PNP 2014-035, Revised Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors
| ML14092A126 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/02/2014 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2014-035 | |
| Download: ML14092A126 (4) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway
-Entergy 7642000 Anthony J Vitale Site Vice President PNP 201 4-035 April 2, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Revised Response to Request for Additional Information License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Palisades Nuclear Plant Docket 50-255 License No. DPR-20
References:
1.
ENO letter, PNP 2012-106, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated December 12, 2012 (ADAMS Accession Number ML12348A455) 2.
ENO letter, PNP 2013-013, Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated February 21, 2013 (ADAMS Accession Number ML13079A090) 3.
NRC electroni mail of August 8, 2013, Palisades
- Requests for Additional Information Regarding Transition to the Fire Protection Program to NFPA Standard 805 (TAC No. MF0382) (ADAMS Accession Number ML13220B131) 4.
ENO letter, PNP 2013-075, Response to Request for Additional Information License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated September 30, 2013 (ADAMS Accession Number ML13273A469) 5.
ENO letter, PNP 2013-079, Response to Request for Additional Information License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated October 24, 2013 (ADAMS Accession Number ML13298A044)
PNP 2014-035 April 2, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J Vitale Site Vice President
SUBJECT:
Revised Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Palisades Nuclear Plant Docket 50-255 License No. DPR-20
References:
- 1. ENO letter, PNP 2012-106, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors," dated December 12, 2012 (ADAMS Accession Number ML12348A455)
- 2. ENO letter, PNP 2013-013, "Response to Clarification Request-License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors," dated February 21, 2013 (ADAMS Accession Number ML13079A090)
- 3. NRC electfOnic mail of August 8, 2013, "Palisades - Requests for Additional Information Regarding Transition to the Fire Protection Program to NFPA Standard 805 (TAC No. MF0382)" (ADAMS Accession Number ML13220B131)
- 4. ENO letter, PNP 2013-075, "Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors", dated September 30, 2013 (ADAMS Accession Number ML13273A469)
- 5. ENO letter, PNP 2013-079, "Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors", dated October 24,2013 (ADAMS Accession Number ML13298A044)
PNP 201 4-035 Page 2 of 2 6.
ENO letter, PNP 2013-083, Response to Request for Additional Information License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated December 2, 2013 (ADAMS Accession Number ML13336A649)
Dear Sir or Madam:
In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request to adopt the NFPA 805 performance-based standard for fire protection for light water reactors. In Reference 2, ENO responded to a clarification request. In Reference 3, ENO received electronic mail Request for Additional Information (RAI5). In Reference 4, ENO submitted the 60-day RAI responses.
In Reference 5, ENO submitted the revised 90-day RAI responses. In Reference 6, ENO submitted the 120-day RAI responses.
In Attachment 1, ENO is providing a revised 90-day RAI response for Safe Shutdown Analysis (SSA) RAI 07. The SSA RAI 07 revised response supercedes the SSA RAI 07 response provided in Reference 5.
A copy of this response has been provided to the designated representative of the State of Michigan.
This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2, 2014.
Sincerely,
Attachment:
- 1. Revised Response to Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors cc:
Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USN RC State of Michigan PNP 2014-035 Page 2 of 2
- 6. ENO letter, PNP 2013-083, "Response to Request for Additional Information - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors", dated December 2, 2013 (ADAMS Accession Number ML13336A649)
Dear Sir or Madam:
In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request to adopt the NFPA 805 performance-based standard for fire protection for light water reactors. In Reference 2, ENO responded to a clarification request. In Reference 3, ENO received electronic mail Request for Additional Information (RAls). In Reference 4, ENO submitted the 60-day RAI responses. In Reference 5, ENO submitted the revised 90-day RAI responses. In Reference 6, ENO submitted the 120-day RAI responses.
In Attachment 1, ENO is providing a revised 90-day RAI response for Safe Shutdown Analysis (SSA) RAI 07. The SSA RAI 07 revised response supercedes the SSA RAI 07 response provided in Reference 5.
A copy of this response has been provided to the designated representative of the State of Michigan.
This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2, 2014.
Sincerely,
Attachment:
- 1. Revised Response to Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors cc:
Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan
ATTACHMENT 1 REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTORS NRC REQUEST SAFE SHUTDOWN ANALYSIS (SSA) RAI 07 In LAR Attachment G, Table G-2, for Fire Area 23, the staff noted that a recovety action may be required to provide portable fans for cooling to the CR based on a postulated fire in Fire Area 22, turbine lube oil room. During the audit, the licensee indicated the portable fans used for this recoveiy action are gasoline powered.
The requirements of General Design Criterion 3 (GDC-3) state for fire protection that structures, systems, and components (SSCs) important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and CR. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.
The use of gasoline near the CR does not align with GDC-3. The use and refueling of a portable gasoline-powered blower presents a hazard to equipment important to nuclear safety. The use ofportable fuel-fired equipment should be consistent with the requirements of GDC-3.
Provide an approach to resolving the subject VFDRs and providing CR ventilation that is consistent with the requirements of GDC-3.
ENO REVISED RESPONSE By letter dated October 24, 2013, Entergy Nuclear Operations (ENO) provided the NFPA 805, 90-day RAI response for PNP, which included a response to SSA RAI
- 07. After subsequent conference calls with the NRC regarding this RAI response, ENO determined that an alternate approach to resolve VFDRs that rely on the use of gasoline powered portable fans for temporary control room ventilation was necessary at PNP.
Implementation of an alternate approach, consistent with the requirements of GDC-3, will be included as part of the overall NFPA 805 implementation timeline.
Page 1 of 2 ATTACHMENT 1 REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTORS NRC REQUEST SAFE SHUTDOWN ANAL YSIS (SSA) RAI 07 In LAR Attachment G, Table G-2, for Fire Area 23, the staff noted that a recovery action may be required to provide portable fans for cooling to the GR based on a postulated fire in Fire Area 22, turbine lube oil room. During the audit, the licensee indicated the portable fans used for this recovery action are gasoline powered.
The requirements of General Design Griterion 3 (GOG-3) state for fire protection that structures, systems, and components (88Gs) important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and GR. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not Significantly impair the safety capability of these structures, systems, and components.
The use of gasoline near the GR does not align with GOG-3. The use and refueling of a portable gasoline-powered blower presents a hazard to equipment important to nuclear safety. The use of portable fuel-fired equipment should be consistent with the requirements of GOG-3.
Provide an approach to resolving the subject VFORs and providing GR ventilation that is consistent with the requirements of GOG-3.
ENO REVISED RESPONSE By letter dated October 24, 2013, Entergy Nuclear Operations (ENO) provided the NFPA 805, gO-day RAI response for PNP, which included a response to SSA RAI
- 07. After subsequent conference calls with the NRC regarding this RAI response, ENO determined that an alternate approach to resolve VFDRs that rely on the use of gasoline powered portable fans for temporary control room ventilation was necessary at PNP.
Implementation of an alternate approach, consistent with the requirements of GDC-3, will be included as part of the overall NFPA 805 implementation timeline.
Page 1 of 2
ENO has also confirmed that there are no other VFDRs/recovery actions, beyond temporary control room ventilation, that relied on the use of gasoline powered portable fans.
This revised response to SSA RAI 07 supersedes the original response submitted on October 24, 2013.
Page 2 of 2 ENO has also confirmed that there are no other VFDRs/recovery actions, beyond temporary control room ventilation, that relied on the use of gasoline powered portable fans.
This revised response to SSA RAI 07 supersedes the original response submitted on October 24,2013.
Page 2 of 2