ML15149A265
| ML15149A265 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/19/2015 |
| From: | Glover R M Duke Energy Corp, Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/15-0047 | |
| Download: ML15149A265 (6) | |
Text
R. Michael GloverDUKE H. B. Robinson SteamElectric Plant Unit 2)ENERGY, Site Vice President Duke Energy Progress3581 West Entrance RoadHartsville, SC 295500:843 857 1704F: 843 857 1319Mike. Glover@duke-energy.com Serial: RNP-RA/1 5-0047MAY 1 9 2015U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23RESPONSE TO FOLLOW-UP REQUEST FOR ADDITIONAL INFORMATION (RAI)ASSOCIATIED WITH RESPONSE TO 90-DAY RAI RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) STANDARD 805
Dear Sir/Madam:
By letter dated September 16, 2013 (Reference
- 1) Duke Energy Progress, Inc. submitted a licenseamendment request to adopt a new risk-informed performance-based fire protection licensing basisfor the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2).
During the week of September 22, 2014, the NRC conducted an audit at HBRSEP2 to support development of questions regarding the license amendment request.
On October 23, 2014 the NRC provided a set ofrequests for additional information (RAI) regarding the license amendment request (Reference 2).That letter divided the RAIs into 60-day, 90-day, and 120-day required responses.
The DukeEnergy Progress 60-Day, 90-Day, and 120-Day responses were conveyed to the NRC DocumentControl Desk via letters from R. Michael Glover on November 24, 2014 (Reference 3), December22, 2014 (Reference 4), and January 22, 2015 (Reference 5), respectively.
On April 23, 2015 afollow-up RAI regarding the Reference 4 submittal was conveyed to Duke Energy Progress, Inc. viaelectronic mail message (Reference 8). Enclosed is the Duke Energy Progress response to thatrequest.Please address any comments or questions regarding this matter to Mr. Richard Hightower, Manager -Nuclear Regulatory Affairs at (843) 857-1329.
There are no new regulatory commitments made in this letter.I declare under penalty of perjury that the foregoing is true and correct.
Executed on,, A,, ? ,2015.Sincerely, R; Michael GloverSite Vice President U. S. Nuclear Regulatory Commission Serial: RNP-RA/15-0047 Page 2RMG/jmwEnclosure cc: Mr. V. M. McCree, NRC, Region IIMs. Martha C. Barillas, NRC Project Manager, NRRNRC Resident Inspector, HBRSEP2Ms. S. E. Jenkins,
- Manager, Infectious and Radioactive Waste Management Section (SC)
REFERENCES:
- 1. Letter from W. R. Gideon (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USNRC) (Serial:
RNP-RA/1 3-0090),
License Amendment Request (LAR) to Adopt NFPA805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition),
dated September 16, 2013, ADAMS Accession No. ML1 3267A21 12. Letter from Martha Barillas (USNRC) to Site Vice President, H. B. Robinson Steam ElectricPlant (Duke Energy Progress),
H. B. Robinson Steam Electric Plant, Unit 2 -Request forAdditional Information on License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection (TAC No.MF2746),
dated October 23, 2014, ADAMS Accession No. ML14289A260
- 3. Letter from R. Michael Glover (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USNRC) (Serial:
RNP-RA/1 4-0122),
Response (60-Day) to Request forAdditional Information Associated with License Amendment Request to Adopt National FireProtection Association (NFPA) Standard 805, dated November 24, 20144. Letter from R. Michael Glover (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USNRC) (Serial:
RNP-RA/1 4-0134),
Response (90-Day) to Request forAdditional Information Associated with License Amendment Request to Adopt National FireProtection Association (NFPA) Standard 805, dated December 22, 20145. Letter from R. Michael Glover (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USNRC) (Serial:
RNP-RA/1 5-0006),
Response (120-Day) to Request forAdditional Information Associated with License Amendment Request to Adopt National FireProtection Association (NFPA) Standard 805, dated January 22, 20156. Letter from Martha Barillas (USNRC) to Site Vice President, H. B. Robinson Steam ElectricPlant (Duke Energy Progress),
H. B. Robinson Steam Electric Plant, Unit 2 -Request forAdditional Information on 60-Day Response to License Amendment Request to AdoptNational Fire Protection Association Standard 805, Performance-Based Standard for FireProtection (TAC No. MF2746),
dated March 26, 2015, ADAMS Accession No.ML15057A403
- 7. Letter from R. Michael Glover (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USNRC) (Serial:
RNP-RAI1 5-0021),
Supplemental Response (120-Day) toRequest for Additional Information Associated with License Amendment Request to AdoptNational Fire Protection Association (NFPA) Standard 805, dated April 1, 20158. Electronic Mail message from Martha Barillas (USNRC) to H. B. Robinson Steam ElectricPlant, Unit 2 Regulatory Affairs staff members Richard Hightower/Scott Connelly (DukeEnergy Progress)
-Robinson NFPA 805 Follow-up 90-Day FM and RR RAI, dated April 23,2015.
U. S. Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/15-0047 4 Pages (including this cover page)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING VOLUNTARY FIREPROTECTION RISK INITIATIVE REQUEST FOR ADDITIONAL INFORMATION VOLUNTARY FIRE PROTECTION RISK INITIATIVE DUKE ENERGY PROGRESSH. B ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2DOCKET NO. 50-261Fire Modeling (FM) Request for Additional Information (RAI) 01.o.01In a letter dated December 22, 2014 (ADAMS Accession No. ML15005A073),
the licensee responded toFM RAI 01.o and explained that the individual panels considered in the main control room (MCR)abandonment analysis were effectively separated by double wall construction and therefore, propagation to adjacent cabinets was not assumed.
