ML031890259

Summary of Regulatory Conference with Entergy Operations, Inc. River Bend Station

ML031890259
Person / Time
Site:	River Bend
Issue date:	07/02/2003
From:	Graves D NRC/RGN-IV/DRP/RPB-B
To:	Hinnenkamp P Entergy Operations
References
Download: ML031890259 (65)

Text

UNITED STATES NUCLEAR REGULATORY OMMISSION

..I REGION IV t --

611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-4005 JUL - 2 2003 Paul D. Hinnenkamp Vice President - Operations River Bend Station Entergy Operations, Inc.

P.O.Box 220 St. Francisville, Louisiana 70775

SUBJECT:

REGULATORY CONFERENCE WITH ENTERGY OPERATIONS, INC.

CONCERNING THE RIVER BEND STATION

Dear Mr. Hinnenkamp:

This refers to the meeting conducted in the Region IV office of the Nuclear Regulatory Commission, located in Arlington, Texas, on June 23, 2003, to discuss safety concerns identified during the September 18, 2002, event which involved a turbine trip and subsequent reactor scram with a loss of feedwater flow.

Issues discussed at the conference included a synopsis of the event, the apparent violation identified during the special inspection of the event, and a review of the assessment of risk associated with the event.

During the meeting your staff indicated that documentation describing the process your staff used to complete your risk assessment would be provided to NRC within 2 weeks. We will review this information and inform you if additional information is required.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title IO, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.

Should you have any questions concerning this matter, we will be pleased to discuss them with you.

Sincerely, P.2.3--

David N. Graves, Chief Project Branch B Division of Reactor Projects Docket: 50-458 License: NPF-47

Entergy Operations, Inc.

Enclosures:

1. Agenda

2. Attendance List

3. Licensee Presentation cc w/en closures:

Senior Vice President and Chief Operating Officer Entergy Operations, lnc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 General Manager Plant Operations River Bend Station Entergy Operations, Inc.

P.O. Box220 St. Francisville, Louisiana 70775 Director - Nuclear Safety River Bend Station Entergy Operations, Inc.

P.O. Box220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway P.O. Box651 Jackson, Mississippi 39205 Mark J. Wetterhahn, Esq.

Winston & Strawn 1401 L Street, N.W.

Washington, DC 20005-3502 Manager - Licensing River Bend Station Entergy Operations, Inc.

P.O. Box220 St. Francisville, Louisiana 70775

Entergy Operations, Inc. The Honorable Richard P. leyoub Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70806 President West Feliciana Parish Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 Michael E. Henry, State Liaison Officer Department of Environmental Quality Permits Division P.O. Box4313 Baton Rouge, Louisiana 70821-4313 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, Texas 78701-3326

I Entergy Operations, Inc. t *-

Electronic distribution by RIV:

Acting Regional Administrator (TPG) I DRP Director (ATH)

Acting DRS Director (TWP)

Senior Resident Inspector (PJA)

Branch Chief, DRP/B (DNG)

Senior Project Engineer, DRP/B (RAKI)

Staff Chief, DRP/TSS (PHH)

RlTS Coordinator (NBH)

ADAMS: Rqves 6 Publicly Available 0 No Initials: P 0 Non-Publicly Available El Sensitive Non-Sensitive OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE 1 Regulatory Conference Agenda CONFERENCE WITH ENTERGY OPERATIONS, INC.,

RIVER BEND STATION JUNE 23,2003 NRC REGION IV, ARLINGTON, TEXAS

1. Introduction and Opening Remarks Pat Gwynn, Acting Regional Administrator

2. Issue Discussion Gail Good, Acting Deputy Director, Division of Reactor Projects

3. Licensee Presentation

4. NRCCaucus

5. Resume Conference

6. NRC Closing Remarks Pat Gwynn

ENCLOSURE 2 REGULATORY CONFERENCE ATTENDANCE

,_ 1 LICENSEE/FACILlTY Entergy Operations/ River Bend Station DATEIT1ME June 23, 2003/1:00 p.m. CDT LOCATION U. S. NRC Region IV Office, 611 Ryan Plaza Drive, Suite 400 I Arlington. TX ~

