notavailable. The addition of this program and such technology may have called for thereplacement of the B train header at an earlier time. The Corrosion Control Program,through physical monitoring, found the leaks on the B train buried header.[2] Due to the re-routing of the B train header, approximately 5,000 feet of carbon steelpiping (ASTM SA106 Grade B, 0.375 inches wall) was replaced with 1,625 feet of extrastrong carbon steel pipe (ASTM SA106 Grade B, 0.5 inches wall) that has an exteriorepoxy coating.[3] The A train header has exhibited a smaller number of leaks than the B train. The leaksin both the A and B trains have been small leaks, which have not affected the overallintegrity of the pipe, nor affected the ability of the system to provide the required fireprotection flow. Attempts have been made to determine the difference in the buriedA train and B train headers. Differences that were considered included:1. Construction practices during initial installation;2. Use of the headers to support construction activities, such as filling other systems;3. Use of the headers to provide construction fire protection;4. Operational differences in how valves were positioned;5. How chemical treatment was performed on each header.No definitive explanation could be found to clarify the reason for the difference betweenoccurrence of leaks in the two headers. There is no definitive way to determine if theA train header will have to be replaced or not, but the Corrosion Control Program willcontinue to treat, test and maintain the A train header to obtain its maximum service life.The most recent leaks on the buried A train header are examples of leaks found bymonitoring by plant personnel. The leak that has been repaired was found by an AUOwhile doing normal plant (outside the buildings) rounds. The leak that has not beenrepaired yet was found during post maintenance testing of the repaired leak justmentioned above. The un-repaired leak was observed by plant personnel although thelocation is physically removed from the location of the repaired leak (approximately1,300 feet away with two changes in direction plus a hill between the two locations). Themonitoring for ground water leaks is performed by a variety of personnel either in thecourse of their assigned duties (e.g., AUOs are specifically tasked to look for leaksinside the buildings as well as when making periodic rounds outside the buildings) or sitepersonnel performing other duties observing unexpected conditions (some examplesinclude the abovementioned test personnel observing locations well outside the requiredtest boundaries, or in another situation, a leak was found by personnel performing yardmaintenance duties).E1-39 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"The common (nonsafety) related buried header from the IPS is ductile iron, cement linedpipe. This ductile iron pipe has not experienced the MIC issues of the carbon steel pipedue to the cement lining and does not require exterior coatings to protect it from the soilsin this area.29. NRC Question (RAI FPR V11-2.4)The TVA response to RAI FPR VII-2 part 5 (in the May 26, 2011 TVA letter) mentions awater treatment program to address problems due to the use of raw water, but does notprovide details of the program or discuss the effectiveness of the program.[1] Provide details concerning the raw water treatment program. [2] Justify theeffectiveness of the raw water treatment program at WBN in light of the continuedproblems with corrosion, wall thinning, MIC, biofouling, etc., experienced by the fire watersystem. [3] Describe any corrective actions taken or planned to improve programperformance.[4] Describe how the conditions of underground piping will be monitored, as well asacceptance criteria.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The details of the raw water program were provided in Letter Item 1 (NRC Question[RAI FPR VII-2.1]) above. The HPFP piping was not provided with the extensiveprogram of treatment, testing and maintenance during the construction phase whichhas resulted in historical concerns and problems that are being addressed at this time.The Corrosion Control Program has evolved since the licensing of Unit 1 and iscontinually evolving to find and improve the treatment of raw water systems, asevidenced by the addition of the Buried Pipe Program added in 2009. As new ordifferent technologies become available, the raw water program will evaluate theprocess outlined in NPG-SPP-09.7 or NPG-SPP-09.15 and incorporate, as appropriate.To better document the raw water program, the following revision for the FPR, Part II,Section 12.1 will be a part of the next revision to the FPR:Measures were taken to account and compensate for the effects of corrosion onpiping due to biological growth, such as MIC nodules by designing normally rawwater wetted, unlined carbon steel pipe using calculations that:1. reduced the pipe diameter to account for diameter reducing inclusions, and2. lowering the C-factor to C=55 in the Hazen-Williams formula to account for theadded roughness.The water used in both the HPFP and RCW system is chemically treated to addressconcerns resulting from the use of raw water. WBN has a comprehensive chemicalEl-40 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"treatment program for treating raw water systems. This treatment is a major part ofWBN Raw Water Corrosion Program as specified by site procedures. The chemicaltreatment is used to control corrosion, to control organic fouling, including slime, tominimize the effect of MIC and inhibit growth of Asiatic clams in carbon steel.Buried piping portions of the HPFP system are monitored by the buried pipingprogram in accordance with NEI 09-14, "Guideline for the Management ofUnderground Piping and Tank Integrity," which provides for the risk ranking ofburied piping relative to installed conditions (e.g., design and construction practices,as well as soil) and consequences of a failure and testing of the piping.Silt from river water is addressed for fire protection in two methods. One method isthe design of the IPS. For the fire pumps, water has to travel up two elevations,traverse the basin area that is just under one half the size of the IPS betweenelevation changes, and then there is a weir at the entrance to the fire pump wetwells. This relative movement of water to reach the fire pump wet wells allows forthe majority of the silt to drop out. The other method is the design of the RCWsystem which provides normal makeup for the HPFP system. The RCW systempumps draw water remotely from the water's entrance to the IPS allowing for siltsettlement. The cross tie of the RCW and HPFP is in the Turbine Building close tothe service water load on the HPFP system. Thus, silt drawn into the HPFP systemis in the paths of these service water loads.In 1995 (at licensing of Unit 1), a three year evaluation program was implemented tomonitor the performance of the HPFP system by yearly testing of the HPFPdistribution system. The results of this evaluation determined that testing on a threeyear basis (instead of yearly) was adequate (See Reference 4.2.60).[2] The Chemical Treatment for raw water systems including HPFP is described inresponse to NRC Question (RAI FPR VII-2.11). This treatment, which is consistent withother nuclear facilities, includes oxidizing biocide, non-oxidizing biocide, phosphate, andzinc. This treatment is effective on the HPFP piping that has been replaced to preventcorrosion, slime, and MIC. On the existing HPFP piping, the phosphate is used tosequester iron from existing corrosion products, the zinc is used to passivate the carbonsteel surfaces, and the oxidizing and non-oxidizing biocide will control slime which willhelp prevent MIC growth. This provides the most effective treatment that a nuclearplant may use to prevent corrosion in raw water systems.A description of the Chemical Treatment Program will be provided in the FSAR A106amendment.The leaks in both the A and B trains have been small leaks, which have not affected theoverall integrity of the pipe, nor affected the ability of the system to provide the requiredfire protection flow, and thus the program is considered effective.[3] The corrective actions that have been taken to improve program performance are pipereplacement as a part of the Corrosion Control Program, testing, and the Buried PipeEl-41 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"Program (established in 2009). The details and benefits of these actions are describedin response to NRC Question (RAI FPR VII-2.1).[4] The condition of the underground piping is monitored by the NPG-SPP-09.15, "BuriedPiping Integrity Program," as discussedin Letter Item 1 (NRC Question [RAI FPR VII-2.1], part 1) and the testing, as discussed in Letter Item 2 (NRC Question [RAI FPR VII-2.2], parts 1 and 2).The Corrosion Control Program cannot reverse the MIC issues of the past, and thusthere is no evidence of clean piping without new corrosion. Recently replaced pipinghas not been destructively tested (e.g., cut open for observation) to determine thestatus of the piping.30. NRC Question (RAI FPR V11-2.6)In its response to RAI FPR VII-2 in the letter dated May 6, 2011, TVA states, in part 4 of theresponse, that the three sets of standpipes tested by procedure 0-FOR-26-2 "3 Year HighPressure Fire Protection Hydraulic Performance Verification," have shown somedegradation; but that flow and pressure from the hose stations continue to meet acceptancecriteria. The response includes the data collected during flow testing from the auxiliarybuilding roof in January 2008 and from the diesel generator building roof and intakepumping station in August 2010.During the public meetings with the staff held on June 30 and July 12, 2011, TVA stated thatthere was a failure identified during the flow testing performed in August 2010. TVA alsostated in the July 12 meeting that the failure may have been caused by faulty testequipment.TVA stated at the meeting on June 30, 2011, that the failure led it to identify leakage in theTrain A high pressure fire protection safety-related header caused by microbiologicallyinduced corrosion (MIC).* [1] Describe how the failure discussed in the public meetings affects the previousresponse to RAI FPR VII-2.* [2] Describe the actions taken to confirm that the test failure was a result of faulty testequipment.* [3] Provide a detailed summary of the trending information for each of the monitoredhose stations.0 [4] Describe how the determination was made that the corrosion discovered in the TrainA header was caused by MIC.El-42 ENCLOSUREIResponse to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"IVA Response:[1] The public meeting discussions gave insight to provide additional detailed informationfor RAI FPR VII-2 provided in TVA letter dated May 26, 2011. The additional details aredocumented in TVA's responses to NRC questions RAI FPR VII-2.1, RAI FPR VII-2.2,RAI FPR VII-2.3, and RAI FPR VI, 1-2.4 provided in this letter.[2] As discussed in TVA response to RAI FPR VII-2.3 in TVA letter to NRC dated July 22,2011, the post calibration of the test equipment indicated the device was reading about45 GPM below the actual flow. To determine the actual conditions, the test of the hosestations for the Auxiliary Building will be re-performed summer 2011.[3] Please see the TVA response to RAI FPR VII-2.3.[4] For the two leaks that have been repaired on the buried A train header, as of this time,one was a holiday (failure of external protective coating) and the other is unknown. Theleak of unknown cause was in a location that resulted in the decision to reroute the pipeand abandon the leaking segment in place.31. NRC Question (RAI FPR VI1-12)It appears that the description of the Reactor Building Equipment Hatches (757. O-A 11 and757. O-A 15) in Part VII, Section 6.1.2 "Discussion and Justification," of the as-designed FPRis in conflict with the information in the balance of the FPR. For example, the descriptionidentifies Thermo-Lag installations in each of these rooms, but both Table I-1 and Part VI,Section 3.83.2.1, indicate that none is installed in room 757.0-A 15.Resolve these conflicts and provide assurance that other, similar conditions have beenidentified and corrected.