ML15005A487

NRR E-mail Capture - Palisades Nuclear Plant - NFPA-805 LAR Revised License Condition Necessitates Updated Enclosures 2 and 3 to Original LAR (MF0382)

ML15005A487
Person / Time
Site:	Palisades
Issue date:	12/08/2014
From:	Jennivine Rankin Plant Licensing Branch III
To:	Erickson J Entergy Nuclear Operations
References
TAC MF0382
Download: ML15005A487 (5)

Text

NRR-PMDAPEm Resource From: Rankin, Jennivine Sent: Monday, December 08, 2014 2:12 PM To: ERICKSON, JEFFREY S (JERICKS@entergy.com)

Cc: Robinson, Jay; Wall, Scott

Subject:

Palisades Nuclear Plant - NFPA-805 LAR revised license condition necessitates updated Enclosures 2 and 3 to Original LAR (MF0382)

Attachments: Palisades NFPA 805 LC.DOCX Mr. Erickson, As we discussed on the phone, in your original LAR, Attachments M and N, referenced Enclosures 2 and 3 for the marked up and clean versions of the TS and License Condition changes. Since the license condition language has been revised since the original LAR (as attached), the NRC staff would need that new language submitted (new marked-up and clean license condition pages) on the docket from the licensee in order to complete review and issue the amendment.

Please let me know if you have any questions.

Thanks, Jennie Jennie Rankin, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 1

Hearing Identifier: NRR_PMDA Email Number: 1802 Mail Envelope Properties (Jennivine.Rankin@nrc.gov20141208141100)

Subject:

Palisades Nuclear Plant - NFPA-805 LAR revised license condition necessitates updated Enclosures 2 and 3 to Original LAR (MF0382)

Sent Date: 12/8/2014 2:11:41 PM Received Date: 12/8/2014 2:11:00 PM From: Rankin, Jennivine Created By: Jennivine.Rankin@nrc.gov Recipients:

"Robinson, Jay" <Jay.Robinson@nrc.gov>

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

Tracking Status: None "ERICKSON, JEFFREY S (JERICKS@entergy.com)" <JERICKS@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 725 12/8/2014 2:11:00 PM Palisades NFPA 805 LC.DOCX 26308 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated December 12, 2012, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, and ___________, as approved in the safety evaluation dated ___________. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program

elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard.

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.10); and

• Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated _________, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2, below, risk-informed changes to the licensees fire

protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications Committed, of ENO letter PNP 2014-080 dated August 14, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the second full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Table S-3, Implementation Items, of ENO letter PNP 2014-097 dated November 4, 2014, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval with the exception of Implementation Items 3 and 8 which will be completed once the related modifications are installed and validated in the PRA model.