NAME (PLEASE PRINT) 0RGANIZATION I

REGULATORY CONFERENCE ATTENDANCE II LICENSEE/FACILITY Entergy Operations/ River Bend Station I DAT E/TIME June 23, 2003/1:00p.m. CDT LOCATION U.S. NRC Region IV Office, 611 Ryan Plaza Drive, Suite 400 Arlington, TX 1 NAME (PLEASE PRINT) ORGANIZATION Page of -3

REGULATORY CONFERENCE ATTENDANCE

~~

LICENSEE/FACILITY Entergy Operations/ River Bend Station l---GGG- June 23, 2003/1:00p.m. CDT LOCATION U.S. NRC Region IV Office, 61IRyan Plaza Drive, Suite 400 Arlington, TX 1 NAME (PLEASE PRINT) ORGANIZATlON J

Page L_ of 2

REGULATOI 1 CONFERENCE ATTENDANCE

~

LICENSEE/FACILlTY Enterqv Operations/ River Bend Station DATE/TIME June 23, 2003/1:00 p.m. CDT LOCATION U. S. NRC Region 1V Office, 611 Ryan Plaza Drive, Suite 400 Arlington, TX NAME (PLEASE PRINT) ORGANIZATION Page of 2

ENCLOSURE 3 River Bend Station eptember 2002 Scram Event Risk Perspectives 1

Opening Remarks Bill Eaton, VP Engineering 1

2

Opening Remarks B. Eaton Agenda Review & Timeline R. King Event Description J. Clark Risk Model/Methodology D. Rao

- PSAModel

- Evaluation Results 0 Risk Evaluation L. Bedell

- Internal Risks 0 Changes to Model

- External Risks Design Basis Review Review of Actual Plant Conditions Scenarios for September Scram

- Large Early Release

- Fire Fire Risk Assumptions Detailed Fire Risk Evaluation 0 Regulatory Summary R. King 0 Closing Remarks B. Eaton 3

I imeline Milestone I Risk (ICCDP)

I9/18/02 Plant Scram w/ Loss of Feedwater Initial risk evaluation 9.3E-7 I 11/14/02 NRC Identified Finding Procedure Inadequate I 1/9/03 NRC SRA on site @ RBS 7.7 E-7 12/7/03 IR issued 1 I I3/19/03 SRA informed of IPEEE actions for I 8 fire areas RBS provided SRA with external events information 7.7 E-7 (IPEEE screening results)

Notified of preliminary finding greater than Green 15/6/03 Choice letter received d I

I5/20/03 RBS decision on Reg. Conf. I 5.3 E-7 ENS PSA Dialogue with 4 NRC PSA David Loveless

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-Entwgy Agenda Opening Remarks B. Eaton

- PSAModel

- Evaluation Results k Evaluation L. Bedell

- Internal Risks 0 Changes to Model

- External Risks Design Basis Review Review of Actual Plant Conditions Scenarios for September Scram

- Large Early Release

- Fire 0 Fire Risk Assumptions e Detailed Fire Risk Evaluation 0 Regulatory Summary R. King 0 Closing Remarks B. Eaton

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Event Description Reactor Level 3

- Feedwater Level Control System set point set down actuated as designed causing a rapid increase in Condensate / Feedwater System Flow

- Unexpected closing of full flow filtration bypass valve (CNM-FCV200)

- Reactor feed pumps tripped on low suction pressure

- RClC was initiated to maintain Reactor level

- Condensate System was shutdown by the operators due recognition of leakage d

Entwg-y Agenda 0 Opening Remarks B. Eaton enda Review & Timeline R. King 0 Event DescriDtion J. Clark a Risk Model/Methodology B. Rao

--PSA Model

-Evaluation Results Risk Evaluation L. Bedell

- Internal Risks Changes to Model

- External Risks Design Basis Review Review of Actual Plant Conditions Scenarios for September Scram e Large Early Release 0 Fire

- Fire Risk Assumptions

- Detailed Fire Risk Evaluation 0 Regulatory Summary R. King osing Remarks B. Eaton

Entwgy PSA Model Current Model Reflects plant design and procedure changes since the IPE submittal, Le., reflects the as-built; as-operated plant.

