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

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 EntergyNuclear NuclearOperations, Operations,Inc.

Inc.

Palisades PalisadesNuclear NuclearPlant Plant 27780 27780Blue BlueStar StarMemorial MemorialHighway

-Entergy Highway Covert, MI 49043-9530 Tel 269 764 2000 7642000 AnthonyJJ Vitale Anthony Vitale Site Site Vice Vice President President PNP 2014-035 PNP 201 4-035 April 2, April 2, 2014 2014 U. S.

U. Nuclear Regulatory S. Nuclear Regulatory Commission Commission ATTN: Document Control ATTN: Document Control Desk Desk Washington, DC Washington, DC 20555-0001 20555-0001

SUBJECT:

Revised Response Revised Response to Request Request for for Additional Additional Information Information - License License Amendment RequestRequest toto Adopt NFPA NFPA 805805 Performance-Based Performance-Based Standard Standard for Fire for Fire Protection Protection for Light Light Water Reactors Reactors Palisades Nuclear Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1. ENO letter, PNP 2012-106, "License

References:

License Amendment Request to Adopt Performance-Based Standard for Fire Protection for Light NFPA 805 Performance-Based Water Reactors,"

Reactors, dated December 12, 2012 (ADAMS Accession Number ML ML12348A412348A455)55)

2. ENO letter, PNP 2013-013, 2013-013, Response "Response to Clarification Request- Request License Amendment Request to Adopt NFPA NFPA 805 Performance Performance-Based

-Based Standard for FireFire Protection Protection for Light Light Water Reactors, Reactors," dateddated February February 21, 21, 2013 2013 (ADAMS (ADAMS Accession Number Number ML13079A0 ML13079A090) 90) 3.

3. NRCNRC electroni electfOnic mail mail of of August 8,8, 2013, 2013, Palisades "Palisades - Requests

- Requests for for Additional Additional Information Information Regarding Regarding Transition Transition to to the the Fire Fire Protection Protection Program Program to to NFPA NFPA Standard Standard 805 805 (TAC (TAC No.No. MF0382)

MF0382)" (ADAMS (ADAMS Accession Accession Number Number ML13220B1 ML13220B131) 31) 4.

4. ENOENO letter, letter, PNP PNP 2013-075, 2013-075, Response "Response to to Request Request for for Additional Additional Information Information - License License Amendment Amendment Request Request to to Adopt Adopt NFPANFPA 805805 Performance -Based Performance-Based Standard Standard for for Fire Fire Protection Protection for for Light Light Water Water Reactors, Reactors", dated dated September September 30,30, 2013 2013 (ADAMS (ADAMS Accession Accession Number Number ML1 3273A469)

ML13273A469) 5.5. ENO ENO letter, letter, PNP PNP 2013-079, 2013-079, Response "Response to to Request Request for for Additional Additional Information Information - License License Amendment Amendment Request Request to to Adopt Adopt NFPANFPA 805805 Performance -Based Standard Performance-Based Standard for for Fire Fire Protection Protection for for Light Light Water Water Reactors, Reactors", dated dated October October24, 2013 (ADAMS 24,2013 (ADAMS Accession Accession Number Number ML1 3298A044)

ML13298A044)

PNP 2014-035 PNP 201 4-035 Page 22 of Page of 22

6. ENO letter,

6. ENO letter, PNP PNP 2013-083, 2013-083, "Response Response to to Request Request for for Additional Additional Information - License Information License Amendment Amendment Request Request toto Adopt Adopt NFPA NFPA 805805 Performance -Based Standard Performance-Based Standard for Fire for Fire Protection Protection for for Light Light Water Water Reactors, dated Reactors", dated December December 2, 2, 2013 2013 (ADAMS (ADAMS Accession Accession Number Number ML113336A649)

ML 3336A649)

Dear Sir Dear Sir or or Madam:

Madam:

In Reference 1, In Reference 1, Entergy Entergy Nuclear Nuclear Operations, Operations, Inc. (ENO) submitted Inc. (ENO) submitted aa license license amendment request amendment request to to adopt adopt the the NFPA NFPA 805 805 performance-based performance-based standard standard for fire fire protection for light protection light water reactors.

reactors. InIn Reference Reference 2, 2, ENO ENO responded responded to aa clarification request. In request. Reference 3, ENO received electronic mail Request In Reference Request for Additional Information (RAI5).

Information (RAls). In In Reference ENO submitted the 60-day RAI responses. In 4, ENO Reference 5, ENO Reference ENO submitted the revised 90-day RAI responses. In Reference 6, ENO ENO submitted the 120-day RAI submitted RAI responses.

Attachment 1, ENO is providing a revised 90-day RAI response for Safe Shutdown In Attachment In Analysis Analysis (SSA)(SSA) RAI 07. The SSA RAI 07 revised response supercedes the SSA RAI 07 response provided response provided in Reference 5.

A copy A copy of of this response has been provided to the designated representative this response representative of the State of Michigan.

of Michigan.

This This letter letter contains contains no new commitment commitmentss and no revisions to existing commitment commitments. s.