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:The information in Section 6.1 refers to the various items that require inspections on aregular basis. Thermo-Lag is a material that requires an inspection on a regular basis. Thejustification was written to cover each room without specifying the specific items that are ineach of the two rooms. The current FSSD analysis does not require any electrical racewaysin 757.0-Al 5 to be protected with Thermo-Lag. There is no conflict since Table I-1 and PartVI, Section 3.83.2.1 are dealing with each room separately and the Part VII, Section 6.1 iswritten to cover both rooms generically. However, to remove any potentialmisunderstanding, Section 6.1 will be revised to read as follows:6.1.1 "The Reactor Building Equipment Hatches (757.0-Al1 and 757.0-Al 5) areinaccessible during plant operations; therefore, surveillance of sprinklers, Firedetectors, penetration seals and Thermo-Lag (757.0-Al 1 only) fire wrap cannot beperformed per the regular schedules."El-43 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"6.1.2 "The in situ combustible loading in the rooms is comprised of the insulation on thecable trays that traverse the room, the light covers on the lights in the room andThermo-Lag (757.0-Al 1 only) on conduits that pass through the room."This change will be included in the next FPR submittal.32. NRC Question (RAI FPR VI1-13)Part VII, Section 2.8 "Reactor Coolant Pump Oil Collection System," of the as-designed FPRstates, in part:In designing the oil collection system, it is not feasible in all instances toprevent minor amounts of oil from becoming entrained in the ventilation airand escaping the collection system. This oil becomes a thin film on pipingand supports in the vicinity of the RCPs [reactor coolant pumps].0 [11 Using Unit I operating experience, describe in detail all Unit I locations, outside theoil collection system, where RCP oil has been found. Provide the estimated amount ofoil discovered and if the oil was a fine film or pooling.* [2] Describe whether the capability exists to refill the RCP lube oil systems during poweroperation. If the capability does exist:" [a] Describe the amount of RCP lube oil added during operation, if any." [b] Describe whether the capability exists to drain the oil collection system duringoperation, thus ensuring that the collection system remains capable of containing thefull volume of RCP oil.0 [3] Using Unit 1 operating experience, provide the details of any preventativemaintenance activity or modifications that have been utilized to reduce or eliminate oilleaking outside the RCP oil collection system.0 [4] Describe, in detail, any design differences between the Unit I and Unit 2 RCP oilcollection system.* [5] Describe any physical or operational design differences between Unit I and Unit 2that could change the surrounding environment of the RCPs and affect the function ofthe RCP oil collection system.* [6] Identify the methods and procedures that Unit 2 will use to monitor the effectivenessof the RCP oil collection system during start up and operation. This includes possiblechanges to RCP maintenance and modification to the RCP oil collection system.This RAI may involve an update to the FPR to incorporate the response to the RAI.El-44 ENCLOSURE IResponse to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"TVA Response:[1] Unit 1 has not experienced any significant amount of oil outside the Oil CollectionSystem.[2] The capability does exist to refill the RCP lube oil systems during power operation buthas not been used or required because of the significant amount of dose that theemployees would incur. The capability does not exist to drain the RCP lube oil systemsduring power operation.[3] See response to sub question [1] above. The preventative maintenance (PM) activitythat is used on the RCP Oil Collection System is PM 0891W, "Reactor Coolant Pump OilCollection System Visual Inspection." This PM ensures every 18 months that the systemis capable of containing the full volume of the RCP oil. The PM that was created forWBN was based on Operating Experience (OE) from Sequoyah Nuclear Plant. Therehave not been any modifications since Unit 1 startup based on OE.[4] No design differences exist between Unit 1 and Unit 2 RCP Oil Collection Systems.[5] See response to sub question [4] above.[6] See response to sub question [3] above.TVA has determined that the FPR does not require revision.33. NRC Question (RAI FPR V11-14)Part VII, Section 2.8 "Reactor Coolant Pump Oil Collection System, "of the as-designed FPRdescribes the design of the oil collection system and the significant airflow environmentwhere the system has to function. The installation and design of the stainless steel mirrorinsulation and certain properties of the RCP oil is also discussed.* [1] Confirm that only noncombustible, nonpermeable stainless steel mirror insulation isinstalled on the RCPs and reactor coolant piping in the vicinity of the RCPs and that allmirror insulation panels are fitted together with overlapping seams and secured in place.[2] Provide the installation and material details of any RCP or reactor coolant pipinginsulation that does not meet the above criteria, and [3] provide a technical justificationfor acceptability.0 [4] Describe in detail the nearest ignition sources to the RCPs and locations similar towhere Unit I RCP oil has been found outside the oil collection system.* [5] Provide the fire point and auto ignition temperature for the type of RCP oil used atWBN Unit 2. Also, [6] provide a technical justification for acceptability.E1-45 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The original WBN Specification Number 1475 contains the requirements for reflectivemetal insulation inside Containment. Section 11.1 of the specification requires the useof a reflective type insulation and all-metal construction. Section 12.1 reinforces thematerial specification by stating all hardware shall be AISI type 304 austenitic stainlesssteel. Section 4.6 requires that the insulation shall have separate lap straps on all pipingwith at least 1-inch overlap on each insulation panel unit and utilize buckle-typeconstruction. Section 11.8 states that all insulation panels shall have quick-releaselatches. Unit 2 installation under Specification 25402-011-3PS-NNPO-00001 meets theUnit 1 criteria. Unit 2 work has not yet been completed.The previously mentioned sections of Specification Number 1475 are also found invendor manual WBN-VTD-D1 50-0070. Diamond Power Drawings for the ReactorCoolant Pump, Reactor Coolant Cold and Interim Leg are as follows:590955-031C Shts. 1-4 "RC Pump General Arrangement"590955-032C Shts. 1-4 "RC Pump Insulation Development"590955-033C Shts. 1-4 "RC Pump Bottom Head Development"590955-034C Sht. 2 of 2 "RC Pump Insulation Support Steel"590955-034S Sht. 1 of 2 "RC Pump Insulation Support Steel"590955-040C Shts. 1-4 "Reactor Coolant Interim Leg"590955-042C Shts. 1-4 "Reactor Coolant Cold Leg"[2] There is no RCP or reactor coolant piping that does not meet the above criteria.[3] See response to sub question [2] above.[4] The nearest ignition sources to the RCPs are the RCP Motors. As stated in response toNRC Question (RAI FPR VI1-13), Unit 1 has not experienced any significant amount ofoil outside the oil collection system.[5] The Flash Point of Mobil, ASTM D92 is 478.40 F. The fire point and auto ignitiontemperature has not been determined by Mobil; however, Mobil stated that the fire pointis approximately 50 -750 F above the Flash Point (approximately 528.4 -553.40 F) andauto ignition temperature is approximately 1500 F above the Flash Point (approximately628.4 F).[6] The technical justification for acceptability is that the RCP oil is a NFPA 30 Class IIIBliquid, the oil is enclosed in the motor, a RCP Oil Collection System is capable ofcontaining the full volume of the oil, and there is detection and suppression. The RCSpiping is operating at a temperature of approximately 5570 F, which is at the fire point of5530 F but below the auto ignition of 6280 F of the oil used. In addition, the mirrorinsulation does not aspirate the oil like the fiber insulation. The temperature rating of theEl-46 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"oil used, the stainless steel overlapping joint straps, and the lack of ignition sourcesmakes the oil used acceptable.TVA has determined that the FPR does not require revision.34. NRC Question (RAI FPR VII-15)Part VII, Section 2.8 "Reactor Coolant Pump Oil Collection System, " of the as-designed FPRstates, in part:In designing the oil collection system, it is not feasible in all instances toprevent minor amounts of oil from becoming entrained in the ventilation airand escaping the collection system. This oil becomes a thin film on pipingand supports in the vicinity of the RCPs.[1] Discuss the actions that will be taken with regard to manufacturers' recommendations toeliminate or significantly reduce oil misting and [2] the controls in place to assure RCP oil ofdifferent (more combustible) properties will not be used in the future.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The design of the RCP Oil Collection System took into consideration Westinghouse'srecommendations to address oil collection system problems, and Westinghouse did nothave any recommendations to reduce oil misting. As stated in response to NRCQuestion (RAI FPR VII-13), Unit 1 has not experienced any significant amount of oiloutside the oil collection system.[2] TI-78, "Lubrication Program," requires that an evaluation be performed if the oil type ischanged. Based on this procedure, controls are in place to ensure the RCP oil meetsthe proper criteria, including fire protection.TVA has determined that the FPR does not require revision.35. NRC Question (RAI FPR VI1-16)The terms "embedded duct" and "embedded collector box" are used throughout Part VII,Section 6.2 "Justification for Fire Damper Surveillance Requirements, "of the as-designedFPR, and its subsections.Explain what "embedded" means in this context.This RAI may involve an update to the FPR to incorporate the response to the RAI.E1-47 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"TVA Response:Embedded means that the duct and collector box were installed prior to the concrete wallbeing poured and that they are embedded in the concrete.TVA has determined that the FPR does not require revision.36. NRC Question (RAI FPR VI1-17)Part VII, Section 6.3.1 "Statement of Condition," of the as-designed FPR, states, in part: "Aportion of the gap between the door and frame of fire door W9 exceeds the maximum 3/16-inch clearance," but does not continue to identify the extent of the nonconforming condition.[1] Identify the maximum gap for fire door W9 and [2]justify why it is acceptable.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The maximum gap for fire door W9 is 7/32-inch (1/32-inch over the allowable) and isalong the top of the door on the right hand side looking in. The length of the gap isapproximately 181/4 inches.[2] The justification for the acceptability of this gap is documented in Part VII,Sections 6.3.2 and 6.3.3 (FPR update submitted to NRC as part of the 1999 U1 UFSARupdate). As can be seen in the FPR, the justification and conclusion state there is nocredible exposure fire that would impact the door. TVA considers this to still be validand no update to the FPR is needed.37. NRC Question (RAI FPR VII1-13. 1)The reviewers intended RAI FPR VII1-13 to cover testing and operability requirements of firehydrants. However, the RAI was ambiguously worded. The TVA response to RAI FPR VIII-13 (in the May 26, 2011 TVA letter) thus did not answer the intended question, but insteadan alternate interpretation. This follow-up seeks to correct this miscommunication.