Implemented in EOOS Risk Monitor 8

Reviewed by an industry (BWROG) PSA Certification team.

e Includes RBS plant specific operating history (failure data and initiating events) a e

Rev 3A (completed November 2002) 0 Model Configuration Control Reviews of lant changes (design & procedural) per EN-S PSA l

Procedure E-P-05.0I 0

PSA Model Change Request (MCR) database used to track issues 1 Q

Important issues are addressed with higher priority 9

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-Entergy PSA Model

- Long-term enhancements 0 Scheduled

- External Events PSA

- Transition Risk

- Improved LERF Tools

- Shutdown Risk Models

- Developed interim fire risk tool This really was an accelerated item to assist in LheSept. I 8 scram risk evaluation Provided us additional insights that we will apply to all EN-S sites 11

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-Entwgy PSA Model

- Accelerated Update Provides more accurate characterization of event Reviewed model changes that would impact CDF Focused primarily on impact to high pressure injection and depressurization Accelerated these update items to support September Scram Risk Assessment 12

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-cL-cc roved Fire Risk Model 0

The Sept. I 8 scram evaluation has resulted in an Improved Fire Risk Quantification Tool being available for future evaluations at River Bend 0

Considerably more realistic than IPEEE screening fire evaluations e

end to apply this enhancement to other EN-S PSAs e es the latest tree corresponding to the as built, as operated plant (instead of IPEEE vintage model) e is tool will help in better managing RBS risk profiles in the future

Risk Evaluation Results Initial Entergy After PSA k Evaluation Refinements for 126-day period Fire Risk ICCDP 9.3E-7 Not significant (well ICCDP quantified below 1E-6) via with additional results from model refinements screening method to be -3E-I0 Internal ICCDP 9.3E-7 ICCDP -7.7E-7 ICCDP quantified Events using MOR with updated model and shown to be

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Risk Evaluation Results Risk Pre-Special Initial Entergy After PSA Component Inspection Risk EvaIuat ion Refinements for 126day Evaluation period LERF Considered to be Considered to be ALERF assessed insignificant insignificant to be below 5E-9 Total Risk & ICCDP 9.3E-7 -7.7E-7 (ICCDP) 4 3 E - 7 (ICCDP);

considered external <5E-9 (ALERF) events, assessed to external events be insignificant confirmed to be insignificant 1

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Agenda Opening Remarks B. Eaton Agenda Review & Timeline R. King Event Description J. Clark 0 Risk ModeVMethodology D. Rao

- PSAModel

- Evaluation Results I .Risk.Internal Evaluation Risks L. Bedell

• Changes to Model

• External Risks

.Design Basis Review

• Review of Actual Plant Conditions

• Scenarios for September Scram

• Large Early Release

• Fire

.Fire Risk Assumptions

• Detailed Fire Risk Evaluation gulatory Summary R. King sing Remarks B. Eaton 18

Preliminary Significance Determination Internal Events ICCDP of 7.7E-7 All Reactor Scrams would Result in a Loss of Feedwater and Condensate Limited Credit For CRD with HPCS and RCIC Failure to Run (after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />)

Fire ICCDP of 8E-7 PRA Screening Process used to Determine Fire ICCDP NRC combined internal and external events to derive a best estimate judgment of I.6E-6.

The NRC agreed with the internal events number of 7.7E-7 in their letter of May 2,2003.

1

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-Entergy Risk Evaluation Internal Events

-Changes to Model 1 0

External Events

-Design Basis Review

-Review of Actual Plant Conditions

-Scenarios for September Scram 0

Large Early Release 0

Fire Risk Events

-Fire Risk Assumptions I

--Detailed Fire Risk Evaluation

a (lec3.

