ML15058A624
| ML15058A624 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/06/2015 |
| From: | Hazelhoff A Entergy Nuclear Operations |
| To: | Jennivine Rankin Plant Licensing Branch III |
| References | |
| TAC MF0382 | |
| Download: ML15058A624 (44) | |
Text
1 NRR-PMDAPEm Resource From:
Hazelhoff, Amy C [ahazelh@entergy.com]
Sent:
Friday, February 06, 2015 2:21 PM To:
Rankin, Jennivine Cc:
GUSTAFSON, OTTO W; MIKSA, JAMES P; Smith, Keith E
Subject:
RE: Request for NFPA-805 license amendment factual accuracy review (TAC No. MF0382)
Attachments:
Palisades NFPA 805 Draft SE Comment Form_2 6 15.pdf Hi Jennie, The Entergy comments on the Palisades NFPA 805 Draft SE are attached.
- Thanks, Amy Amy C. Hazelhoff NFPA 805 Licensing Lead 269-764-2983 269-370-7445 From: Rankin, Jennivine [1]
Sent: Friday, January 23, 2015 4:12 PM To: ERICKSON, JEFFREY S; MIKSA, JAMES P
Subject:
Request for NFPA-805 license amendment factual accuracy review (TAC No. MF0382)
Mr. Miksa and Mr. Erickson, Attached is the Palisades NFPA 805 license amendment including DRAFT technical specification pages, DRAFT license pages, and DRAFT SE for your review for:
- 1. factual accuracy/completeness and,
- 2. sensitive information Im transmitting this to you in accordance with NRCs Office of Nuclear Reactor Regulation Office Instruction COM-203, Revision 2, which states in part:
As another example, a Draft Safety Evaluation (SE) might be provided to a licensee or applicant to obtain agreement that it contains no proprietary information, in accordance with Office Instruction LIC-204. Similarly, draft SEs or selected portions thereof may be provided to a licensee or applicant to obtain agreement that factual information is accurate and complete. If these exchanges result in the discovery of new information needed for decision making, then this additional information must be appropriately submitted and preserved.
The conclusions stated in these draft documents are preliminary, subject to further staff review, until it is finally issued.
During recent NFPA-805 reviews, the NRC staff has found the following guidelines helpful in assisting the staff in timely evaluation and disposition of licensees comments. We ask you to please consider them in your response.
- 1. Please provide the basis for any proposed change, including the date of the reference and the accession number if it is on the docket, and the exact location in the SE where the licensee is proposing a change.
- 2. Please do not provide general comments. Be specific.
- 3. Please review the response/comments for duplicates, clear language, and internal discussions.
2
- 4. Please provide a legible response/comment document, with the comments clearly numbered, SE sections cited, page numbers and paragraphs identified. Please provide the document in a spreadsheet or word table that we can use to document the resolutions.
- 5. Please provide a consolidated response.
If possible, Id appreciate your response by COB February 6, 2015. Please call me 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
Hearing Identifier:
NRR_PMDA Email Number:
1908 Mail Envelope Properties (D5D583CEB8B34049B675A518CA328E3819C41283)
Subject:
RE: Request for NFPA-805 license amendment factual accuracy review (TAC No. MF0382)
Sent Date:
2/6/2015 2:20:40 PM Received Date:
2/6/2015 2:20:49 PM From:
Hazelhoff, Amy C Created By:
ahazelh@entergy.com Recipients:
"GUSTAFSON, OTTO W" <ogustaf@entergy.com>
Tracking Status: None "MIKSA, JAMES P" <jmiksa@entergy.com>
Tracking Status: None "Smith, Keith E" <ksmit21@entergy.com>
Tracking Status: None "Rankin, Jennivine" <Jennivine.Rankin@nrc.gov>
Tracking Status: None Post Office:
JDCXMETSP001.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 2801 2/6/2015 2:20:49 PM Palisades NFPA 805 Draft SE Comment Form_2 6 15.pdf 131825 Options Priority:
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Recipients Received:
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 1 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
1 N/A N/A The last Sentence on the first page of the letter refers to changes to the licenses This should be License Editorial Revise to license 2
T OF C 4.0 Table of contents is missing section 4.0 Fire protection license condition page 143.
Editorial Add Section 4.0 to Table of Contents 3
All Throughout Section 1.2 describes the LAR and all subsequent submittals.
SE is not consistent subsequent to Section 1.2 with regard to referencing the licensees submittal, as supplemented.
Accuracy Suggest either removing all references to as supplemented for consistency.
OR Insert sentence in Section 1.2 to note that any subsequent references to the LAR or Licensee submittal is considered to include any supplemental information submitted.
