ML091550768

ME1387-ME1404, Draft Emergency Amendment Request - Comments from PRA Branch

ML091550768
Person / Time
Site:	FitzPatrick
Issue date:	06/02/2009
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Eugene Dorman, Joseph Pechacek Entergy Nuclear Northeast, Entergy Nuclear Operations
vaidya B, NRR/Dorl/lpl1-1, 415-3308
References
TAC ME1387, TAC ME1404
Download: ML091550768 (3)

Text

From: Bhalchandra Vaidya Sent: Tuesday, June 02, 2009 4:32 PM To: 'Pechacek, Joseph'; Dorman, Eugene Cc: John Boska; Douglas Pickett; Andrew Howe; Donnie Harrison; Richard Guzman

Subject:

FitzPatrick, Emergency Amendment Request - Ext of AOT in Ts 3.8.1 The PRA Branch reviewer has identified the following in the draft version of the submittal:

A quick check of the draft submittal revealed that Entergy has apparently not performed the necessary PRA model peer review and/or self-assessment to conform to the guidance of RG 1.200. Specifically, their submittal states that the PRA model "has not been through the Regulatory Guide 1.200 peer review process" The industry peer review was conducted in 1997 and the comments from this assessment are identified as addressed and incorporated into the PRA model. However, RG 1.200 requires a "gap assessment" against the requirements of the internal events ASME standard as modified and clarified by the RG. The submittal does not state that this assessment has been done.

RG 1.200 for internal events has been available for industry use since 2006, and has been the NRC's guidance for internal events PRA technical adequacy since January 2008, consistent with the Commission's policy on the phased approach to PRA quality. The licensee will need to identify that the gap assessment has been performed, discuss the results of this assessment as it pertains to this application, and submit the required documentation in accordance with RG 1.200 Section 4.2 for identifying the relevant technical elements and how their PRA model compares to the requirements of the internal events standard for this application. If the gap assessment has not been performed such that RG 1.200 is not conformed with, then DRA intends to reject this application.

The following deficiencies are also apparent, again from a very quick scan of the document:

- There is no discussion of the cause/effect relationship; given the teleconference focus on the capability of one EDG to safely shutdown the unit, I would need a discussion of the PRA model assumptions with regards to mitigation of a loss of offsite power (i.e., what is the success criteria for # of EDGs). Note that the staff will also need to understand LOOP frequency, recovery probabilities, and any assumed EDG repairs to assess the apparent very low probability of core damage.

- The fire analysis is based on an out-of-date fire PRA model which is stated to be conservative; the submittal does not: discuss how the licensee determined that plant changes made since the IPEEE were determined to be conservative with respect to fires; address any of the aspects identified in RG 1.200 (Section 1.2.4); does not discuss cause/effect relationships as to which fire areas could result in a LOOP and the resulting plant effect; does not discuss screened out areas and how the fire PRA calculations address.

- The submittal does not discuss whether internal or external flooding is impacted by an unavailable DG, only that the IPE/IPEEE did not identify significant contributions; this is not adequate for the staff to disposition these events.

- The submittal is silent on other external hazards.

- Commitment #6 regarding re-evaluation by the licensee to determine if the NRC's basis for granting the request remains valid is not appropriate. The tier 2 process of RG 1.177 requires the licensee to identify, a priori, the plant equipment which needs to remain available to justify the request. Emergent failures are required to be handled either by a TS, license condition, or

commitment to immediately shut down if the risk is known up front to be unacceptable, or to handle in the tier 3 configuration risk management program if the risk may be acceptably managed.

Please make sure that these comments are addressed in the "Final" version of the Emergency Amendment Request.

Please contact me, if you have any questions.

Bhalchandra K. Vaidya Licensing Project Manager NRC/NRR/DORL/LPL1-1 (301)-415-3308 (O) bhalchandra.vaidya@nrc.gov E-mail Properties Mail Envelope Properties ()

Subject:

FitzPatrick, Emergency Amendment Request - Ext of AOT in Ts 3.8.1 Sent Date: 06/02/2009 4:26:13 PM Received Date: 06/02/2009 4:31:00 PM From: Bhalchandra Vaidya Created By: Bhalchandra.Vaidya@nrc.gov Recipients:

JPechac@entergy.com ('Pechacek, Joseph')

Tracking Status: None EDorman@entergy.com (Dorman, Eugene)

Tracking Status: None John.Boska@nrc.gov (John Boska)

Tracking Status: None Douglas.Pickett@nrc.gov (Douglas Pickett)

Tracking Status: None Andrew.Howe@nrc.gov (Andrew Howe)

Tracking Status: None Donnie.Harrison@nrc.gov (Donnie Harrison)

Tracking Status: None Richard.Guzman@nrc.gov (Richard Guzman)

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 13934 06/02/2009

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Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: