ML15096A054

NFPA-805 Draft follow-up RAI to 90-day RAI Responses

ML15096A054
Person / Time
Site:	Robinson
Issue date:	03/31/2015
From:	Barillas M C Plant Licensing Branch II
To:	Hightower R E Duke Energy Corp
References
Download: ML15096A054 (3)

Text

1 NRR-PMDAPEm Resource From: Barillas, Martha Sent: Tuesday, March 31, 2015 1:28 PM To: Richard.Hightower@duke-energy.com; Conne lly, Scott (Scott.Conne lly@duke-energy.com)

Cc: Helton, Shana; Miller, Barry

Subject:

Robinson NFPA-805 DRAFT follow-up RAI to 90-day RAI responses Attachments:

Robinson Draft Follow-up 90 day_FM and RR RAI.docx Richard/Scott, By letter dated September 16, 2013, Duke Energy Progress Inc., the licensee of H. B. Robinson Steam Electric Plant, Unit 2 (HBRSEP), submitted a license amendment request to change its fire protection program to one based on the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10

of the Code of Federal Regulations (10 CFR), Part 50, Section 50.48(c) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13267A211). By letter December 22, 2014 (ADAMS Accession No. ML15005A073), you provided 90-day responses to staff request for additional information (RAI).

To complete its review, the NRC staff has the following follow-up draft request for additional information (RAI) attached.

Please see the attached RAI in DRAFT form.

A Sensitive Unclassified Non-Safeguards Information (SUNSI) review was completed by the staff on the draft RAI and the staff concluded the RAI do not contain SUNSI.

If you find any information needs to be withheld from the public, please notify me within 5 days of receipt of this

email.

Please submit your response to these RAI within 30 days of this email. If you need a clarification call for the attached draft 90-day follow-up RAI, or you need to change the RAI response due date, please contact me at

(301)-415-2760.

Respectfully, Martha Barillas Project Manager

Shearon Harris & H. B. Robinson NRR/DORL/Licensing Branch II-2 US Nuclear Regulatory Commission

301-415-2760

Hearing Identifier: NRR_PMDA Email Number: 1972 Mail Envelope Properties (Martha.Barillas@nrc.gov20150331132700)

Subject:

Robinson NFPA-805 DRAFT follow-up RAI to 90-day RAI responses Sent Date: 3/31/2015 1:27:41 PM Received Date: 3/31/2015 1:27:00 PM From: Barillas, Martha Created By: Martha.Barillas@nrc.gov Recipients: "Helton, Shana" <Shana.Helton@nrc.gov> Tracking Status: None "Miller, Barry" <Barry.Miller@nrc.gov>

Tracking Status: None "Richard.Hightower@duke-energy.com" <Richard.Hightower@duke-energy.com> Tracking Status: None "Connelly, Scott (Scott.Conne lly@duke-energy.com)" <Scott.Connelly@duke-energy.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 1675 3/31/2015 1:27:00 PM Robinson Draft Follow-up 90 day_FM and RR RAI.docx 28540 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

DRAFT Robinson NFPA-805 Follow-up RAIs to 90-Day RAI Response Fire Modeling (FM) RAI 01.o.01 In a letter dated December 22, 2014 (ADAMS Accession No. ML15005A073), the licensee responded to FM 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, "EPRl/NRC-RES Fire PRA Met hodology for Nuclear Power Facilities," Appendix S, Section S.1, it is recommended that in order to assume there is no fire propagation between cabinets, an air-gap must be present. However, the licensee did not state such an assumption (e.g., that an air-gap was present between the walls of the electrical 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 or provide the technical justification for not assuming fire propagation between cabinets.

Radiation Release 02.01 In a letter dated December 22, 2014 (ADAMS Accession No. ML15005A073), the licensee responded to RR 02described its evaluationof the potential for radioactive release and radiation exposure to members of the public using a quantitative analysis (i.e., dose calculation) for radiological storage and sea-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 site exclusion boundary, release fraction, burn time, and plume exposure period.

From the NRC staff's review of the licensee's analysis, it was determined that although gaseous radioactive 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 to members of the public are as low as reasonably achievable (ALARA) and do not exceed the applicable 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 amount of activity which may be present in radiological storage and sea-land type containers in the RCA Yard. c) Describe the engineering controls such as catch basins to collect leakage for sampling, storm drain covers, diversion equipment, or other means to prevent water runoff used to contain potentially contaminated fire suppression water runoff for radiological storage and sea-land containers in the RCA Yard.