4 All Throughout Check consistent use of Acronyms/Definitions and Abbreviations.
Clarification/Consistency Examples:
-PCS is defined as Primary Coolant System in the LAR. PCS is used as Primary Control Station in the SE.
-PB-RI vs. the SER using PB/RI
-MSO vs MSOs 5
1 1.1 Last full Insert wording:
for fire prevention and Section 50.48(a)(2) states that the fire protection plan must describe the specific features necessary to
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 2 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
sentence manual suppression activities; Accuracy implement the program described in paragraph (a)(1) including administrative controls and personnel requirements for fire prevention and manual suppression activities; automatic and manual fire detection and suppression systems; and the means to limit fire damage to structures, systems, and components (SSCs) to ensure the capability to safely shut down the plant.
6 4
1.2 Current wording in third paragraph:
established in accordance all provisions of the approved FPP as described Editorial word missing between accordance and all established in accordance with all provisions of the approved FPP as described 7
4 1.2 Current wording in third paragraph:
to an RI/PB FPP Editorial - Grammar to an RI/PB FPP 8
7 2.0 Bullet (2)
Word fire is missing from sentence - Insert fire after Rapidly detecting Editorial (2) Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting fire damage; and 9
7 2.1 FAQ 07-0032 concluded that if the NFPA 805 requirements were met then GDC-3 was Include reference to FAQ 07-0032 in Section 2.1
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 3 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
satisfied.
10 9
2.2 Current wording in second paragraph:
to an RI/PB FPP Basis:
Editorial - Grammar to an RI/PB FPP 11 15 Table 2.3-1 FAQ 07-0039 In FAQ Title and Summary column:
NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1 (Reference 60)
Draft SE page 153 lists NEI 00-01 as reference 80.
Reference 60 is FAQ# 07-0039 which is already listed in the Reference No. Column Clarification NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1 (Reference 60 80) 12 16 2.4.1 Current wording in second paragraph:
The licensee requested that one exemption be transitioned into the NFPA 805 FPP and that five exemptions be rescinded.
Clarification/ Consistency -
PNP has requested that six appendix R exemptions be rescinded. PNP also The licensee requested that the evaluation from one exemptions underlying condition be transitioned into the NFPA 805 FPP licensing basis and that six exemptions be rescinded.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 4 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
requested that an evaluation associated with one of the exemptions be used as a basis for the underlying condition in the new NFPA 805 FPP.
13 16 2.4.1 Current wording in third paragraph:
The NRC staff accepts the licensees determination that one exemption should be transitioned into the NFPA 805 FPP and that five exemptions should be rescinded as listed in LAR Attachment K, Existing Licensing Action Transition, of the LAR, and that no orders need to be superseded or revised to implement NFPA 805 at PNP.
Clarification/Consistency -
PNP has requested that six appendix R exemptions be rescinded. PNP also requested that an evaluation associated with one of the exemptions be used as a basis for the underlying condition in the new NFPA 805 FPP.
The NRC staff accepts the licensees determination that one exemptions underlying condition evaluation should be transitioned into the NFPA 805 FPP licensing basis and that six exemptions should be rescinded as listed in LAR Attachment K, Existing Licensing Action Transition, of the LAR, and that no orders need to be superseded or revised to implement NFPA 805 at PNP.
14 19 2.5 Current wording in second paragraph:
The licensee requested that The licensee requested that six exemptions be rescinded and that the evaluation from one exemptions underlying condition be transitioned
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 5 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
five exemptions be rescinded and that one exemption be rescinded but the engineering evaluation of the underlying condition be transitioned to the new licensing basis under 10 CFR 50.48(a) and 50.48(c) as previously approved (NFPA 805, Section 2.2.7) and compliant with the new regulation.
Clarification/ Consistency -
PNP has requested that six appendix R exemptions be rescinded. PNP also requested that an evaluation associated with one of the exemptions be used as a basis for the underlying condition in the new NFPA 805 FPP.
into the new NFPA 805 FPP licensing basis under 10 CFR 50.48(a) and 50.48(c) as previously approved (NFPA 805, Section 2.2.7) and compliant with the new regulation.
15 20 2.5 Current wording in first paragraph:
The following exemption is rescinded as requested by the LAR, but the engineering evaluation of the underlying condition will be used as a qualitative engineering evaluation for transition to NFPA 805:
Clarification/Consistency -
PNP has requested that six appendix R exemptions be rescinded. PNP also The following exemption is rescinded as requested by the LAR, and the evaluation of the underlying condition will be used as a licensing basis for transition to NFPA 805:
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 6 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
requested that an evaluation associated with one of the exemptions be used as a basis for the underlying condition in the new NFPA 805 FPP.