Entwgy Current Model Features I MOR features:

- Div 3-Cross Connect

- Instrument Air Plant Mods

- Component Cooling Water Plant Mods

- Service water 599 valve mod (EDG return valve)

- DC power system modeling refinements in MOR

- RClC system mods

- Offsite power recovery is more accurate

- CRD availability I 21

Internal Events Model Accelerated Updates:

- Incorporated CRD following HPCS and RCIC failures after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

- Updated DC Power Model to remove Battery Depletion for Systems that Start Early

- Removed DC Dependencies for MCC Powered Components 22

Accelerated Updates:

- Corrected removal of HPCS & RClC in EOOS calculation (Increase in CDF)

- Updated HPCS and RClC Failure to Start Probabilities based on plant specific data

- Updated Common Cause Failure of ADS Valves I Based on NUREG/CR-5497 23

Internal Events Results Based on Model m27E-7 = (9.95E-6/yr - 8.46E-6/yr)

• 126/365 24

Risk Evaluation 0 Internal Events

- Changes to Model

-Design Basis Review

-Review of Actual Plant Conditions rge Early Release

- Fire Risk Assumptions

- Detailed Fire Risk Evaluation 25

lllr Entergy External Event Overview 6 ternal Event Review

- Seismic

- High Winds (Hurricanes, Tornadoes)

- External Flooding

- Transportation

- Other (Severe Weather, Lightning, External Fire) 26

m c-Entwg-y Design Basis Information 0

Feedwater and Condensate are not credited for DBA ternal Events.

0 edwater and its Support Systems are Non-Seismic ategory and Non-Safety Related.

All Feedwater support systems are not protected from weather events (offsite power lines).

I 27

Qualitative Review of Actual Data Seismic frequenc for RBS is very low (>0.5g seismic Y

0 event = 1.2E-6/yr Highest average Wind I O mph Mild Drought (flooding less likely) curity changes reduce transportation events eked at all scenarios and eliminated them as possible contributors to risk.

I Meets 1975 Standard Review Plan for IPEEE and design basis.

28

Risk Evaluation ternal Events

- Changes to Model 0 ternal Events

- Design Basis Review

- Review of Actual Plant Conditions

- Scenarios for September Scram b

Io arge Early Release I 0 e Risk Events

- IPEEE Methodology

- Detailed Fire Risk Evaluation 29

Large Early Release Major Contributors to LERF

- Containment Isolation

- Hydrogen Igniters

- Suppression Pool Bypass vel ICutsets show Major Contributors Not Impacted by Event ALERF Impact Estimated at -5E-9 30

Risk Evaluation Internal Events

- Changes to Model External Events

- Design Basis Review

- Review of Actual Plant Conditions

- Scenarios for September Scram 0 rge Early Release Fire Risk Events

-Fire Risk Assumptions

-Detailed Fire Risk Evaluation 31

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-Entwgy Fire Risk Overview e EEE Fire Risk Assumptions 0 IPEEE Screening Process Re-Evaluated Fire Areas w/ Feedwater Credit ire Risk Results

- Fire ICCDP = 8E-7 Based on IPEEE Fire Screening Process 32

eEntwg-y Fire Protection Design 0 Post-Appendix R Plant visional Cable Separation rong Fire Barriers edomin-antly IEEE-383 Cable Little reliance on manual actions Detection and suppression in most areas IPEEE screening method does not measure the impact of post Appendix R designs 33

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- I terg>. Fire Risk Assumptions

- IPEEE All Fires in the Appendix R Fire Areas result in a Reactor Scram 0

Generally Only Credited SSA Equipment 0

ry little credit for automatic or manual suppression e

omponents fail in worst case position 0

No Credit for Thermo-Lag Fire Barriers 34

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process CDFelE-6 w/ Credit Unscreened for Feedwater & (CDFBI E-6) (7) support systems (22)

No SSA Equipment C D F 4 E-6 w/Manual (611 Suppression of Transient Fires (3)

CDF4E-6 by Adjusting Frequency due to Fire Modeling (30)

C D F 4 E-6 after fire modeling (8)

Containment Zones C D F 4 E16 / Complete (17)

Damage (16)

I 6 4 Appendix R Fire Zones 36

Re-Evaluation of Feedwater Areas Reviewed fire zones to identify.those that credited feedwater 0

o techniques used for re-evaluation

- Review for scram potential

- Calculate fire severity factors 37

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-Entwgy Fire-Area Evaluation process Remaining zones (3)

