ML14118A293

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NRR E-mail Capture - Request for Additional Information - Palisades - NFPA 805 Project LAR - MF0382
ML14118A293
Person / Time
Site: Palisades Entergy icon.png
Issue date: 03/11/2014
From: Mahesh Chawla
Division of Operating Reactor Licensing
To: Smith K
Entergy Nuclear Operations
References
MF0382
Download: ML14118A293 (5)


Text

NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Tuesday, March 11, 2014 3:44 PM To: Smith, Keith E (ksmit21@entergy.com); Amy Hazelhoff (ahazelhoff@enercon.com); MIKSA, JAMES P (jmiksa@entergy.com)

Cc: Lain, Paul; Metzger, Brian; Klein, Alex; Robinson, Jay; Wall, Scott; Carlson, Robert; Duncan, Eric; Garmoe, Alex; Scarbeary, April; Shah, Swetha

Subject:

Request for Additional Information - Palisades - NFPA 805 Project LAR - MF0382 Attachments: Palisades AFPB Follow Up RAIs TAC No MF0382.docx By letter dated December 12, 2012 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12348A455), as supplemented by letters dated February 21, September 30, October 24, and December 2, 2013 (ADAMS Accession Nos. ML13079A090, ML13273A469, ML13298A044, and ML13336A649 respectively), Entergy Nuclear Operations, Inc. (ENO or the licensee) submitted a license amendment request (LAR) to revise Facility Operating License No. DPR 20 for Palisades Nuclear Plant. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" (NFPA 805).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete the review, as per the attached file. The Fire Protection Branch is requesting the licensee respond to these RAIs as soon as practical (60 days or less). Should the licensee need additional clarification, please contact me to arrange the clarification call. The timeline we would like to follow is to have the clarification call within two weeks of when the licensee receives the drafts and then to issue the final RAIs within two weeks of having the clarification call. In case of any other questions or concerns, please contact me. Thanks Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 1

Hearing Identifier: NRR_PMDA Email Number: 1250 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20140311154300)

Subject:

Request for Additional Information - Palisades - NFPA 805 Project LAR -

MF0382 Sent Date: 3/11/2014 3:43:59 PM Received Date: 3/11/2014 3:43:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

"Lain, Paul" <Paul.Lain@nrc.gov>

Tracking Status: None "Metzger, Brian" <Brian.Metzger@nrc.gov>

Tracking Status: None "Klein, Alex" <Alex.Klein@nrc.gov>

Tracking Status: None "Robinson, Jay" <Jay.Robinson@nrc.gov>

Tracking Status: None "Wall, Scott" <Scott.Wall@nrc.gov>

Tracking Status: None "Carlson, Robert" <Robert.Carlson@nrc.gov>

Tracking Status: None "Duncan, Eric" <Eric.Duncan@nrc.gov>

Tracking Status: None "Garmoe, Alex" <Alex.Garmoe@nrc.gov>

Tracking Status: None "Scarbeary, April" <April.Scarbeary@nrc.gov>

Tracking Status: None "Shah, Swetha" <Swetha.Shah@nrc.gov>

Tracking Status: None "Smith, Keith E (ksmit21@entergy.com)" <ksmit21@entergy.com>

Tracking Status: None "Amy Hazelhoff (ahazelhoff@enercon.com)" <ahazelhoff@enercon.com>

Tracking Status: None "MIKSA, JAMES P (jmiksa@entergy.com)" <jmiksa@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1518 3/11/2014 3:43:00 PM Palisades AFPB Follow Up RAIs TAC No MF0382.docx 27450 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION VOLUNTARY FIRE PROTECTION RISK INITIATIVE ENTERGY NUCLEAR OPERATIONS, INC.

PALISADES NUCLEAR PLANT DOCKET NO. 50-255 Fire Modeling (FM) Request for Additional Information (RAI) 01.01 In a letter dated December 2, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13336A649), the licensee responded to PRA RAI 01.q and stated that, because sound engineering judgment has been provided regarding this assumption, additional technical justification for not having to consider structural collapse of the compartment as a result of the failure of one structural steel column is not required.

The staff noted that the licensees evidence consisted of statements made by a civil engineer about general building construction and structural engineering principles that were not specific enough for the staff to complete its review. Provide a summary of the actual analysis that was conducted that provides information in sufficient detail regarding your conclusion that consideration of structural collapse of the compartment as a result of the failure of one structural steel column is not required.

FM RAI 07 In the main control room (MCR) abandonment analysis, the licensee assumed that fire spreads to adjacent cabinets in 15 minutes rather than in 10 minutes, as recommended in Appendix S of NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, for the case when cables in the adjacent cabinet are in direct contact with the separating wall.

Provide a technical justification for this assumption.

FM RAI 08 NFPA 805, Section 2.4.3.3, on acceptability states: The PSA approach, methods, and data shall be acceptable to the AHJ. The staff has noted that the licensee has utilized a number of accepted tools and methods in its analyses for transition such as the Consolidated Model of Fire and Smoke Transport (CFAST) and NUREG-1805, Fire Dynamic Tools (FDTs) - Empirical Correlations and Algebraic Models.

a. Identify any fire modeling tools and methods that have been used in the development of the NFPA 805 LAR that are not already documented in the LAR and where their use or application is documented. Examples might include a methodology (empirical correlations and algebraic models) used to convert damage times for targets in Appendix H of NUREG/CR-6850 to percent damage as a function of heat flux and time or Supplements to the Generic Fire Modeling Treatments (GFMTs) - Empirical Correlations and Algebraic Models.
b. For any tool or method identified in a) above, provide the Verification and Validation (V&V) basis if not already explicitly provided in the LAR (for example in LAR Attachment J).

FM RAI 09 Explain how high energy arcing fault (HEAF) initiated fires were addressed in the Hot Gas Layer (HGL) and Multi Compartment Analysis (MCA) and provide a technical justification for the approach that was used to calculate HGL development timing. More specifically, confirm whether the guidance provided in NUREG/CR-6850; page 11-19, fourth bullet regarding the fire growth, and the guidance provided on page M-13, sixth bullet regarding delay to cable tray ignition was followed. Also, considering the energetic nature of the HEAF event, provide a technical justification for the heat release rate (HRR) used in the HGL calculations for electrical cabinet fires following a HEAF.