16 22 2.6.1 First paragraph - typo the licensee the actions should be the licensee has actions Revise to the licensee has actions 17 26 2.7.1 Second paragraph, first sentence The SE states that the modifications in LAR Table S-2 are the same as those identified in LAR Table B-3.
The modifications in Table B-3 are a subset of those in Table S-2. Modifications in Table S-2 include code compliance modifications that are unrelated to variances from the deterministic requirements of 4.2.3 and/or unrelated to fire PRA risk reduction.
Accuracy The NRC staffs review confirmed that the modifications identified in LAR Table S-2 Table B-3 on a fire area basis are the same as those also identified in LAR Table B-3, Fire Area Transition, on a fire area basis, as Table S-2, and are the modifications being credited in the proposed NFPA 805 licensing basis.
18 27 2.7.2 Second paragraph AND 2.7.3 First paragraph, The time from for implementation items in Table S-3 is 6 months from the issuance of the SE, except for items 3 and 8. The exceptions are not mentioned consistently throughout the document. The schedule section should discuss the exceptions.
Clarification 2.7.2:
Each implementation item will be completed prior to the deadline for implementation of the RI/PB FPP based on NFPA 805, as specified in the license condition and the letter transmitting the amended license (i.e., implementation period) which states that the implementation items listed in LAR Attachment S, Table
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 7 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
last sentence S-3, will be completed 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.
2.7.3:
The licensee stated that it will complete the implementation of new NFPA 805 FPP to include procedure changes, process updates, and training to affected plant personnel 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.
19 29 3.1 Typo - the last paragraph of section 3.1 has too many closing PARENTHESES.
Delete extra parentheses 20 31 3.1.1.1 Current wording in Second paragraph:
The licensee further stated that the types of combustible materials are broken down into four categories with The licensee further stated that an ENO procedure defines the types of combustible materials, which are broken down into four categories with general requirements for handling, including maximum amounts of combustibles for
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 8 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
different combustible control procedures, including maximum amounts of combustibles for specific combustible control areas.
ENO FPE RAI 02 response dated 9/30/2013 (ADAMS Accession No. ML13273A469) wording is more accurate /
correct than draft SE wording.
specific combustible control areas.
21 37-38 3.1.1.6 Current wording in Fifth paragraph:
The licensee identified an action to include steps in the fire prevention activities procedure that address wiring above suspended ceilings to make sure they comply with the requirements of NFPA 805.
Clarification/Consistency -
Fire prevention activities is the title of a current PNP procedure that is part of a subset of fire protection implementing procedures. The new steps may not be added to the fire prevention activities procedure but will be contained under the fire protection implementing procedure group. Therefore referencing this group of procedures is more accurate than referencing a specific The licensee identified an action to include steps in the fire protection implementing procedures that address wiring above suspended ceilings to make sure they comply with the requirements of NFPA 805.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 9 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
procedure title.
22 38 3.1.1.6 Current wording in Second paragraph:
The licensee identified an action to revise the fire prevention activities procedure to ensure compliance with this requirement.
Clarification/Consistency -
Fire prevention activities is the title of a current PNP procedure that is part of a subset of fire protection implementing procedures. The new steps may not be added to the fire prevention activities procedure but will be contained under the fire protection implementing procedure group. Therefore referencing this group of procedures is more accurate than referencing a specific procedure title.
The licensee identified an action to revise the fire protection implementing procedures to ensure compliance with this requirement.
23 38 3.1.1.6 Current wording in Fifth paragraph:
The licensee identified an action to update the fire prevention activities procedure to include controls for eliminating the possibility of combustible liquids, including high flashpoint lubricating oils, The licensee identified an action to update the fire protection implementing procedures to include controls for eliminating the possibility of combustible liquids, including high flashpoint lubricating oils, from coming into contact with hot pipes and surfaces, and controls for ensuring the prompt cleanup of oil on insulation.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 10 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
from coming into contact with hot pipes and surfaces, and controls for ensuring the prompt cleanup of oil on insulation.
Clarification/Consistency -
Fire prevention activities is the title of a current PNP procedure that is part of a subset of fire protection implementing procedures. The new steps may not be added to the fire prevention activities procedure but will be contained under the fire protection implementing procedure group. Therefore referencing this group of procedures is more accurate than referencing a specific procedure title.
24 38-39 3.1.1.6 Current wording in Sixth paragraph:
The licensee identified an action to revise fire suppression training procedures to ensure the required written records are maintained and also an action to track the document change to closure.