In NUREG/CR-6850, "EPRI/NRC-RES Fire PRAMethodology for Nuclear Power Facilities,"
Appendix S, Section S.1, it is recommended that in order toassume there is no fire propagation between cabinets, an air-gap must be present.
- However, thelicensee did not state such an assumption (e.g., that an air-gap was present between the walls of theelectrical cabinets,)
only that the panels were of double wall construction.
State whether the individual panels considered in the MCR abandonment analysis are separated by a double wall with an air-gap orprovide the technical justification for not assuming fire propagation between cabinets.
Response
o) The statement in Section 5.1.3.1 refers to the MCBs and the cabinets located at the ends of thehorseshoe that have the same configuration as the MCBs (In-Core Instrument Racks, Radiation Control Panels, and Nuclear Instrument Racks). Fire scenarios involving these panels arecharacterized using fires that propagate to adjacent panels and those that do not (i.e., third andfourth bullets in Section 5.3.1). These are baseline fire scenarios as seen in Section 5.4. Theother panels within the MCR are individual panels that are effectively separated by a doublewall with an air gap construction.
In these cases, non-propagating fire scenarios are applicable (i.e., first and second bullets in Section 5.3.1).Page 2 of 4 Radiation Release RAI 02.01In a letter dated December 22, 2014 (ADAMS Accession No. ML15005A073),
the licensee responded toRR 02 described its evaluation of the potential for radioactive release and radiation exposure tomembers of the public using a quantitative analysis (i.e., dose calculation) for radiological storage andsea-land containers in the RCA Yard. The dose calculation considered dry active waste (DAW)radionuclide distribution and activities, atmospheric dispersion, distance from the RCA Yard to the siteexclusion
- boundary, release fraction, burn time, and plume exposure period.From the NRC staffs review of the licensee's
- analysis, it was determined that although gaseousradioactive releases and radiation exposures were evaluated, liquid radioactive releases and radiation exposures due to the direct effects of fire suppression activities were not evaluated.
a) Provide an analysis that demonstrates liquid radioactive releases and radiation exposures tomembers of the public are as low as reasonably achievable (ALARA) and do not exceed theapplicable 10 CFR Part 20 dose limits. The analysis should describe:
- i. The liquid radionuclide distribution and activities (and their basis).ii. The method, any inputs (and their basis), and assumptions used in the analysis.
b) Describe the administrative controls such as procedures and training that will limit the amountof activity which may be present in radiological storage and sea-land type containers in the RCAYard.c) Describe the engineering controls such as catch basins to collect leakage for sampling, stormdrain covers, diversion equipment, or other means to prevent water runoff used to containpotentially contaminated fire suppression water runoff for radiological storage and sea-landcontainers in the RCA Yard.Response:
a)i An analysis was performed to demonstrate liquid radioactive releases and radiation exposures to members of the public are as low as reasonably achievable (ALARA) and do not exceed theapplicable 10 CFR Part 20 dose limits. The analysis calculated the estimated TEDE from a"standard" DAW shipment, then took the TEDE, and found a ratio to the 100 mRem memberof the public dose limit from 10 CFR 20. This ratio was in turn used to scale the "standard" DAW to a "max" DAW activity allowable to ensure compliance with 10 CFR 20. While thisvalue may change based on the container's radionuclide
- content, it serves as an average forthe purpose of the calculation.
Page 3 of 4 ii. Assumptions Fight fire 60 minHose Flow 125 gpmNUREG/CR 2658 is 30% 40%Rad Mat in water 0.4 for conservatism Lake Robinson Damflow (dilution) 1.01E+05 gpmf 0.001236conv 3780 ml/galconv 4.49E+02 gpm/cfsLake Rob Flow 225 CfsNuclides considered are the same as those considered for gaseous effluents.
ResultsTEDE 1.91E-01 mremAllowed 1.36E+03 Cib) LAR Table S-3, will be updated to include an Implementation Item to revise site programs andprocedures to ensure actions are in place for limiting the amount of radionuclide activityconsistent with the assumptions and inputs provided in calculation RNP-M/MECH-1901, Evaluation of Dose Consequence from Fire in a Radwaste Container Stored in an Outside Areafor airborne effluents.
c) The volume of fire suppression flow from a typical attack line is well within the site capability tocontain and monitor firefighting related run-off prior to release to areas outside the OwnerControlled Area. A conservative one hour of suppression flow from a single 1Y2" attack line, at arate of 125 gallons per minute, equates to 0.25 cubic feet per second of runoff (assuming no lossof water volume).
The capacity of RNP's storm drain system is not credited for flooding on site.It was designed to accommodate the 5 inch per hour, 50 year storm. The piping at thebeginning of the storm run is 10 inch reinforced concrete pipe (RCP) and progressively grows toa 30 inch RCP. It would take significantly more fire suppression flow to over tax this sized stormpipe.In the event of a fire during a significant storm event, RNP has developed a new calculation RNP-M/MECH-1901, Evaluation of Dose Consequence from Fire in a Radwaste Container Storedin an Outside Area. This calculation establishes the maximum level of curies that can be storedin a single fuel package (i.e., area, container or building) which, if completely consumed by fire,would not result in a radioactive release as a gaseous effluent that would exceed 10 CFR 20limits. If the same release conditions were assumed, but with all activity released as a liquideffluent the bounding conditions, in concert with site actions to contain and monitor prior torelease, it would ensure the same result of not exceeding 10 CFR 20 limits.Page 4 of 4