[1] Confirm that all hydrants, as identified in Part VIII, entry F. 16, of the as-designed FPR,that are used to provide "protection to the refueling water storage tanks and the primarywater storage tanks" are listed in Part II, Table 14.7. [2] Otherwise, add these hydrants tothe table or document the operability requirements and testing and inspection requirementsthat apply to these hydrants. [3] If these hydrants are not added to Table 14.7, describe thedifferences in operability requirements and testing and inspection requirements of thesehydrants and those in the Table.This RAI may involve an update to the FPR to incorporate the response to the RAI.E1-48 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"TVA Response:[1] Appendix A to BTP 9.5-1 states storage tanks that supply water for safe shutdownshould be protected from the effects of fire. The refueling water storage tank (RWST) islocated in the yard area with the immediate fire exposure being from the grass about10 feet away from the tank, the instrumentation associated with the tank and the powerfor the submersible heaters in the tank. The valves for the RWST are located below thetank itself underground and protected from the effects of fire by the ground and tank.The tank is shielded from the nearest road by a concrete wall. Based on this design andthe administrative controls provided by NPG-SPP-18.4.7, "Control of TransientCombustibles," the fire hydrants in the immediate area of the Unit 1 and Unit 2 RWSTare not identified in the FPR, Part II, Table 14.7. The BTP goes on to say that a tanksuch as the RWST "should" be provided with a local hose station, but does not requirethem. Thus TVA took the position to not include a fire hydrant in lieu of a hose station,since the protection was provided by the limited ignition sources and exposure. Inaddition, the primary water storage tank (PWST) does not supply water for safeshutdown. The as-designed FPR, Part VIII, F.16, "Plant Conformance," will be revisedto remove the reference to the PWST, and this revision will be included in the next FPRsubmittal.[2] The fire loading in the area of the RWST is low and there is a thermal barrier (i.e.,concrete wall between the only normal combustible exposure and the RWST). Based onthis information, there is no reason to add the fire hydrants to the FPR, Part II,Table 14.7.[3] The hydrants near the Unit 1 and Unit 2 RWSTs have the following tests and inspectionsthe same as the hydrants in FPR, Part II, Table 14.7:1. Flushed in coordination with the chemical treatment program two times per year, onein the spring and one in the fall.2. Operate/cycle hydrant and isolation valve and ensure smooth proper operation;lubricate caps' threads and hydrant operating mechanism; flush the hydrant andverify drainage; inspect area for obstructions and remove; and ensure caps will holdunder pressure two times per year, one in the spring and one in the fall.3. The hydrant near the Unit 2 RWST is flow tested once every 3 years.The hydrants contained in the FPR, Part II, Table 14.7, receive the following additionaltests and inspections; the other hydrants (i.e., non-FPR) do not:1. A visual inspection that the hydrants are accessible and no apparent physicaldamage every 6 months in accordance with TIR 14.7.c.2. Flow test of hydrants once every 3 years.El-49 ENCLOSURE1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"38. NRC Question (RAI FPR V111-14.1)The reviewers intended RAI FPR VIII-14 to cover testing and operability requirements of firehydrants. However, the RAI was ambiguously worded. The TVA response to RAI FPR VI/I-14 (in the May 26, 2011 TVA letter) thus did not answer the intended question, but insteadan alternate interpretation. This follow-up seeks to correct this miscommunication.[1] Confirm that all hydrants, as identified in Part VIII, entry F. 17, of the as-designed FPR,that are used to provide "support manual fire suppression activities around the coolingtowers" are listed in Part /I, Table 14.7. [2] Otherwise add these hydrants to the table ordocument the operability requirements and testing and inspection requirements that apply tothese hydrants. [3] If these hydrants are not added to Table 14.7, describe the differences inoperability requirements and testing and inspection requirements of these hydrants andthose in the Table.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The cooling towers at WBN are of noncombustible construction; therefore, the secondparagraph of F.17 does not apply. The manual fire suppression activities around thecooling towers are not an Appendix R requirement since there is no safe shutdownequipment in this area.[2] The hydrants will not be added to the table and they have no special operability, testingor inspection requirements that are associated with the ability to safely shut down theplant in the event of a regulatory postulated fire (i.e., an Appendix R fire).[3] Fire hydrants listed in the table are required to support manual fire suppression forcomponents required for FSSD. The fire hydrants near the cooling towers are notrequired to support manual fire suppression for components required for FSSD (i.e., thecooling towers are not required for FSSD nor do they present a hazard to FSSD).TVA has determined that the FPR does not require revision.39. NRC Question (RAI FPR V111-17.1)RAI FPR VIII-17 requested conformance information regarding detailed guidance regardingseismically qualified standpipes and hose stations. The TVA response to RAI FPR VIII-17(in the June 7, 2011 TVA letter) did not supply this information, instead referring to an earlierRAI response.Provide plant conformance information for the detailed guidance regarding seismicallyqualified standpipes and hose stations in the paragraph that begins: "The standpipe systemserving such hose stations..." at the end of entry E.3.d, in Part VIII "Appendix A Guidance,"of the FPR and reproduced below.E1-50 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"The standpipe system serving such hose stations should be analyzed for SSE[safe-shutdown earthquake] loading and should be provided with supports toassure system pressure integrity. The piping and valves for the portion of hosestandpipe systems affected by this functional requirement should at least satisfyANSI [American National Standards Institute] B31.1, "Power Piping." The watersupply for this condition may be obtained by manual operator actuation of valve(s)in a connection to the hose standpipe header from a normal Seismic Category Iwater system such as Essential Service Water System. The cross connectionshould be (a) capable of providing flow to at least two hose stations (approximately75 gpm/hose station), and (b) designed to the same standards as the SeismicCategory I water system; it should not degrade the performance of the SeismicCategory I water system.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:See response to Question No. 9, NRC RAI FPR 11-41.1.40. NRC Question (RAI FPR VIII-20)A change was made to Part VIII, entry F. 1.B, of the FPR to change the "Plant Conformance"entry from:Administrative procedures limit the amount of combustible materials within thearea and control hot work activities. [emphasis added]to:Administrative procedures control the type of combustible materials within thearea and control hot work activities. [emphasis added]It appears that this change was made between Revision 40 and the as-designed version ofthe FPR.The NRC position is that administrative procedures for combustible control should have bothof these attributes (limiting the amount and controlling the type of combustible materials), asdescribed in Regulatory Guide 1.189, Revision 2 regulatory position 2.1.Confirm that the procedures for WBN unit 2 consider both of these attributes. If not, provide.a technical justification for this change.This RAI may involve an update to the FPR to incorporate the response to the RAI.El-51 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"TVA Response:NPG-SPP-18.4.7, "Control of Transient Combustibles," is the TVA procedure to addresscontrol of transient materials for the present operating Unit 1 and the under constructionUnit 2. In the procedure, limitations are provided on material type and amount. As anexample, a distinction is made between flammable and combustible liquids as to thequantity that can be stored outside an approved storage room due to a work activity. Toaddress this concern the FPR, Part VIII, F.1 .B, Plant Conformance column will be revised toread:Administrative procedures limit the amount and control the type of combustible materialswithin the area and control hot work activities.This change will be incorporated into the next submittal of the FPR.41. NRC Question (RAI FPR Vi11-21)The NRC determined that the WBN fire protection program was acceptable, in part, due tothe use of noncombustible insulating liquid in transformers in safety related buildings.SSER 18 (ADAMS No.ML070530364) states, in part:Transformers insulated with Askarel oil (a noncombustible insulating liquid) arelocated in various areas of the plant without being located in a separate room.Near these transformers are various redundant safety-related cable trays orconduits or both.andThe staff finds that the applicant's proposed use of transformers filled withnoncombustible insulating liquid conforms to the guidelines of Position D. 1.g ofAppendix A to BTP (APCSB) 9.5-1 and, therefore, is acceptable.Element D. 1.g of NRC BTP 9.5-1 APCSB Appendix A (Adams No. ML070880458) states inpart:High Voltage -High amperage transformers installed inside buildings containingsafety-related systems should be of the dry-type or insulated and cooled withnoncombustible liquid. [emphasis added]Part VIII of the as-designed version of the FPR states the following in the "PlantConformance" column of the table:High Voltage -High amperage transformers are not installed within buildingspaces. Transformers installed within safety-related buildings are either dry-typeor insulated and cooled with "high fire point" (650 F) liquid. [emphasis added]El-52 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"The underlined text does not describe conformance, but rather an alternative.0 [1] Describe TVA's understanding of the term "high voltage -high amperagetransformers" as used in the Appendix A to BTP 9.5-1 Guidelines.* [2] Confirm the insulating liquid used in transformers installed in safety related buildingsis noncombustible.If the insulating liquid is not noncombustible,* [3] Identify the locations where combustible oil filled transformers are installed. Providethe locations to the level of detail of room subdivisions used to assemble analysisvolumes (for example, room 692.0-Al has been subdivided into 692.0-A 1A1, -A IA2,-AIA3, -AIAN, -AIBI, -AIB2, -AIB3, -A1BN and -AIC).