Clarification/Consistency -
Fire suppression training is the title of a current PNP procedure that is part of a The licensee identified an action to revise fire protection implementing procedures to ensure the required written records are maintained and also an action to track the document change to closure.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 11 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
subset of fire protection implementing procedures. The new steps may not be added to the fire suppression training procedure but will be contained under the fire protection implementing procedure group. Therefore referencing this group of procedures is more accurate than referencing a specific procedure title.
25 39 3.1.1.6 Paragraph discussing Section 3.5.16 refers to Standard Operating Procedures (SOPs).
Palisades uses System Operating Procedures (SOPs).
Revise acronym definition to System Operating Procedures (SOPs) 26 39 3.1.1.6 Paragraph discussing Section 3.7 states by the addition new fire extinguishers. This should read by the addition of new fire extinguishers.
Revise to:
by the addition of new fire extinguishers.
27 39 3.1.1.6 Paragraph discussing Sections 3.8.1 and 3.8.2 should also reference S-3 Item 1 and Item 2 to develop a procedure to periodically clean, test, and inspect for accuracy and completeness.
Include reference to Table S-3, Items 1 and 2 28 40 3.1.1.6 Paragraph discussing Section 3.11.1 begins on page 39.
The first paragraph on page 40 lists several modifications.
It appears that Mod S2-20 should also be listed for completeness.
Include Mod S2-20
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 12 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
29 40 3.1.1.6 Paragraph discussing Section 3.11.3 lists a couple of modifications. It appears that Mods S2-22 AND S2-25 should also be listed for completeness.
Include Mods S2-22 and S2-25 30 41 3.1.1.8 2ND bullet, 1st sub-bullet Draft SE Section 3.1.1.8 states:
The licensee states that it does not have systems of this type installed (e.g., NFPA 805 Section 3.6.5 which applies to seismic designed hose stations that are cross-connected to seismic non-fire protection essential water systems or NFPA 805 Section 3.10 which applies to gaseous fire protection systems).
The examples provided may be misleading. The LAR Attachment A Table B-1 compliance basis for Section 3.10 states There are no automatic total flooding or local application gaseous fire suppression systems required to meet the performance or deterministic requirements of Chapter 4 of NFPA 805 at PNP. It does not state that PNP does not have systems of this type installed.
Clarification The licensee states that it does not have required there are no systems of this type installed required to meet the performance or deterministic requirements (e.g.,
NFPA 805 Section 3.6.5 which applies to seismic designed hose stations that are cross-connected to seismic non-fire protection essential water systems or NFPA 805 Section 3.10 which applies to gaseous fire protection systems).
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 13 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
31 42 3.1.2 Draft SE Section 3.1.2 states:
As stated in the LAR, Section 4.1.3, the power block includes structures that contain equipment that could affect plant operation for power generation; equipment important to safety; equipment that could affect the ability to maintain NSCA in the event of a fire; or structures containing radioactive materials that could potentially be released in the event of a fire.
This wording is not consistent with the wording contained in LAR Section 4.1.3.
As stated in the LAR, Section 4.1.3, the power block includes structures that contain equipment that could affect plant operation for power generation; equipment important to safety; equipment that could affect the ability to maintain NSCA in the event of a fire; or structures containing radioactive materials that could potentially be released in the event of a fire. any area that contains equipment or cables that are necessary to achieve safe and stable condition is considered a Power Block area.
Safe and stable condition applies to all modes of operation, including Non-Power Operational modes (NPO). Areas with equipment or cables that are required for nuclear plant operations that do not support safe and stable were excluded from the PNP Power Block.
32 43 3.1.4.1 Statement is made in the third paragraph on the page, The licensee stated that there will be no impact on the NFPA 805 NSCA Attachment L states that there will be no adverse impact on the Nuclear Safety Performance Criteria (NSPC).
Clarification The licensee stated that there will be no impact on the NFPA 805 NSCA NSPC.
33 43 3.1.4.1 Second to last paragraph on Pg.43 should read no Add word adverse
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 14 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
adverse impact rather than No impact 34 47 3.1.4.3 The last paragraph states that DID by implementing site procedures The LAR referred to ENO procedure EN-DC-127 which is not a site procedure.
Revise to DID by implementing ENO procedures 35 47 3.1.4.3 2ND full paragraph, last sentence Tot work should be Hot work Editorial The licensee further stated that the radiological release review was performed based in part on manual fire suppression activities and is not dependent on hot work activities, that hot work is controlled and does not add additional radiological materials to the area or challenge system boundaries, and that thot work activities do not change the radiological release evaluation.