Zones not reviewed (DC Initiator) (4)

Reviewe d

\ equipment&

cables for scram potential (I5)

Fire Zones w/ Credit for Feedwater & Support Systems 38

Fire Zone Screenina Method U Fire Screen # Zones Crqg&wl for Feedwater Impact of Crediting FW Other Areas of Evaluation

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Unscreened 7 FW not credited, cannot easily Base CDFs drop from E-6 range to E-9 Scram Potential, Severity Factors determine damage to FW or Supports, range. Also scram potential drops.

Delta CDF evaluated as 0.

Feedwater 22 FW credited. Risk impact Base CDFs drop from E-7 range to E- Done.

Credit, Manual evaluated. 10 range. Also scram potential drops. Scram Potential, Severity Factors Suppress 3 FW not credited. Cannot easily determine damage to FW or Supports, Delta CDF evaluated as 0.

Fire Scenario 30 FW not credited. Screened wlo Base CDFs drop from E-7 range to E- Scram Potential, Severity Factors, Frequency evaluating FW. ll range. Also scram potentialdrops. Manual Suppression I Fire Modeling All Damage 8 Nv not credited. Screened wlo evaluating FW.

16 FW not credited. Screened w/o Based CDFs drop from E-7 range to E-12 range. Also scram potential drops.

Based CDFs drop from E-7 range to E-Scram Potential, Severity Factors, Manual Suppression, Fire Scenario Frequency Scram Potential, Severity Factors, evaluating FW. 14 range. Also scram potential drops. Manual Suppression, Fire Scenario Frequency, Fire Modeling.

Containment 17 FW not credited. Screened Evaluation of scram potential. Scram Potential, Severity Factors, qualitatively. Manual Suppression, Fire Scenario Frequency, Fire Modeling.

I No SSA 61 FW not credited. Screened Evaluation of scram potential. Scrams ~ Scram Potential, Severity Factors, qualitatively. bounded by internal events PSA. Manual Suppression, Fire Scenario Frequency, Fire Modeling.

Fire Risk for zones is insignificant.

w pire Area txamples I

Example I: r Consider zone AB-2/Z-l in the River Bend Fire PSA, the HPCS Room.

40

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- En'w@ ABn2/Z-1 Fire PSA Updates oom contains the following equipment and cables in addition to HPCS equipment:

R, Auxiliary Building Floor drain system, level switches, pumps (non-safety)

RMS, RHR Room East Radioactivity Monitors, (non safety)

SSR, Reactor Plant Sample System (non-safety)

HVR HPCS Room Unit Cooler power cable.

0 JPB, non-safety 120V power to receptacle in instrument rack.

0 S, RHR Pump Room 2C, Elevator Area, RPCCW Area , and R Hoist area temperature (both divisions I and 11). These isolate 2-MOVF008 and E l 2-MOVF009 shutdown cooling isolation es. These valves are required to open approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdown for cooling and are addressed in the safe shutdown analysis.

0 ERS, Earthquake recording system (non-safety) 41

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-Entergy AB-2IZ-I Fire PSA Updates Initial Entergy After PSA Refinements Comments evaluation Baseline 4.64E-11 0 PSA Refinements wlfeedwater Review of cable routings include:

available showed that a fire in this zone .Model update would not cause a plant .Use of updated model scram in the fire risk Case 5.64E-8 0 quantification w/Feedwater (would screen per Review of cable routings unavailable IPEEE) showed that a fire in this zone would not cause a plant scram A CDF 5.64 E-8 0 Feedwater did not impact the result (it was not envisioned that a ACDF would be determined using this information) 42

Fire Severity Factors 0 Definition: Fraction of historical fires (EPRI Fire Events Database) in the area that are severe 0

Calculated Fire Severity Factors for 22 zones w/

edwater credit re frequency reduced by the fire severity Severity factors ranged from 0.01 to 0.24 43

Fire Severity Factors 0

AC-l78L, EPRI Fire Events Database used for evaluation NSAC-178L also used for IPEEE Fire Frequencies Review of EPRI TR-I0031 II(Update of NSAC-178L) -

eve looked at the standard and confirmed no nificant impact.