* [41 Provide a technical justification for this deviation for each analysis volume containingcombustible oil filled transformers. Each justification should include, but not be limitedto, consideration of: fire protection features (i.e., detection and suppression), fire ratedbarriers, nearby safe shutdown equipment or components, smoke effects, diking, andeffects on manual actions that require reentry or transit of the area.This RAI may involve an update to the FPR to incorporate the response to the RAI.NRC Follow-up Questions Provided in July 28, 2011 Public Meetinq:The following needs to be addressed in relation to the issue on the indoors transformers'dielectric fluid being changed from a PCB fluid to a silicone fluid:1. Are any transformers in areas where spatial separation is provided and not a physicalbarrier?2. How quickly will the transformer dike area overflow if the sprinkler system is inoperation? In particular if just one or two heads are flowing and exceeding the minimumdesign density coverage?3. If the transformer's diked area over flows, where will the drainage go, to another trainarea?TVA Response:[1] As specified in TVA design documents and in industry documents such as ANSI C84.1,"American National Standard for Electric Power Systems and Equipment-VoltageRatings (60 Hertz)," these 6.9kV transformers are not classified as "high voltage-highamperage." ANSI C84.1 classifies transformers as "medium voltage" when the nominalsystem voltages are greater than 1,000 volts and less than 100kV. ANSI C84.1classifies "high voltage" as 100 kV and equal to or less than 230 kV.E1-53 ENCLOSURE 1Response to NRC's Round 5 Request for Additional Information Regarding"Fire Protection Report"[2] The insulating liquid used in the safety-related buildings is not a PCB noncombustibleliquid. The insulating liquid is a high flash point silicone liquid that is combustible but isnot flammable in accordance with the definition of flammable and combustible providedby the National Fire Protection Association (NFPA) 30, "Flammable and CombustibleLiquids Code." The change from a PCB liquid to a silicone liquid was done before thefuel load of Unit 1 and was documented in the FPR, Revision 4, Part VIII. This changefrom a PCB fluid to a silicone fluid was to address environmental concerns and reduceeconomic impact of a spill. The liability of having the PCB liquids was ill advised, as anyspill of a PCB liquid has a large economic impact, but one in the radiological controlledarea would have had an excessive economic impact.[3] The locations of silicone oil filled transformers are listed below:El-54 ENCLOSURE 1Response to NRC's Round 5 Request for Information Reqardina "Fire Protection Report"Released GrossNet Oil Sprinkler Flow in DikeFire Gal of Oil in Dike Area Contain Area Appx time to dike Drain inTransformer Location Area AV Oil Cu-FtA'B Sq-Ft Volume Cu-Ft c Cu-Ft/Min D area overflow AV1-OXF-68-341D-B 782-A4 75 96 163 21.8 82 36.6 2.81 5.3 min N/Al-OXF-68-341H782-A4 75 96 163 21.8 187 75.7 4.1 13.1 min N/A2-OXF-68-341H2-OXF-68-341D-B2-OXF-68-341A-A 782-A2 25 51 163 21.8 78.8 35 2.7 4.9 min N/A1-OXF-68-341F782-A2 25 51 163 21.8 186 75.5 4.1 13.1 min N/A2-OXF-68-341F1-OXF-68-341A-A1-OXF-212-B-B 772-A5 36 63 317 42.4 263 124 4.1 19.9 min N/A1-OXF-212-B 1-B772-A5 36 63 317 42.4 393 181 4.1 33.8 min N/A1-OXF-212-B2-B1-OXF-212-Al-A772-A6 37 64 317 42.4 393 185 4.1 34.8 min N/A1-OXF-212-A2-A1-OXF-212-A-A772-A6 37 64 317 42.4 378 176 4.1 32.6 min N/AO-OXF-206-A772-All 4168 317 42.43961874.135.3 minN/A2-OXF-212B-BE1-55 ENCLOSURE 1Response to NRC's Round 5 Request for Information Regarding "Fire Protection Report"FireLocation AreaReleasedGal of Oil inAV Oil Cu-FtABGrossDike AreaSq-FtNet OilContainVolume Cu-Ft cSprinkler Flow in DikeAreaCu-Ft/Min DAppx time to dikearea overflowDrain inAVTransformer0-OXF-206-B2-OXF-212-B1-B772-All 41 68 317 42.4 414 194 4.1 40 min N/A2-OXF-212-B2-B2-OXF-212-A2-A772-A12 42 69 317 42.4 415 195 4.1 37.2 min N/A2-OXF-212-Al-A2-OXF-212-A-A 772-A12 42 69 317 42.4 288 138 4.1 23.3 min0-OXF-228-1 737-AIA 14 36 139 18.6 39.4 19.7 1.35 0.8 min Yes0-OXF-228-2 737-AlB 14 38 139 18.6 39.1 19.6 1.35 0.7 min Yes0-OXF-228-3 692-Al 1 2 139 18.6 36.2 18.1 1.24 N/A Yes0-OXF-228-4 692-Al 1 5 139 18.6 38.7 19.4 1.32 0.6 min Yes0-OXF-226-A IPS 60 89 323 43.2 100 45.6 3.42 0.7 min Yes0-OXF-226-B IPS 60 89 323 43.2 100 45.6 3.42 0.7 min YesGeneral Notes:A If a transformer shares a diked area with another transformer it is assumed only one transformer has failed and leaked its contents.B Assumed that one transformer releases all of its oil into the diked area and none is retrained in the transformer.C Based on dike curb height of 6 inches. Volume reduced due to blockage (e.g., transformer pedestal or large hanger in dike area).D Sprinkler head flow into dike area based on dike size and GPM/sq. ft. flowing at 30 PSIG.E1-56 ENCLOSURE1Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"The above table is based on one sprinkler head flowing and a pump pressure of135 PSIG at approximately El. 724. The sprinklers heads used at WBN have a K=5.6.The assumptions are:1. The transformers listed have curbing that will hold the entire dielectric fluidexcept for one (see discussion below) and are protected with automatic detectionand suppression.2. Transformers grouped together are in the same diked area but only onetransformer is expected to release all its dielectric fluid.3. Only one head is expected to open due to the low rate of heat release (RHR) andthe quick extinguishment in accordance with vendor information documentedbelow.4. The sprinkler flow is based on a head pressure of 30 PSI or 31 GPM for theK=5.6 heads used at WBN. This is equal to 0.256 GPM/sq. ft. for 120 sq. ft.coverage heads. The 30 PSI was selected based on the maximum pressureshown for standard spray sprinkler heads in testing coverage capability. Asprinkler head flow based on pressure, adjusted for elevation, of two fire pumpsrunning maintaining a pressure of 135 PSIG at approximately El. 724 wouldresult in a flow of 57 GPM or 93 feet per second, which is unreasonable.5. The flow from the head is distributed over 120 sq. ft.6. The diked area will receive flow coverage at the specified density. If the dikedarea is greater than 120 sq. ft., only the flow of one head will be expected to flowinto the diked area due to the low rate of heat release with the cooling effect ofone head flowing.[4] These transformers are provided with curbing of sufficient height to capture the entirevolume of dielectric fluid should it leak out of the transformer except for one transformer.As part of preparing the response to this RAI, it was identified that one curb will have a3.7 gallon spill over into the floor and flow to the floor drain approximately six feet in frontof the transformer. WBN has initiated a corrective action program document(SR 412174) to document this condition. The area around these transformers isprotected with smoke detection that annunciates to a constantly attended location and apre-action sprinkler system. This dielectric fluid is a Dow 561 silicone transformer liquidand is an acceptable substitute for a PCB fluid based on the following from the vendorinformation:1. The dielectric fluid has a high flash point (650 degrees F) combustible liquid and wasincluded in the combustible loading calculation.2. The silicone fluid reaches maximum sustained RHR after ignition, and the RHR ismaintained for 10 to 15 minutes at which time the RHR decreases with time even ifextinguishment is NOT attempted. The decreasing RHR is not like a typicalhydrocarbon that reaches steady state until the hydrocarbon is consumed. Thisdecreasing RHR with time is the result of the progressive formation of a crust of ashand silica that forms over the surface during a pool fire.E1-55 ENCLOSURE 1Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"3. The silicone fluid RHR is 10 to 18 times lower than the average value forhydrocarbons. An independent test lab documented the RHR for the561 transformer fluid was 109 kW/sq. m., but for a high FP hydrocarbon it was1,270 kW/sq. m.4. Silicone fluid fires are extinguished in 20 to 30 seconds with a water application of0.15 gpm/sq. ft. The sprinkler systems designed to provide protection for thesetransformers are designed to have a minimum water coverage of 0.16 gpm/sq. ft.Thus, for the transformer dikes that contain the oil, the sprinkler system willextinguish any burning silicone fluid before the diked area overflows. For the onearea that will overflow if the transformer's entire contents are spilled and less thanfour gallons overflows to the floor drain, the material will still be in the sprinklercoverage area and be extinguished.5. The smoke from a silicone fluid fire is typically 3 to 5 times less dense thanhigh-fire-point hydrocarbon smoke.6. As an example of the reduced risk of the silicone fluid, the Dow vendor's manualdiscusses a Factory Mutual study that determined the separation requirements for atypical fluid-insulated distribution transformer fire from a wooden structure. See thefollowing table for the separation recommendations:Fluid FM suggested separation from awooden structureSilicone 8 ft.High Molecular Weight 39 ft.HydrocarbonMineral Oil 49 ft.7. These transformers were filled with a PCB (Askarel) dielectric fluid, thus the siliconefluid's flash point is not lowered by contamination by the PCB material as wouldhappen if the previous liquid had been a mineral oil.TVA has determined that the FPR does not require revision.42. NRC Question (RAI FPR X-4)A sampling review of the NFPA 13-1975 compliance matrix in Part X of the as-designedFPR identified the following:" Items 1-11.5 and 3-12.1.5 are identified as "Deviations" in the matrix, but detail is notprovided after the matrix for these items.* Item "3-14.2.1 thru 3.4" is identified as a "Deviation" in the matrix, but detail is notprovided after the matrix for this item. Additionally, other, similar, items (for example 3-14.5 and "3-14.1.5 thru 1.8') are identified as "Alternatives."E1-56 ENCLOSURE IResponse to NRC's Round 6 Request for Information Reqarding "Fire Protection Report"[1] Resolve these conflicts and [2] provide assurance that other, similar conditions havebeen identified and corrected.This RAI may involve an update to the FPR to incorporate the response to the RAI.TVA Response:[1] The following has been added at the end of the compliance matrix for NFPA 13 andwill be included in the next FPR submittal.Section 1-11.5 DeviationThe 2 inch main drain test was not performed at Watts Bar because the design didnot account for how to move the water from inside the safety related structures.The main purpose of the 2 inch main drain test is to ensure valves in the supplyline are not closed due to mis-positioning or valve failure. At Watts Bar the mis-positioning is addressed by the rigid controls placed on configuration control andprocedure use and adherence. The design will not allow for a meaningful 2 inchmain drain test; however, operational controls are greater than normal industryinstallations and the installed equipment is less susceptible to blockage failure andWBN considers this acceptable.Section 3-12.1.5 DeviationFlange joints on risers are not provided on each floor. The piping design andinstallation are in accordance with WVA seismic criteria that exceed the intent ofthis section.Section 3-14.2.1 thru 3.4 DeviationHangers in concrete are in accordance with TVA structural criteria that exceed theintent of this section.The referenced sections that use an "Alternative" means of complying with thecode are adequately addressed in the remarks section. Fire protection piping insafety related areas at WBN is designed in accordance with ANSI B 31.1, "PowerPiping" per guidance in BTP-APCSB 9.5-1, which exceeds the criteria in thissection of the code.[2] A review of the codes evaluated in Part X (i.e., NFPA 12, 13, 14, 20, 24, 30, 72D, &72E) concluded that only items 1-11.5, 3-12.1.5, 3-14.2.1 thru 3-14.3.4 for NFPACode 13 were not addressed at the end of the compliance matrix. TVA concluded thatthe items 3-14.5 and 3-14.1.5 thru 3-14.1.8 identified as "Alternatives" are adequatelyaddressed in the "Remarks" column, which is consistent with the other items identifiedas "Alternatives." Additionally, the other sections of the codes evaluated in Part X thatare identified as "Alternative" are also adequately addressed.E1-57 ENCLOSURE 1Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"ATTACHMENTSimplified Sketch of the HPFP SystemE1-58 ENCLOSURE 2Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"Regulatory Commitments1. The following will be added at the end of the table and will be included in the next FPRsubmittal: (Letter Item # 1, NRC Question RAI FPR I-1)* Combustible load fire severity is assumed to be comparable to the correspondingUnit 1 room. At the completion of construction, a walkdown of these rooms will beconducted to verify the in situ combustibles located in the rooms, and the Table will berevised as necessary.2. FPR Part I, Table I-1 and Part VI, Sections 3.21.1 and 3.22.1 have been revised to correctthese conflicts and will be included in the next FPR submittal. (Letter Item # 2, NRCQuestion RAI FPR 1-23. Table I-1 and other applicable parts of the FPR were reviewed to ensure consistencybetween the parts of the report, and corrections have been incorporated into the FPR andwill be included in the next FPR submittal. (Letter Item # 2, NRC Question RAI FPR 1-2)4. The FPR will be clarified to update the verbiage for these fire detectors and will be includedin the next FPR submittal. (Letter Item # 7, NRC Question RAI FPR 11-37.1)5. The information from Revision 41 of the FPR is correct. The rooms that are "Inaccessibleonly during a resin transfer" should have a single "*." The rooms that are "Refer to Part VIIfor engineering evaluations should have a double "**." This has been corrected and willshow the correct information in the next "As-Designed" FPR submittal. (Letter Item # 10,NRC Question RAI FPR 11-43)6. FPR Part II, Subsection 4.2, "TVA Documents," has been revised to reference the following:4.2.66 WBPEVAR9509001 -Appendix R-Multiple High Impedance Fault AnalysisThis reference, as well as adding a sentence to the text of the FPR to refer to this referencewill be included in the next "As-Designed" FPR submittal.