36 48 3.1.4.4 Second Paragraph typo -
missing comma after title Life Safety Code, Add comma 37 48 3.1.4.4 Third paragraph Information Notice 2007-26 be added to the list of references for completeness Add IN 2007-26 to reference list 38 51 3.1.4.5 Second paragraph - no mention of Fire Area 27 which was included in the LAR.
Accuracy Add Fire Area 27 39 52 3.1.4.5 First bullet on page refers to PNP procedures. The LAR referred to ENO procedure EN-DC-161 and ADMIN 1.01.
EN-DC-161 is the primary procedure and is not a site Revise PNP Procedures to ENO Procedures
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 15 of 41 Comment No:
SE Page No:
SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
procedure.
40 52 3.1.4.5 Eighth Bullet Draft SE Section 3.1.4.5 includes a bullet that states:
The cable was specified to meet the vertical flame tests in accordance with Insulated Power Cable Engineers Association Standard S 81.
This wording by itself is incomplete. It is partial wording from a 1978 SER that accepted IPCEA S-19-81 in lieu of IEEE 383 since it did not exist at the time Palisades was built. Cables since original construction were not necessarily specified to meet S-19-81. Other requirements exist relative to electric cable construction. The suggested revision is wording directly from LAR Attachment L Request 5 and is intended to help put the S-19-81 requirement into perspective.
Although IEEE 383 was not in existence at the time the Palisades electrical cabling was purchased and installed, Tthe cable was specified to meet the vertical flame tests in accordance with Insulated Power Cable Engineers Association Standard S-19-81.
41 53 3.1.4.6 4TH paragraph, last sentence Probalistic should be Probabilistic Editorial The licensee concluded that the use of embedded or underground plastic conduit and the use of EMT do not impact NSPC. The licensee further stated that exposed plastic conduit is used in cooling tower related applications and that the cooling tower functions are not relied upon to satisfy NSPC or fire
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 16 of 41 Comment No:
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SE Section No:
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NRC Disposition:
probalistic probabilistic risk assessment (FPRA).
42 54 3.1.4.6 First paragraph discusses Echelon 2 and states to have portable fire extinguishers and hose reel stations Delete, to for accuracy to the LAR.
The licensee stated for echelon 2 that areas where exposed plastic conduit exist, to have portable fire extinguishers and hose reel stations that are available for manual firefighting activities by the site fire brigade, to assure that if a fire was to occur that the damage from the fire would be limited.
43 55 3.1.4.7 2ND full bullet, last sentence To take out should be Would take out Editorial It is unlikely that an event involving hydrogen bulk storage to would take out the F and G buses and take out Diesel Generator 1-3.
44 56 3.1.4.8 Section 3.1.4.8 refers to NFPA 20 in multiple locations but does not include (Reference 54).
Consistency Consider including Reference 54 for each use of NFPA 20 45 57 3.1.4.9 Third paragraph runs on with multiple ands being used.
Editorial Suggest a period after started from the control room. and start a second sentence with The licensee also stated if the pump started automatically...
46 57 3.1.4.9 Second Paragraph Draft SE Section 3.1.4.9 states:
In LAR Attachment L, Approval Request 9, the licensee stated that the diesel fire pumps are provided with an automatic start feature and a manual stop at the fire pumps. The licensee further In LAR Attachment L, Approval Request 9, the licensee stated that the diesel fire pumps are provided with an automatic start feature and a manual stop at the fire pumps.
The licensee further stated that in the Control Room the diesel pumps can be manually stopped if the pumps have been manually started in the Control Room and there is no
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 17 of 41 Comment No:
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SE Section No:
Comment:
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NRC Disposition:
stated that in the Control Room the diesel pumps can be manually stopped if the pumps have been manually started in the Control Room and that this configuration is not in compliance with NFPA 805 Section 3.5.6.
Add clarification that even if the diesel fire pump was started from the control room, the pump could not be stopped from the control room if the low pressure auto start signal actuated as noted in LAR Attachment L.
auto start for low pressure signal.
The licensee stated that this configuration is not in compliance with NFPA 805 Section 3.5.6.
47 59 3.1.4.10 Third Bullet Draft SE Section 3.1.4.10 states:
There is sufficient margin in the PNP fire water system above the required fire suppression demands. The largest design demand of any sprinkler or fixed water spray system in the power block is the deluge system for Start-up Transformers, including the 500 gpm for hose streams.
The draft SE abbreviated the wording from LAR Attachment L and now appears out of context. The missing wording contained the analysis flow rate for the deluge system which included the 500 gpm There is sufficient margin in the PNP fire water system above the required fire suppression demands.