II declare declare under under penalty of perjury that the foregoing is true and correct. Executed on on April April 2,2, 2014.

2014.

Sincerely, Sincerely,

Attachment:

1. Revised

1. Revised Response Response to to Request Request for for Additional Additional Information Information Regarding Regarding License License Amendment Request to Adopt Amendment Request to Adopt NFPA 805 NFPA 805 Performance -Based Standard Performance-Based Standard for for Fire Fire Protection Protection for for Light Light Water Water Reactors Reactors cc:

cc: Administrato Administrator, r, Region Region III, III, USNRC USNRC Project Project Manager, Manager, Palisades, Palisades, USNRC USNRC Resident Resident Inspector, Inspector, Palisades, Palisades, USNUSNRCRC State State ofof Michigan Michigan

ATTACHMENT 11 ATTACHMENT REVISED RESPONSE REVISED RESPONSE TO TO REQUEST REQUEST FOR FOR ADDITIONAL ADDITIONAL INFORMATION INFORMATION REGARDING LICENSE REGARDING LICENSE AMENDMENT AMENDMENT REQUEST REQUEST TO TO ADOPT NFPA ADOPT NFPA 805 805 PERFORMA PERFORMANCE-BASED NCE-BASED STANDARD STANDARD FOR FOR FIREFIRE PROTECTION PROTECTION FOR FOR LIGHT WATER LIGHT WATER REACTORSREACTORS NRC REQUEST NRC REQUEST SAFE SHUTDOWN SAFE SHUTDOWN ANAL ANALYSIS (SSA) RAI YSIS (SSA) RAI 0707 In LAR In LAR Attachment Attachment G, Table G-2, G, Table G-2, forfor Fire Area 23, Fire Area 23, the the staff staff noted that aa recovery noted that recovety action may action may be required required to to provide portable fans fans for for cooling toto the GR CR based on aa postulated fire postulated fire in in Fire Area 22, turbine lube oil room. room. During the the audit, the licensee licensee indicated the portable fans used for this recovery indicated recoveiy action are gasoline powered.

The requirements The requirements of General Design Griterion Criterion 3 (GOG-3)

(GDC-3) state for fire protection that structures, that structures, systems, and components (SSCs) important to safety shall be (88Gs) designed and located to minimize, consistent with other safety requirements, designed requirements, the probability probability and effect of fires and explosions. Noncombustible and heat resistant Noncombustible materials shall be used wherever practical throughout the unit, particularly in materials locations such locations such as the containment and GR. CR. Fire detection and fighting systems of appropriate appropriate capacity and capability shall be provided and designed to minimize the adverse adverse effects of fires on structures, systems, and components important to safety.

safety. Firefighting Firefighting systems shall be designed to assure that their rupture or inadvertent inadvertent operation significantly impair the safety capability of these operation does not Significantly structures, structures, systems, and components.

The The useuse of gasoline near the CR GR does not align with GDC-3. GOG-3. The use and refueling of of a portable portable gasoline-pow gasoline-powered ered blower presents aa hazard hazard to equipment important to to nuclear nuclear safety.

safety. The use of of portable portable fuel-fired equipment should should be be consistent consistent with with the requirements of of GDC-3.

GOG-3.

Provide Provide an an approach approach to to resolving resolving the the subject subject VFDRs VFORs and and providing providing CR GR ventilation ventilation that that isis consistent with the requirements with the requirements of of GDC-3.

GOG-3.

ENO ENO REVISED REVISED RESPONSE

RESPONSE

By By letter letter dated dated October October 24,24, 2013, 2013, Entergy Entergy Nuclear Nuclear Operations Operations (ENO)(ENO) provided provided thethe NFPA NFPA 805, 805, 90-day gO-day RAIRAI response response for for PNP, PNP, which which included included aa response response to to SSA SSA RAI RAI 07.

07. After After subsequent subsequent conference conference calls calls with with the the NRC NRC regarding regarding thisthis RAI RAI response, response, ENO ENO determined determined that an alternate that an alternate approach approach to to resolve resolve VFDRs VFDRs that that rely rely on on the the use use of of gasoline gasoline powered powered portable portable fansfans forfor temporary temporary control control room room ventilation ventilation waswas necessary necessary at at PNP.

PNP.

Implementat Implementation ion ofof an an alternate alternate approach, approach, consistent consistent with with the the requirements requirements of of GDC-3, GDC-3, will will be be included included as as part part ofof the the overall overall NFPA NFPA 805 805 implementati implementation timeline.

on timeline.

Page Page 11of of 22

ENO has ENO has also also confirmed confirmed that there are that there are no no other other VFDRs/recovery VFDRs/recovery actions, actions, beyond beyond temporary control temporary control room room ventilation, ventilation, that that relied relied on on the the use of gasoline powered use of gasoline powered portable fans.

portable fans.

This revised This revised response response toto SSA SSA RAIRAI 07 supersedes the 07 supersedes the original original response response submitted submitted on October on October 24,2013.

24, 2013.

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