(Letter Item # 13 NRC Question RAI FPR 111-15)7. The evaluation of fire hazards due to a fire-induced open circuit in the secondary of CTsinstalled in high energy panels (i.e., 6.9kV switchgear) included non-required as well asrequired power systems as may be seen by the content of other paragraphs of Section 7.5.The sentence containing the subject statement will be revised to provide clarification asfollows: "Fire hazards due to a fire-induced open circuit in the secondary of CTs installed inhigh energy panels (i.e., 6.9kV switchgear) of the required and non-required power systemshave been evaluated." This revision will be included in the next FPR submittal. (Letter Item# 14, NRC Question RAI FPR 111-16)8. The methodology used for the fire hazards analysis for CTs as a potential source ofsecondary fires due to open circuiting of the secondary circuit generally consists ofperforming an evaluation to identify CTs that are constructed such that an open secondarycircuit could cause ignition of the transformer and to further identify those CTs susceptible toE2-1 ENCLOSURE2Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"Regulatory Commitmentsignition which have secondary circuits extending outside of the fire area to verify they areeither isolated or protected. The evaluation includes but is not limited to review of thedesign configurations of CT circuits as follows:a. Verify by review of design documentation the CT secondary circuit is contained whollywithin the fire area containing the switchgear, orb. Verify by review of design documentation those CT circuits which extend beyond the firearea containing the switchgear are isolated by transducers such that an open circuitdownstream of the isolation device would not cause failure of the CT, orc. Verify by review of design documentation that the CT is used in a differential protectiverelay circuit such that an open circuit condition would initiate a protective relay actuationto trip the feeder breaker for the power circuit and thereby remove current to the CT.This information will be incorporated into Part IlI, Section 7 and included in the next FPRsubmittal. (Letter Item # 14, NRC Question RAI FPR 111-16)9. The following design changes will be implemented prior to Unit 2 fuel load or startup, asapplicable:EDCR 53217; EDCR 53287; EDCR 53288; EDCR 53290; EDCR 53291; EDCR 53292;EDCR 53293; EDCR 53296; EDCR 54103; DCN 52606; EDCR 54795; EDCR 54796;EDCR 54797; EDCR 54798; EDCR 54799; and EDCR 54819(Letter Item # 15, NRC Question RAI FPR 111-17)10. FPR Part V, Section 2.1.2 is revised to remove the ambiguous statement "OMAs forimportant to safe shutdown components require no further detailed evaluation." Feasibilityand reliability evaluations are performed for both important to safe shutdown and safeshutdown path component OMAs. The OMA evaluations for the safe shutdown path arecontained in FPR Part VII, Section 8.2, while the important to safe shutdown evaluations arecontained in a separate calculation. This split of the documentation was suggested by theNRC reviewers.Assumption number 3 (also in Section 2.1.2) will be revised to read as follows, "OperatorManual Actions with a required completion time (allowable time) of 120 minutes or greaterhave adequate time for feasible and reliable performance and can be excluded fromperformance validation demonstrations."These changes will be included in the next FPR submittal (Letter Item #19, NRC QuestionRAI FPR V-15)11. Feasibility and reliability evaluations of OMAs involving components in the safe shutdownsuccess path with an allowable completion time less than 120 minutes are included inFPRPart VII, Section 8 for staff review. This change will be included in the next FPR submittal.(Letter Item # 19, NRC Question RAI FPR V-15)E2-2 ENCLOSURE2Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"Regulatory Commitments12. TVA will review the WBN analysis and, as necessary, will make similar changes to Part VIfor any additional analysis volumes exhibiting a similar condition in the next FPR revision.(Letter Item #21, NRC Question RAI FPR VI-6.1)13. FPR Part Ill, Table 3-3 and Part VI, Sections 3.84.3.2 thru 3.84.3.12 will be updated toclarify the 2RO and 2RI quadrants included in each analysis volume, and these changes willbe included in the next FPR submittal. (Letter Item #22, NRC Question RAI FPR VI-7.1)14. Evaluations of the Annulus identified the specific locations of the end users and the isolationvalves for the ACAS headers and determined that there is no credible fire that could causefailure of the end users and the ability to close (from the MCR) the isolation valves (they areseparated by at least 30 feet (horizontal distance) and multiple layers of automaticsuppression and detection). Therefore, the ACAS is no longer considered to be lost and thereferences to the Unit 2 components being affected are being removed. This will beincluded in the next FPR submittal. Calculation WBPEVAR9602001 will also be revised todocument this evaluation. (Letter Item # 23, NRC Question RAI FPR VI-9)15. A fire inside primary containment is assumed to damage ACAS end users creating a fewsmall leakage paths. However, since the ACAS is supplied from both the large station aircompressors and the ACAS compressors, these leaks will not depressurize the opposite unitACAS headers. These manual actions are no longer required and will be removed from theassociated analysis volumes in the next FPR submittal. (Letter Item # 24, NRC QuestionRAI FPR VI-10)16. The details for the repair of the RHR valves for Unit 1 and Unit 2 will be documented in FPRPart V, Section 3.3 and will be included in the next FPR submittal. (Letter Item # 25, NRCQuestion RAI FPR VI-1 1)17. Part VI was reviewed and will be revised as necessary in the next revision to the FPR toensure the references to "repair procedure" contain a consistent level of detail and this willbe included in the next FPR submittal. During this review, TVA also noted that severalreferences were made to "See Remarks". These references have also been corrected toprovide the relevant information. (Letter Item # 25, NRC Question RAI FPR VI-1 1)18. To accurately determine the capability of the HPFP system, this section of the test will be re-performed summer 2011. (Letter Item # 27, NRC Question RAI FPR VII-2.2)19. Additional piping and hose stations will be added in the following areas for Unit 2 operation.(Letter Item # 27, NRC Question RAI FPR VII-2.2)a. Two sprinkler systems in the Unit 2 Reactor Building. These are pre-action sprinklersystems, normally dry with an air supervision of the piping.b. Two sets of hose stations in the Unit 2 Reactor Building. These hose stations are fedfrom a sprinkler system type deluge valve, thus they will normally be dry, but will nothave air supervision.E2-3 ENCLOSURE2Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"Regulatory Commitmentsc. Sprinkler system for the protection of the charcoal beds in the Unit 2 Containment PurgeAir filter housing. This will be a pre-action sprinkler system, but will not have airsupervision.20. To better document the raw water program, the following revision for the FPR, Part II,Section 12.1 will be a part of the next revision to the FPR (Letter Item # 29, NRC QuestionRAI FPR VII-2.4)21. A description of the Chemical Treatment Program will be provided in FSAR A106amendment. (Letter Item # 29, NRC Question RAI FPR VII-2.4)22. To determine the actual conditions, the test of the hose stations for the Auxiliary Building willbe re-performed summer 2011. (Letter Item # 30, NRC Question RAI FPR VII-2.6)23. There is no conflict since Table I-1 and Part VI, Section 3.83.2.1 are dealing with each roomseparately and the Part VII, Section 6.1 is written to cover both rooms generically. However,to remove any potential misunderstanding, Section 6.1 will be revised to read as follows:6.1.1 "The Reactor Building Equipment Hatches (757.0-Al1 and 757.0-A15) areinaccessible during plant operations; therefore, surveillance of sprinklers, Firedetectors, penetration seals and Thermo-Lag (757.0-Al 1 only) fire wrap cannot beperformed per the regular schedules."6.1.2 "The in situ combustible loading in the rooms is comprised of the insulation on thecable trays that traverse the room, the light covers on the lights in the room andThermo-Lag (757.0-Al 1 only) on conduits that pass through the room."This change will be included in the next FPR submittal. (Letter Item #31, NRC Question RAIFPR VII-12)24. The primary water storage tank (PWST) does not supply water for safe shutdown. The as-designed FPR, Part VIII, F.16, Plant Conformance will be revised to remove the reference tothe PWST, and this revision will be included in the next FPR submittal. (Letter Item #37,NRC Question RAI FPR VIII-13.1)25. NPG-SPP-1 8.4.7, "Control of Transient Combustibles," is the TVA procedure to addresscontrol of transient materials for the present operating Unit 1 and the under constructionUnit 2. In the procedure, limitations are provided on material type and amount. As anexample, a distinction is made between flammable and combustible liquids as to thequantity that can be stored outside an approved storage room due to a work activity. Toaddress this concern the FPR, Part VIII, F.1 .B, Plant Conformance column will be revised toread:Administrative procedures limit the amount and control the type of combustible materialswithin the area and control hot work activities.E2-4 ENCLOSURE2Response to NRC's Round 6 Request for Information Regarding "Fire Protection Report"Regulatory CommitmentsThis change will be incorporated into the next submittal of the FPR. (Letter Item # 40, NRCQuestion RAI FPR VIII-20)26. The following has been added at the end of the compliance matrix for NFPA 13 and will beincluded in the next FPR submittal.Section 1-11.5 DeviationThe 2 inch main drain test was not performed at Watts Bar because the design did notaccount for how to move the water from inside the safety related structures. The mainpurpose of the 2 inch main drain test is to ensure valves in the supply line are not closeddue to mis-positioning or valve failure. At Watts Bar the mis-positioning is addressed bythe rigid controls placed on configuration control and procedure use and adherence. Thedesign will not allow for a meaningful 2 inch main drain test; however, operationalcontrols are greater than normal industry installations and the installed equipment is lesssusceptible to blockage failure and WBN considers this acceptable.Section 3-12.1.5 DeviationFlange joints on risers are not provided on each floor. The piping design and installationare in accordance with TVA seismic criteria that exceed the intent of this section.Section 3-14.2.1 thru 3.4 DeviationHangers in concrete are in accordance with TVA structural criteria that exceed the intentof this section.