The largest design demand of any sprinkler or fixed water spray system in the power block is the deluge system for Start-up Transformers,. Analyzed required system flow includeding the 500 gpm for hose streams.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 18 of 41 Comment No:
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NRC Disposition:
for hose streams.
48 61 3.1.4.11 First paragraph - the requirement stated is for NFPA section 3.4.11, not 3.11.4(b) as the SE reflects.
The requirement for 3.4.11(b) should be stated as shown in LAR Att.L or NFPA 805.
Accuracy Add NFPA 805 Code words from 3.4.11b, not from 3.4.11.
49 61 3.1.4.11 Second and Fourth paragraph
- the request should clearly state that the proposed alternative conduit fire and smoke sealing is based on the Professional Loss Control Report, Conduit Fire Protection Research Program, dated June 1, 1987, and reference the report. The wording currently mentions a detailed fire test and report which is not identified. The section later mentions the June 1, 1987 date, but the report is not identified.
Include reference to report for completeness.
Include the specific Professional Loss Control Report, Conduit Fire Protection Research Program, dated June 1, 1987, and reference the report.
50 62 3.1.4.11 Third bullet - include S2-35 &
S2-36 for mods and include S-3 item 1 for completeness.
Include Mods S2-35 & S2-36 for and include S-3 item 1 51 62 3.1.4.11 Third paragraph after bullets -
the last sentence should begin as the licensee has stated that for echelon 3, criteria being Revise last sentence to include:
The licensee has stated that for Echelon 3, criteria being
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 19 of 41 Comment No:
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SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
52 63 3.2 First paragraph - risk-informed (RI)/PB should be spelled out as risk-informed performance-based (RI/PB)
Revise risk-informed (RI)/PB to risk-informed performance-based (RI/PB) 53 65 3.2.1 First full sentence Word Worksheet is missing from title Editorial This NRC-endorsed guidance (i.e.,
NEI 04-02 Table B-2, NFPA 805 Chapter 2 - Nuclear Safety Transition - Methodology Review Worksheet and NEI 00-01, Chapter
- 3) has been determined to address the related requirements of NFPA 805, Section 2.4.2.
54 66 3.2.1 Draft SE Section 3.2.1 states:
The review of LAR Attachment G, Table G-1 Recovery Actions Required to Resolve VFDRs to Meet Risk Criteria indicates that there are three required RAs on rising stem motor-operated valves taken within the fire area of concern. The licensee determined that the valves would not be susceptible to direct fire effects and would remain operable post-fire.
The draft SE abbreviated the wording from LAR Section 4.2.1.1 which could be misleading. A review of LAR Attachment G Table G-1 does not clearly identify three required RAs on rising stem motor-operated valves. LAR Section 4.2.1.1 also referred to a PNP report that was The review of licensee documentation and LAR Attachment G, Table G-1 Recovery Actions Required to Resolve VFDRs to Meet Risk Criteria indicates that there are three required RAs on rising stem motor-operated valves taken within the fire area of concern. The licensee determined that the valves would not be susceptible to direct fire effects and would remain operable post-fire.
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 20 of 41 Comment No:
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Comment:
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NRC Disposition:
reviewed in addition to Table G-1.
55 66 3.2.1 Fourth bullet - this bullet should be removed as it is the review disposition for the third bullet.
Remove actual bullet - text describes bulleted information above 56 71 3.2.1.7 Insert the word methodology in the second sentence
...comparing the SSA against the NSCA methodology requirements...
Clarification The licensee performed this evaluation by comparing the SSA against the NSCA methodology requirements using NEI 00-01, Revision 1 with a gap analysis to the NRC-endorsed process in Chapter 3 of NEI 00-01 Revision 2.
57 71 3.2.2 Draft SE Section 3.2.2 states:
In LAR Attachment C, Table B-3, the licensee identified its ability to achieve and maintain NFPA 805 safe and stable conditions following shutdown from full power conditions and that safe and stable conditions can be maintained long term with forced or natural circulation via the Shutdown Cooling System (i.e., steam generators).
The NSCA analysis was performed using hot shutdown as the safe and stable condition which relies on the steam generators to remove decay heat, not the shutdown cooling system. As discussed in LAR Section 4.2.1.2.
In LAR Attachment C, Table B-3, the licensee identified its ability to achieve and maintain NFPA 805 safe and stable conditions following shutdown from full power conditions and that safe and stable conditions can be maintained long term with forced or natural circulation via the Shutdown Cooling System (i.e.,
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58 72 3.2.3 Reference is made to Table C-1, however a search of the Palisades LAR for Table C-1 did not reveal any hits.
