ML11355A074
| ML11355A074 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 12/19/2011 |
| From: | Feintuch K Plant Licensing Branch III |
| To: | Sly C Dominion Energy Kewaunee |
| References | |
| TAC ME7250 | |
| Download: ML11355A074 (4) | |
Text
1 NRR-PMDAPEm Resource From:
Feintuch, Karl Sent:
Monday, December 19, 2011 3:58 PM To:
Craig D Sly
Subject:
ME7250 - Kewaunee - NFPA-805 - LIC-109 Acceptance Review Results By letter dated September 21, 2011 (ADAMS Accession No. ML11277A240), Dominion Energy Kewaunee, Inc. (DEK, the licensee) submitted a license amendment request for the Kewaunee Power Station (KPS). The proposed amendment would adopt NFPA 805 performance-based standard for fire protection for light water reactor electric generating plants (2001 Edition) for the transition of the licensing basis to 10 CFR 50.48(c).
The purpose of this message is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review is being performed to determine if the analyses/evaluations are complete and there is sufficient technical information in scope and depth to allow the NRC staff to start its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff is in the process of reviewing the completeness of your application and concludes that the information delineated in the Request for Supplementation that follows this message is necessary to enable the staff to start to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
The NRC staff has identified seven issues needing supplementation such that the application is currently Unacceptable with Opportunity to Supplement, as defined in Section 3.2.2 of Instruction LIC-109 (ADAMS Accession No. ML091810088). In order to make the application complete, the NRC staff requests that DEK supplement the application to address the information requested in the enclosure within 13 working days of the receipt of this message or of a clarifying phone call, if you so request, within 5 working days after this message.
The items are identified as Draft at this time. However, they become firm for purposes of responding (1) if you express no need for a clarifying phone call; (2) within 5 working days of this message if no call is needed; or (3) at the completion of the clarifying phone call, whichever occurs.
Failure to provide the requested supplemental information within the timeframe as stated above will result in: 1) non-acceptance of the application, 2) cessation of the NRCs review activities pursuant to 10 CFR 2.101, and 3) a loss of enforcement discretion.
If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with Mr. Craig Sly of DEK staff on December 19, 2011, relative to concerns expressed by the Fire Protection Technical Branch (AFPB) and the Probabilistic Risk Assessment Branch (APLA).
The seven items of concern follow:
2 TAC No. ME7250 -
Adoption by Kewaunee Power Station of NFPA-805 Risk Informed Fire Protection Standard -
Draft Items for Request for Supplementation The staff has seven items that need to be addressed relating to the acceptance determination of the Kewaunee NFPA 805 LAR:
- 1. Handling of modifications in the LAR needs to be addressed.
- a. Insufficient justification for the extended modification completion time
- b. Lack of a clear commitment (which will be changed to a license condition) to perform the specific modifications proposed
- c. Proposal that the scope of the proposed modifications may be changed through self approval without prior staff approval To address this issue, the licensee should
- Explain why some of the modifications will require such an extended installation schedule
- Describe the modifications that are required to achieve compliance,
- Make a deliberate commitment that these modifications will be performed
- Remove any references to the ability to change the scope of these modifications through any self-approved process.
- 2. A substantial number of NFPA 805 Chapter 3 elements require the completion of code compliance reviews
- a. 10 CFR 50.48(c)(3)(ii) requires:
The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensee's decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805.
- b. Regulations require the evaluations and analyses to be complete at time of submittal. Describe how the LAR meets the requirement.
- c. The B-1 Table should reflect the state of compliance at the end of implementation. Provide information in Table B-1 to show that information.
- 3. The discussion of the proposed Monitoring Program does not include the use of the Maintenance Rule for those components already included in that program. Verify if the Maintenance Rule program will be used.
If the Maintenance Rule program will not be used then provide additional detailed descriptions of the Monitoring Program, including any approaches in FAQ 10-0059..
- 4. NFPA 805 defines a fire model as Mathematical prediction of fire growth, environmental conditions, and potential effects on structures, systems or components based on the conservation equations or empirical data.
- a. NFPA 805 Section 2.4.1.1 requires that fire models be acceptable to the AHJ (which is NRC for nuclear power plants).
- i. Although the KPS fire modeling was reviewed through the peer review process, the fire models used must be acceptable to the AHJ (which is NRC) even though they are used to support the Fire PRA.
- b. NFPA 805 Section 2.7.3. requires each calculational model or numerical method used shall be independently reviewed, verified & validated, used within its limitations, performed by qualified reviewers, and include an uncertainty analysis.
- i. Although the KPS fire modeling was reviewed through the peer review process, how these quality requirements have been met may not have been addressed by the peer review. For the staff to conclude that these requirements have been met, explain how each of these items have been addressed.
3
- 5. Please provide the Facts and Observations (F&Os) from the latest independent Peer Review of the Kewaunee internal events PRA, and the resolution of the F&Os. From the current description of the reviews in the LAR, the latest independent Peer Review would have been performed before the 2007 self-assessment.
- 6. Please provide an estimate of the risk decrease associated with voluntary plant modifications (i.e.,
modifications not required to bring the plant into compliance with the deterministic fire protection requirements).
- 7. Is the final fire Peer Review report available? If the final report on the fire PRA peer review is available, please identify any substantive differences between the draft and the final reports.
Hearing Identifier:
NRR_PMDA Email Number:
220 Mail Envelope Properties (Karl.Feintuch@nrc.gov20111219155700)
Subject:
ME7250 - Kewaunee - NFPA-805 - LIC-109 Acceptance Review Results Sent Date:
12/19/2011 3:57:59 PM Received Date:
12/19/2011 3:57:00 PM From:
Feintuch, Karl Created By:
Karl.Feintuch@nrc.gov Recipients:
"Craig D Sly" <craig.d.sly@dom.com>
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