(Letter Item # 42, NRC Question RAI FPR X-4)E2-5 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENTI ------------1. VA is in the process of finalizing the Fire Protection CLOSEDReport (FPR) to address both the fire protection The As-Drelated modifications and the other modifications. TheAsDThis review will be completed in December, 2010.WVA will submit the complete Unit 1/2 FPR byDecember 17, 2010.STATUS / COMMENTSesigned version of the FPR was submitted to the NRC via TVA tor dated December 18, 2010 (Reference 3 of this enclosure).2. 1. TVA will provide a separate markup, description,and justification of the changes made since NRCapproved the report. This information will beprovided by August 30, 2010.3. 1. Portions of the report address programmatic aspects(e.g., fire brigades, fire watches, etc.) that are notaffected by the operation of Unit 2. These parts willbe submitted to the NRC by August 6, 2010.4. 1. Table 1 provides a description of the dual unit MSOscenarios identified by the above describedanalysis. TVA will provide a description of how safeshutdown is ensured for each scenario byAugust 20, 2010.5. 1. The baseline list of OMAs is expected to requireonly very minor revisions due to the other non-fireprotection related modifications. TVA will providethe baseline list by August 6, 2010.CLOSEDWVA to NRC letter dated August 30, 2010 (Reference 13 of this enclosure)provided the committed information.Enclosure 1 of TVA to NRC letter dated August 9, 2010 (Reference 14 of thisenclosure) provided the committed information.CLOSEDTVA to NRC letter dated August 20, 2010 (Reference 2 of this enclosure)provided the committed information.CLOSEDEnclosure 2 of WVA to NRC letter dated August 9, 2010 (Reference 14 of thisenclosure) provided the committed information.6. 2. The resolutions contained in Appendix B of the MSO OPENEvaluation Report shall be implemented prior toUnit 2 fuel load.E3-1 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS7. 2. PWROG Scenario 13a: "Charging Pump Runout" OPENshall be confirmed to be within the bounds of CCPoperation during the large break LOCA analysisprior to Unit 2 fuel load......................................................................................................................................................................................8. 3. TVA will issue the as-constructed FPR for WBN OPENUnits 1 and 2 by October 1, 2011......................................................................................................................................................................................9. 3. If the FPR re-analysis determines that any other fire CLOSEDareas are affected, WA will submit the necessary VA to NRC letter dated March 16, 2011 (Reference 5 of this enclosure)revisions by February 28, 2011. submitted a revised FPR that resulted from the re-analysis.10. 3. WVA is in the process of fixing administrative errors CLOSEDin the FPR and will re-submit Parts V and VI by WVA to NRC letter dated January 14, 2011 (Reference 15 of this enclosure)January 14, 2011. submitted the corrected version of the FPR.11. 4. The As-designed FPR will be provided by March 16, CLOSED2011 except for Part V, which will be provided by WVA to NRC letter dated March 16, 2011 (Reference 5 of this enclosure)April 29, 2011. [RAI FPR General -2 Item A] submitted a revised FPR. The second paragraph of the cover letter states,"Enclosure 1 contains the entire As-Designed Unit 1/Unit 2 FPR except Part V,This tracks the portion due March 16, 2011. as explained belowE3-2 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT12. 4. The As-designed FPR will be provided by March 16,2011 except for Part V, which will be provided byApril 29, 2011. [RAI FPR General -2 Item A]This tracks the portion due April 29, 2011.STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure) stated,"In response to Item 1.2, NRC Question (RAI FPR General-2) [A], TVAsubmitted in Reference 1 the Unit 1/Unit 2 'As-designed' FPR, except forPart V. Enclosure 1 of this letter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety for the sake of completeness, except for Part VII,Section 8.0 which is currently under development. Part VII, Section 8.0, willbe transmitted to NRC within two weeks of receipt from the vendor."Reference 1 to this letter is Reference 4 for this enclosure.13. 4. The changes between Unit 1/Unit 2 As-designedFPR that was submitted in TVA's letter to NRC,dated January 14, 2011 and the Unit 1/Unit 2 As-designed FPR will be marked via Revision Bars inthe file. Justification will be provided for changesnot directly related to Unit 2 operation by March 25,2011. [RAI FPR General -2 Item B]CLOSEDTVA to NRC letter dated March 31, 2011 (Reference 16 of this enclosure)stated, "In response to NRC Question (RAI FPR General-2), TVA submitted inReference 1 the Unit 1/Unit 2 As-designed FPR that was marked with revisionbars depicting the differences between the Unit 1/Unit 2 As-designed FPR(submitted January 14, 2011) and the Unit 1/Unit 2 Final As-designed FPR.Enclosure 1 provides the justification for non-editorial changes which are notdirectly related to Unit 2 operation, including changes resulting from Unit 1FPR Revision 41 that was issued on February 22, 2011. TVA has comparedthe As-Designed FPR (submitted on March 16, 2011) to FPR Revision 41which is the current issued version. Differences not directly attributable to theaddition of Unit 2 are listed and justified in Enclosure 1. Some obviouseditorial and grammatical differences are not specifically listed."Reference 1 to this letter is Reference 4 for this enclosure.E3-3 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT14. 4. The digital copy of Revision 41 of the FPR will beincluded as part of the Unit 1/2 As-designed FPRsubmittal. [RAI FPR General -2 Item C]15. 4. TVA will provide a side-by-side comparison betweenthe WBN Unit 1/Unit 2 As-designed FPR that wassubmitted in TVA's letter to NRC, dated January 14,2011 and the WBN Unit 1/Unit 2 FPR As-designedversion following issuance of the next revision,scheduled for March 16, 2011. The WBN Unit 1,Revision 41 was issued on February 22, 2011.[RAI FPR General -3]STATUS / COMMENTSCLOSEDTVA to NRC letter dated March 16, 2011 (Reference 5 of this enclosure)submitted a revised FPR that resulted from the re-analysis.The letter included, "In addition, as committed to in Reference 2, TVA issubmitting documents in accordance with the following commitments:1. The digital copy of Revision 41 of the FPR will be included as part of theUnit 1/Unit 2 As-designed FPR submittal. The WBN Unit 1 FPR,Revision 41 was issued on February 22, 2011. [RAI FPR General-2Item C]""Enclosure 3 contains the digital copy of Revision 41 of the FPR."CLOSEDTVA to NRC letter dated March 16, 2011 (Reference 5 of this enclosure)submitted a revised FPR that resulted from the re-analysis.The letter included, "In addition, as committed to in Reference 2, TVA issubmitting documents in accordance with the following commitments:2. TVA will provide a side-by-side comparison between the WBNUnit 1/Unit 2 As-designed FPR that was submitted in TVA's letter to NRC,dated January 14, 2011 and the WBN Unit 1/Unit 2 FPR As-designedversion following issuance of the next revision of the Unit 1/Unit 2 FPR,scheduled for March 16, 2011. [RAI FPR General- 3]"Enclosure 4 contains a side-by-side comparison between the WBNUnit 1/Unit 2 As-designed FPR that was submitted in TVA's letter to NRC,dated January 14, 2011 and the current version of the WBN Unit 1/Unit 2 FPR"As-designed version ..."E3-4 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT16. 4. Attachment 2 contains Figures Il-1A thru 11-26A,which are the as-designed installed fire detectionand suppression system drawings. These drawingswill be annotated to reflect changes made to thefigures and provided to NRC by March 16, 2011.[RAI FPR General-4]STATUS / COMMENTSCLOSEDTVA to NRC letter dated March 16, 2011 (Reference 4 of this enclosure)responded to RAI FPR General-4 (item 2 of Enclosure 1) as follows:"The as-designed installed suppression systems for both Unit 1 and 2(includes all Unit 2 and common Unit 1/2) are depicted on Figures Il-1A thru II-26A (Attachment 2). The only changes to the Unit 2 suppression anddetection systems were in the Unit 2 Annulus where 30 new sprinkler headswere added. Additionally 18 new smoke detectors were added to various firezones in the Unit 2 Reactor Building. Figures representing the as-constructedplant configuration will be provided after construction completion."Per Figure 11-7A, there are 73 Unit 1 sprinkler heads and 100 Unit 2 sprinklerheads in the Reactor Building Annulus area. WBN Drawing 2-47W850-9, Rev.1, which is the equivalent Unit 2 "configuration control drawing" to Figure 11-7A,shows 70 heads for Unit 2, in this area. Therefore, Figure 11-7A (as-designed) already includes the 30 additional sprinkler heads that will be addedprior to Unit 2 operation in the Unit 2 Annulus Area, as identified in the aboveresponse (above).Since smoke detectors are a level of detail that is not included in these FPRFigures, the 18 additional detectors discussed in the above response wouldnot be reflected on these Figures.Since all of the As-Designed Fire Protection information is already included inthe Drawings that were in TVA to NRC letter dated March 16, 2011(Reference 4 of this enclosure), this item is closed.17. 4. Figures representing the as-constructed plantconfiguration will be provided after constructioncompletion. [RAI FPR General -4]OPENE3-5 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS...................................................................................................................................................................i .....-18. 4. Response to RAI FPR V-I will be provided by CLOSEDMarch 25, 2011. TVA to NRC letter dated March 31, 2011 (Reference 16 of this enclosure)responded to this item as follows:"The purpose of this letter is to provide documents that TVA committed inReference 1 to submit to NRC by March 25, 2011. Reference 1 providedTVA's response to NRC's request for information pertaining to Unit 2 FSARamendment, Section 9.5.1, 'Fire Protection System,' dated February 9, 2011(Reference 2) and NRC's questions received in February 11, 2011 andMarch 3, 2011 emails. The following provides the applicable portions ofNRC's requests that are addressed by the information that TVA committed toprovide by March 25, 2011: .."3. NRC Question (RAI FPR V.1):[A] Provide a description of the criteria and assumptions used toensure that Unit 2 manual actions (including manual actions foralternate or dedicated shutdown) are feasible and reliable. This shouldinclude the criteria and assumptions for feasible and reliable diagnosistime, implementation time, and time margin for the other operatormanual actions not explicitly described in Part V."In response to NRC Question (RAI FPR V-I), Enclosure 2 provides adescription of the criteria used to ensure that Unit 2 operator manual actions(including manual actions for alternate or dedicated shutdown) are feasibleand reliable. It should be noted that additional information related to theevaluation of Unit 2 manual actions against these criteria will be provided aspart of the response to NRC Question (RAI FPR V-2) that TVA committed tosubmit by April 29, 2011. These criteria will not be applied to Unit 1.19. 4. Response to RAI FPR V-2 will be provided by CLOSEDApril 29, 2011. [RAI FPR V-2] TVA to NRC letter dated July 1, 2011 (Reference 11 of this enclosure)provided the response to RAI FPR V-2.E3-6 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT20. 4. Upon performing the final plant walkdowns asprescribed in FPR Sections 2.1.1, 2.4.3, and 2.3,TVA will review the information and submit theresults for NRC approval if they differ from theassumptions and details provided in Part V or theother parts of the FPR. Otherwise, TVA will informthe NRC when the walkdowns are complete and thatno revisions to the FPR were required. [RAI FPRV-3]21. 