Recommend removing Table C-1.
Delete reference to Table C-1 59 75 3.2.5 The draft SE identifies four steps used to determine RAs.
The LAR Att.G identifies five steps. The missing step is Evaluate the reliability of the recovery actions.
Add step:
Evaluate the reliability of the recovery actions.
60 76 3.2.5 Third paragraph - to be consistent the last two sentences should be combined and read:
The licensee stated that these actions are taken to demonstrate the availability of a success path for the NSPC in the fire area, the resulting delta risk of the VFDR is not significant, and these actions are only required based on DID considerations.
Revise to:
The licensee stated that these actions are taken to demonstrate the availability of a success path for the NSPC in the fire area, the resulting delta risk of the VFDR is not significant, and these actions are only required based on DID considerations.
61 78 3.2.7 Third paragraph - VEWFDS is noted to monitor conditions in certain key electrical cabinets.
This is not accurate as the VEWFDS is being installed as area wide detection in a number of key fire areas.
Revise to The NRC staff reviewed the proposed installation of a VEWFDS to monitor conditions in certain key electrical cabinets fire areas.
62 78 3.2.7 Fourth paragraph typo - the last sentence refers to LAR which should be LAR Attachment S.
Revise to LAR Attachment S
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63 79 3.3 Last paragraph Last sentence can be read that there are no acceptable FM methods for supporting NFPA 805, 4.2.4.1, whereas the intent appears to be to state that acceptable FM methods under NFPA 4.2.4.1 were not used.
Clarification There are no plant-specific FM methods acceptable for use to support compliance with NFPA 805, Section 4.2.4.1, as part of this LAR supporting the transition to NFPA 805 at PNP.
64 80 3.4.1.2 Should read that NFPA 805, section 2.4.3, states, in part, that Revise to:
NFPA 805, Section 2.4.3, states, in part, that 65 81 3.4.1.2 Current wording in third paragraph:
In a letter dated September 30, 2013 (Reference 10), the licensee responded to SSA RAI 04 and further described the methodology used to evaluate safety margins in the FREs to include the following evaluations and determinations:
Correct References The PRA logic model review against RA-Sa-2009 was documented in PRA RAI Response part d) which was included in reference 12 PNP letter dated 12/02/2013, ADAMS accession No.
ML1336A649 In a letters dated September 30, 2013 (Reference 10) and December 2, 2013 (Reference 12), the licensee responded to SSA RAI 04 and PRA RAI 01 respectively and further described the methodology used to evaluate safety margins in the FREs to include the following evaluations and determinations:
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66 81 3.4.1.2 Draft SE Section 3.4.1.2 states:
LAR Section 4.5.1.2 states that the FPRA, including fire modeling performed to support the FPRA, applies methodologies consistent with the guidance in NUREG/CR-6850 (Reference 40),
(Reference 41), and (Reference 42), and, according to LAR Attachment H, NRC approved FAQs. LAR Attachment J explains that fire modeling, including verification and validation (V&V),
performed in support of the FPRA utilized accepted codes and standards including NUREG/CR-6850, NUREG-1805 (Reference 46),
NUREG-1824 (Reference 47),
etc. In a letter dated September 30, 2013 (Reference 10), the licensee responded to SSA RAI 04 and further described the methodology used to evaluate safety margins in the FREs to include the following evaluations and determinations:
There are three bullets following this paragraph which appear to come from the response to SSA RAI 04. The Recommend deleting the third bullet which states:
PRA: The PRA logic model was reviewed against the ASME/ANS RA-Sa-2009 PRA standard (Reference 34), and RG 1.200, Rev.
2 (Reference 33).
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third bullet states:
PRA: The PRA logic model was reviewed against the ASME/ANS RA-Sa-2009 PRA standard (Reference 34), and RG 1.200, Rev. 2 (Reference 33).
The third bullet is not associated with SSA RAI 04.
67 82 3.4.2.1 Third paragraph, first sentence Appears the number of F&O Findings and F&O Suggestions were mixed up.
Correct number of F&O findings is 52 and the correct number of F&O suggestions is
- 26.
Accuracy LAR Attachment U, Table U-1 provides the licensees dispositions to all 78 facts and observations (F&Os) related to the IEPRA, which include 26 52 F&Os characterized as findings and 52 26 F&Os characterized as suggestions per peer review guidelines.
68 83 3.4.2.1 2ND & 3RD paragraphs Capability Categories (CC) -
use CC-in front of all capability category numbers in the text.