44

EntMgy Fire Severity Split Fraction Qualitative Meaning Value ndication of a severe fire I I.o lete or inadequate information to formulate a clear 0.5 understanding of event but the description or other similar events would indicate that the event was not severe.

Indication that the event was not severe but extenuating 0.1 circumstance could have altered this evaluation such as a delay in response to the fire or the presence of additional combustible material that did not happen to ignite.

Very unlikely that the event was a severe fire, but cannot be 0.05 pletely ruled out based on the information provided.

meets criteria for exclusion as a severe fire I 0.0 45

Fire Area txampies Example 2:

Consider zone in the Fire PSA, the C18 Room (DIVI DC)

This room contains the following equipment and cables in addition to Division 1 DC Power:

0 Ventilation system cables for battery room temperature control and monitoring (non-safety).

46

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Entergy C18 Fire PSA Updates 3.80E-09 3.04E-11 PSA Refinements zone wl Feedwater include:

.Model update including DC power Case CDF/yr for 4.92E-07 3.31E-1 1 refinernent zone w/ Feedwater *Application of Fire unavaiiable Severity Factor for 4.88E-07 2.74E-12 this zone Feedwater did not *No credit taken for impact the result (it auto or manual was not envisioned suppression of fire that a ACDF would be determined using this information) 48 U

Fire Risk Results by Zone Fire Zone Base CDFlyr Case CDF/yr ACDFlyr (wlo 9 I feadwater) c-I3A 0.02 5.64E-13 2.97E-I 2 2.41 E-I 2 C-I 3B 10.02 I 5.64E-13 I 2.97E-12 I2.41E-12 I I I I 6-2 1 I0.014 I1.81E-I2 I 1.40E-10 1 1.38E-I0 I

~

C-23 10.014 13.04E-12 I 2.8OE-IO 1 2.77E-10 C-26 10.014 I 3.19E-I2 I 3.56E-IO I 3.53E-IO I

Total I I6.61E-I1 I 1.01E-09 1 9.43E-IO if a Severity Factor of .I is assumed, ACDF c 10E-8.

Fire Risk Results Incremental Risk = (instant. CDF (/yr) - base CDF)

• 2 Actual Time (days) /365 d/yr 3.27E-10 = (1.OlE 6.61E-11)

• 1261365 50

Agenda Opening Remarks B. Eaton Agenda Review & Timeline R. King Event Description J. Clark Risk ModeVMethodology D. Rao

- PSAModel

- Evaluation Results Risk Evaluation L. Bedell

- Internal Risks Changes to Model

- External Risks Design Basis Review Review of Actual Plant Conditions Scenarios for September Scram

- Large Early Release

- Fire 0 Fire Risk Assumptions 0 Detailed Fire Risk Evaluation Closing Remarks B. Eaton 51

e

-cc.cL Preliminary Significance Determination inspection Report 02-07:

"B O O installed a plant modification, in a mporary condition, without providing fficiently detailed operating procedures and/or 'operator training. "

52

Risk Results Summary Pre-Special Initial Entergy After PSA Inspection Risk Eva1uation Refinements Evaluation (1103 - 3/03) (6103)

(9/02)

Internal Events 9.3 E-7 (ICCDP) -717E-7 (ICCDP) -5.3E-7 (ICCDP)

External Events 0 Screened:

Insignificant

(<I E-6) 9.3 E-7 (ICCDP) -7.7E-7 (ICCDP) -5.3E-7 (ICCDP);

considered external external events events, assessed to confirmed to be be insignificant insignificant 53

Regulatory Summary I GREEN II 54

Agenda Int roduction R. King Opening Remarks B. Eaton Event Description J.. Clark Risk Model/Methodology D. Rao

- PSAModel

- valuation Results Key Assumptions L. Bedell

- internal Risks xternal Risks 0 Seismic Flooding Hurricane High Wind Transportation

- Large Early Release

- Fire Regulatory Summary R. King 0 Conclusion B. Eaton I

55