4. The requirement for a portable lantern for theaffected AUO from this equipment cage will beevaluated during the Unit 2 walkdowns of operatormanual actions to ensure that existing lighting isadequate. [RAI FPR V-10]STATUS / COMMENTSOPENCLOSEDWVA to NRC letter dated May 18, 2011 (Reference 4 of this enclosure)provided the following response to RAI FPR V-1 0 (item 12 of Enclosure 4):"TVA's response to this comment has been revised as shown:'... The requirement for a portable lantern for the affected AUO from thisequipment cage will be evaluated during the Unit 2 walkdowns of operatormanual actions to ensure that the existing lighting is adequate and that thetimeline includes getting the lantern.'This change has been incorporated into the updated Unit 1/Unit 2As-Designed FPR provided in Enclosure 1 and captured as a commitment(Enclosure 5)."The new commitment is item 2 on Enclosure 5 and reads as:"The operator manual action timelines shall include the time required forgetting the lantern. (Enclosure 4, Question 12. NRC Question (RAI FPR V-10))"This new commitment is item 37 of this enclosure.E3-7 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT22. 4. The FPR will be revised to clarify that this reductiononly applies to areas and/or equipment affecting theunit in Modes 5, 6, and core empty and does notapply to areas where the other unit is in Modes 1 to4 inclusive. [RAI FPR 11-8]STATUS I COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 4 of this enclosure)provided the following Augmented TVA Response to RAI FPR 11-8:"This change has been incorporated into the updated Unitl/Unit 2As-Designed FPR provided in Enclosure 1."23.4. The barriers separating the Unit 2 Reactor Buildingfrom the Refueling Floor will be configured andcontrolled the same as the Unit 1 Reactor BuildingEquipment Hatch. [RAI FPR VII-l]OPEN24. 5. FPR Part V is undergoing revision in accordancewith the commitment made in Reference 2 toincorporate criteria and assumptions used to ensurethat Unit 2 manual actions (including manual actionsfor alternate or dedicated shutdown) are feasibleand reliable. FPR Part V will be submitted to NRCby April 29, 2011.CLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.E3-8 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT25. 6. TVA's response to Letter Item 3. [NRC Question RAIFPR 11-13] states:[1] Part II, Section 14.3.1.b.1 of the FPR shouldsay "For either Reactor Building...".[2] A review of the FPR revealed three other placeswhere the discussion concerns both units:1. Table 14.3, item 14.3.c should read "... Unit1 and 2 Containment Purge Air ExhaustFilters...".2. Part Ill, Section 4.7, third paragraph shouldread "The CCS system provides cooling forthe following safe shutdown equipment perunit." The CCS system equipment is forboth units.3. Part IV, Section 3.3, second sentenceshould read "The number in ( ) is thenumber available for shutdown." Thisdeletes the reference toUnit 1 only.These changes will be incorporated into the nextrevision to the Unit 1/Unit 2 As-Designed FPR.26. 6. For dual unit operation, CCS Pump 2B-B will bereturned to its Unit 2 functional role and will beincluded in the Technical Specification BasesSection 3.7.7. (Letter Item 4. [NRC Question RAIFPR 11-14])STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The changes delineated in the commitment were made by this version of theAs-Designed FPR.OPENE3-9 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT27. 6. Table 14.1 contains detectors that are for protectionof components and areas required for fire safeshutdown. The detection zone 413 contains thedetectors provided for the Motor Driven MainFeedwater Pump located in the Turbine Building.The Motor Driven Main Feedwater Pump is notrequired for fire safe shutdown; therefore, this lineitem for zone 413 is deleted from Table 14.1. Thesechanges will be incorporated into the next revision tothe Unit 1/Unit 2 As-Designed FPR.(Letter Item 6. [NRC Question RAI FPR 11-16])28. 6. Part II and Part VI were corrected to show thedamper (2-ISD-31-3872) is in the fire barrierseparating rooms 713.0-A29 (not 737-A9) and737.0-A8. These changes will be incorporated intothe next revision to the Unit 1/Unit 2 As-DesignedFPR. (Letter Item 8. [NRC Question RAI FPR 11-18])STATUS / COMMENTS...........................................................................................-CLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.CLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR. Note that room 713.0-A29 was correct in Part II as shown onpage 11-137 of the FPR, and did not require revision.E3-10 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT29. 6. A review of the HVAC configuration control drawings(47A381 series, 47W866 series, and 47W920series) has been performed to determine the correctidentification number and fire resistance rating of thedamper. The correct damper number is 1-ISD-31-2516 and correct fire rating of the damper is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.A review of the damper information contained inTable 14.8.2 against the Damper tables provided inPart VI has also been completed. The information inthe tables (Table 14.8.2 and Part VI Damper tables)has been verified and the discrepancies corrected.These changes will be incorporated into the nextrevision to the Unit 1/Unit 2 As-Designed FPR.(Letter Item 9. [NRC Question RAI FPR 11-19])30. 6. The referenced conflicts and inconsistenciesbetween Part II, Section 14.2 "Water Supply" andthe "Fire Pump Inoperability and CompensatoryActions" Table have been reviewed, andSection 14.2 and the Table have been revised toreflect consistency between the two parts. Therevised table is included as Attachment 2 to thisletter and will be incorporated into the FPR as partof the As-Constructed update of the FPR prior toUnit 2 initial fuel load. (Letter Item 24. [NRCQuestion (RAI FPR 11-34)])STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.OPENE3-11 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT31. 6. It is TVA's position that only qualified personnel areallowed and required to make the decisions as towhich of the three conditions apply to eachindividual circumstance. Only Sections 14.8.1.a and14.8.1.b apply to ERFBS and radiant energy shields.Section 14.8.1.c does not apply to ERFBSconfigurations. Section 14.8.1.c will be clarified todenote that it does not apply to ERFBS and radiantenergy shields. (Letter Item 27.[NRC Question RAI FPR 11-36])32. 6. Part III, Sections 2.3 and 3.4.3 provide qualitativestatements regarding the need to control RCSpressure to maintain sub-cooling margin such thatnatural circulation would not be adversely affectedby large bubble formation in the reactor vessel.Both statements convey the desired information, butfor consistency Section 3.4.3 will be revised to say"minimize void formation" rather than "prevent voidformation" and thereby be consistent withSection 2.3. These changes will be incorporatedinto the next revision to the Unit 1/Unit 2 As-Designed FPR. (Letter Item 33. [NRC QuestionRAI FPR 111-7])STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning .the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.CLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.E3-12 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT33. 6. TVA's response to Letter Item 39 [NRC QuestionRAI FPR 111-13] states:[1] Part Ill, Section 4.7 is incorrect and the thirdparagraph should read "The CCS systemprovides cooling for the following safe shutdownequipment per unit." The CCS systemequipment is for both units.[2] A review of the FPR revealed three other placeswhere the discussion concerns both units:1. Table 14.3, item 14.3.c should read: "... Unit1 and 2 Containment Purge Air ExhaustFilters,...".2. Part IV, Section 3.3, second sentenceshould read: "The number in ( ) is thenumber available for shutdown." Thisdeletes the reference to Unit 1 only.3. Part II, Section 14.3.1.b.1 of the FPR shouldsay "For either Reactor Building...".These changes will be incorporated into the nextrevision to the Unit 1/Unit 2 As-Designed FPR.STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAls concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The changes delineated in the commitment were made by this version of theAs-Designed FPR.E3-13 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT34. 6. TVA's response to Letter Item 42 [NRC QuestionRAI FPR V-3] states:[1] Part IV, Section 3.3 is incorrect. The secondsentence should read "The number in ( ) is thenumber available for shutdown." This deletesthe reference to Unit 1 only.[2] A review of the FPR revealed three other placeswhere the discussion concerns both units:1. Table 14.3, item 14.3.c should read: "... Unit1 and 2 Containment Purge Air ExhaustFilters,...".2. Part II, Section 14.3.1.b.1 of the FPR shouldsay "For either Reactor Building...".3. Part Ill, Section 4.7 is incorrect. The thirdparagraph should read: "The CCS systemprovides cooling for the following safeshutdown equipment per unit." The CCSsystem equipment is for both units.These changes will be incorporated into the nextrevision to the Unit 1/Unit 2 As-Designed FPR.STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The changes delineated in the commitment were made by this version of theAs-Designed FPR.E3-14 Summary Listing of Fire Protection CommitmentsItemNo.REF.COMMITMENT35. 6. As described in Enclosure 2 to TVA letter to NRCdated March 31, 2011, most of WBN Unit 2 operatormanual actions are preventative rather thanreactive. That is, they are driven by procedurerather than reacting to changing plant conditions asindicated by instrumentation and alarms. Whilethere are some actions that are taken in response tothe fire itself (de-energize electrical board that is onfire), most WBN Unit 2 actions are in response totripping the reactor. This clarification of T=0 is beingincluded in the ongoing revision of Part V Section 2which will be included in the next FPR revision.(Letter Item 43 [NRC Question RAI FPR V-11])36. 7. In response to Item 1.2, NRC Question (RAI FPRGeneral-2) [A], TVA submitted in Reference 1, theUnit 1/Unit 2 As-designed FPR, except for Part V,which TVA committed to submit by April 29, 2011.Enclosure 1 provides the Unit 1/Unit 2 As-designed FPR in its entirety for the sake ofcompleteness, except for Part VII, Section 8.0which is currently under development. Part VII,Section 8.0 will be transmitted to NRC within twoweeks of receipt from the vendor....................................................................................37. 7. The operator manual action timelines shall includethe time required for getting the lantern.(Enclosure 4, Question 12. NRC Question (RAIFPR V-1 0))38. 8.. TVA will submit the responses to NRC QuestionsRAI FPR 11-41; RAI FPR VI11-17; and RAI FPRMSO-3 by June 7, 2011. [Cover letter]STATUS / COMMENTSCLOSEDTVA to NRC letter dated May 18, 2011 (Reference 7 of this enclosure)provided responses to RAIs concerning the FPR. The second sentence of thethird paragraph of the second page of the letter stated, "Enclosure 1 of thisletter provides the updated Unit 1/Unit 2 'As-designed' FPR in its entirety forthe sake of completeness, except for Part VII, Section 8.0 which is currentlyunder development."The change delineated in the commitment was made by this version of the As-Designed FPR.CLOSEDTVA to NRC letter dated July 1, 2011 (Reference 11 of this enclosure)provided Part VII, Section 8.0.OPENCLOSEDWVA to NRC letter dated June 7, 2011 (Reference 9 of this enclosure)provided the responses to RAls FPR 11-41, FPR VII1-17, and FPR MSO--3.E3-15 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS39. 8. Additionally, it has been determined that the RES OPENM-20A & M-20C materials are no longer availableand Unit 2 will be replaced with a compatiblematerial, such as 3M E54, that will provide equalor greater protection than the M-20A & M-20C.[Enclosure 1, Letter Item 2. NRC Question (RAIFPR 11-42)].................................................................................................................................................40. 8. This oversight has been corrected and will be OPENincluded in the next submittal of the As-designedFPR. A review of Section VII of the FPR hasbeen completed and the other evaluations anddeviations correctly take into consideration dualunit operation. [Enclosure 1, Letter Item 7.NRC Question (RAI FPR VII-4)]41. 8. The Auxiliary Building (Rooms 729.0-A3 and A4) OPENhave fire dampers with fusible links in theventilation system duct work at each point theventilation system enters rooms 729.0-A3 and A4to isolate these rooms. The drains for theserooms go to either the Tritiated Drain CollectorTank or the Floor Drain Collector Tank both ofwhich are in the Auxiliary Building. Thisinformation will be added to the next revision tothe FPR. [Enclosure 1, Letter Item 26. NRCQuestion (RAI FPR VII1-19)]42. 8. WBN design criteria WB-DC-30-13, "10CFR50, OPENAppendix R, Type 1, 11, and III Circuits -Unit 1/Unit 2" will be revised to define the evaluationmethodology and specify the applicable circuitfailure criteria in accordance with NEI-00-01Revision 2 and RG 1.189, Revision 2.[Enclosure 1, Letter Item 29. NRC Question(RAI FPR MSO-1)]E3-16 Summary Listing of Fire Protection CommitmentsItemNo. REF.-----------------------COMMITMENTSTATUS / COMMENTS-------------------------------------43. 8. The term "backup control stations" should have OPENbeen "auxiliary control system" and the WBNUnit 2 MSO Report Revision 1 will be revised tostate "auxiliary control system." [Enclosure 1,Letter Item 33. NRC Question (RAI FPR MSO-6)]44. 9. As resolution of this RAI, TVA commits to OPENcompleting prior to Unit 2 fuel load themodifications and document revisions required toresolve the common MSOs identified inAppendix C submitted in TVA letter to NRCdated August 20, 2010 (Reference 3).45. 10.46. 10.......................47. 10.Room 713.0-A1C "Corridor, Column Lines OPENU-W/A7-A9" is not a part of Fire Area 1 (analysisvolume AV-006). It is in Fire Area 8 (analysisvolumes AV-025C and AV-026A). This correctionto the FPR has been done and will be reflected inthe final As-designed FPR submittal.(Letter Item # 2, Request 1 [NRC RAI FPR VI-5])...............................................................................................................................................................The pump deck was not included in the analysis OPEN(AV-088, AV-089, AV-090) because it has noimpact on the analysis. WBN has revised theFPR, Part VI, Section 3.66.2 to document that theRCW Pump Deck is not included in the abovelisted analysis volumes and will be reflected in thefinal As-designed FPR submittal. (Letter Item #2, Request 2 [NRC RAI FPR VI-5])The FPR has been revised to show that room729.0-Al0 in Fire Area 73 is analysis volume AV-112A and this will be reflected in the final As-designed FPR submittal. (Letter Item # 2,Request 3 [NRC RAI FPR VI-5])OPENE3-17 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS48. 10. The FPR revisions listed in Letter Item # 3 (NRC OPENRAI FPR VI-6) will be included in the nextsubmittal of the Unit 1/Unit 2 As-Designed FPR......................................................................................................................................................................................49. 10. As discussed in Letter Item # 6 (NRC RAI FPR OPENVII-9), the final As-designed submittal of the FPRwill show a more appropriate reference toFPR Part III, Section 7.2......................................................................................................................................................................................50. 10. Door D7A is not part of a required regulatory fire OPENbarrier (see figure 11-35); therefore, it is not listedin Part II, Table 14.8.1, or in Part VI. There is noconflict. Door D7A was included in Part VII,Section 5.2 for completeness. Since this door isnot a regulatory required fire door, it will beremoved from Part VII, Section 5.2, and thisrevision will be included in the next submittal ofthe Unit 1/Unit 2 As-Designed FPR. (Letter Item# 8, [NRC RAI FPR VII-1 1]).....................................................................................................................................................................................51. 10. WBN has corrected this error. NFPA 15-1973 is OPENthe correct code of record for WBN. Thesentence in Section 3.3.1.2, "In accordance withNFPA 13, Section 4-4.1.2, a design density wasdetermined for this unique application based onanalysis of the combustibles," has been deleted.In addition, the 3rd paragraph in Section 3.3.1.2has been revised to reference the correct tablenumber. NFPA 13, Table 2-2.3.1, is changed toTable 3-15.6.1. These FPR revisions will beincluded in the next submittal of the Unit 1/Unit 2As-Designed FPR. (Letter Item # 11,[NRC RAI FPR X-3])E3-18 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS.................................................................................-- .................................................................................................52. 10. TVA will complete the resolution actions for the OPENMSO scenarios affecting Unit 2 prior to the Unit 2fuel load. (Letter Item # 15, [NRC RAI FPRMSO-10])53. 10. The statement in FPR Part IV, Section 1.0, "fires OPENin the building that could result in abandonment ofthe main control room (MCR)," is correct. Thereare fires in the control building that will not resultin MCR abandonment. The WBN Unit 2 MSOReport, Revision 1, will be revised to eliminatethis apparent contradiction. (Letter Item # 16,[NRC RAI FPR MSO-11])54. 11. Validation of the Unit 2 OMA performance times OPENwill be demonstrated prior to Unit 2 fuel load.55. 11. Emergency lighting and communications for the OPENUnit 2 OMAs will be demonstrated during theUnit 2 OMA validation walkdowns......................................................................................................................................................................................56. 11. The post fire safe shutdown procedures OPEN(AOI 30.2) will be revised for dual unit operationprior to Unit 2 fuel load......................................................................................................................................................................................57. 11. The feasibility and reliability evaluation will be OPENreviewed and modifications, as needed,incorporated when the combustible loadings arefinalized. These actions will be completed prior toUnit 2 fuel load.E3-19 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS58. 12. Piping and hose stations will be added in the OPENfollowing areas for Unit 2 operation: [Letter # 2.NRC Question (RAI FPR VII-2.2)]A. Two sprinkler systems in the Unit 2 ReactorBuilding. These are pre-action sprinklersystems, normally dry with an air supervision ofthe piping.B. Two sets of hose stations in the Unit 2 ReactorBuilding. These hose stations are fed from asprinkler system type deluge valve thus they willnormally be dry also but will not have airsupervision.C. Sprinkler system for the protection of thecharcoal beds in the Unit 2 Containment PurgeAir filter housing. This will be a pre-actionsprinkler system but will not have airsupervision.59. 12. Existing Unit 1 hose stations that presently are not OPENrequired by the FPR to provide protection tooperating equipment will be re-classified to providingprotection for operating equipment when Unit 2 goeson line. [Letter # 2. NRC Question (RAIFPR VII-2.2)].................................................................................................................................................60. 12. A description of the Chemical Treatment Program OPENwill be provided in a future FSAR amendment.[Letter # 4. NRC Question (RAI FPR VII-2.4)]E3-20 Summary Listing of Fire Protection CommitmentsItemNo. REF. COMMITMENT STATUS / COMMENTS61. 12. A note will be added to the end of Part VII, Section OPEN3.3 to address the fact the initial three year periodfor annual performance is complete. This changewill be included in the next FPR submittal.[Letter # 5. NRC Question (RAI FPR VII-2.5)]E3-21 Summary Listing of Fire Protection CommitmentsREFERENCE FOR COMMITMENT SOURCE'- -. .................................................................................................................................................................................1. TVA to NRC letter dated July 16, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information Regarding Fire ProtectionProgram"2. TVA to NRC letter dated August 20, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Commitmentto Provide Additional Information on Multiple Spurious Operation (MSO) Scenarios"3. TVA to NRC letter dated December 18, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Submittalof Revised Fire Protection Report"....................................................................................................................................................................................4. TVA to NRC letter dated March 16, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information Regarding Final SafetyAnalysis Report (FSAR) Amendment Related to Section 9.5.1 "Fire Protection System" (TAC No. ME3091)"....................................................................................................................................................................................5. TVA to NRC letter dated March 16, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Commitment toUpdate Fire Protection Report Due to Re-Analysis and Re-Submit"6. TVA to NRC letter dated May 6, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information Regarding 'Fire ProtectionReport' (TAC No. ME3091)"....................................................................................................................................................................................7. TVA to NRC letter dated May 18, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Submittal ofInformation to Address Commitment in Support of Response to Fire Protection Report Request for Additional Information (RAI) and Revision toWVA March 16, 2011 RAI Response"8. TVA to NRC letter dated May 26, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information (RAI) Regarding 'FireProtection Report' (TAC No. ME3091)"E3-22 Summary Listing of Fire Protection CommitmentsREFERENCE FOR COMMITMENT SOURCE9. TVA to NRC letter dated June 7, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -NRC Round 4B Request for Additional Information (RAI)Regarding 'Fire Protection Report' (TAC No. ME3091)"10. TVA to NRC letter dated June 17, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information Round 5 Regarding 'FireProtection Report' (TAC No.ME3091)"11. TVA to NRC letter dated July 1, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information (RAI) Regarding Final SafetyAnalysis Report (FSAR) Amendment Related to Section 9.5.1, 'Fire Protection System' (TAC No. ME3091)"12. TVA to NRC letter dated July 22, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Corrosion Related Portion of NRC's Request for AdditionalInformation (RAI) Round 6 Regarding 'Fire Protection Report' (TAC No. ME3091)"13. TVA to NRC letter dated August 30, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Commitmentto Provide Summary of Changes to Fire Protection Report (FPR)(TAC No. ME0853)"14. TVA to NRC letter dated August 9, 2010, "Watts Bar Nuclear Plant (WBN) Unit 2 -Request for Additional Information Regarding Fire ProtectionProgram (TAC No. ME0853)"15. TVA to NRC letter dated January 14, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Commitmentto Correct Administrative Deficiencies Contained in Parts V and VI of Fire Protection Report and Re-Submit"16. TVA to NRC letter dated March 31, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 -Fire Protection Program (TAC No. ME0853) -Submittal ofInformation to Address Commitment in Support of Response to Fire Protection Report Request for Additional Information (RAI)"E3-23