Editorial For many supporting requirements (SRs), there are three degrees of satisfaction referred to as Capability Categories (CC) (i.e.,
CC-I, CC-II, and CC-III), with CC-I being the minimum, CC-II considered widely acceptable, and CC-III indicating the maximum achievable scope/level of detail, plant specificity, and realism. For other SRs, the CCs may be combined (e.g., the requirement for meeting CC-I may be combined with CC-II), or the requirement may be the same across all CCs so that the requirement is simply met or not met. For each SR, the PRA
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reviewer from the peer review team designates one of the CCs or indicates that the SR is met or not met.
In general, an F&O is written for any SR that is judged not to be met or does not fully satisfy CC-II of the ASME standard, consistent with RG 1.200, Revision 2.
69 85 3.4.2.2 Eighth paragraph, third sentence (PRA RAI 01.h.02)
The SE states the minimum floor value for joint HEPs was incorporated into the integrated analysis and that the supplement to LAR Attachment W provided in RAI response of 08/14/2014 reflects this change in the baseline FPRA to be used for self-approval.
The floor value was incorporated into the process for joint HEPs and was not incorporated into the Attachment W results in the RAI response of 08/14/2014.
The impact of implementing the floor value results was assessed and determined to be negligible, as stated in the 08/14/2014 RAI response for PRA RAI 01h.02.
The floor value will be reflected in the baseline FPRA Furthermore, in its response to PRA RAI 30 (Reference 16), the licensee assessed the impact of incorporating this floor value to be negligible incorporated this floor value into the integrated analysis and provided a supplement to LAR Attachment W per Table S-3, Implementation Item 3 is reflecting this change in the baseline FPRA to be used for self-approval. The NRC staff finds this issue to be resolved because the transition change-in-risk estimates, submitted by the licensee on August 14, 2014 (Reference 16), and updated on November 4, 2014 (Reference 17),
make are consistent with the use of a floor value consistent with per the NUREG-1921 guidance.
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to be used for self-approval, per Table S-3, Implementation Item 3.
Accuracy 70 88 3.4.2.2 1st full paragraph 3rd Sentence Clarify wording Editorial During the assessment, the licensee identified specific plant locations where a higher transient combustible base taller (up to 30 inches) transient combustibles exists.
71 92 3.4.2.2 Current wording in Second paragraph:
The licensee stated that the plant-specific element is modelled using general PRA methods and that the generic element is modeled consistent with the WCAP-16175-P (Reference 93), consensus model endorsed by the NRC.
Correct Reference NRC endorsed WCAP-16175-P-A versus WCAP-16175-P as stated in PRA RAI 01.e.01 ENO response from ENO letter dated 6/17/2014 ADAMS Accession No. ML14169A046 The licensee stated that the plant-specific element is modelled using general PRA methods and that the generic element is modeled consistent with the WCAP-16175-P-A (Reference 93), consensus model endorsed by the NRC.
72 94 3.4.2.3.1 First bullet list The primary algebraic radiation model is the method of Shokri and Beyler, which is also one of the models addressed in NUREG 1824 V&V. Modaks Point Source Please revise the first bullet list as follows:
Modaks Point Source Radiation Model.
Shokri and Beyler Solid Flame
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Radiation Model was used as a check against the Shokri and Beyler Solid Flame Radiation Model.
Clarification Radiation Model.
Please add the following sentence after the revised last bullet:
In addition, Mudaks Point Source radiation model was used to provide a bounding check on the Shokri and Beyler Solid Flame model.
73 95 3.4.2.3.1 Second bullet list The Method of Shokri and Beyler belongs in the previous bullet list. This model is also one of the models addressed in NUREG 1824 V&V.
Clarification Delete Method of Shokri and Beyler from the bullet list:
Shokri and Beyler flame radiation model (Reference 95) 74 96 3.4.2.3.2 First bullet, second paragraph Consider clarification that the 4 percent increase in probability of abandonment is not considered significant in the MCR abandonment calculation.
Clarification Revise the second sentence as follows:
The licensee stated that a sensitivity analysis shows that decreasing the time when the door is opened from 15 to 10 minutes reduces the probability for abandonment by up to 27 percent in all but one scenario for which the probability increases by 4 percent, which is not considered significant in the MCR abandonment calculation.
75 96 3.4.2.3.2 Current wording in first paragraph, first bullet, second paragraph:
In its response to FM RAI 01.a (Reference 12), the licensee stated that a review of reports of fire brigade drills conducted In its response to FM RAI 01.a (Reference 12), the licensee stated that a review of reports of fire brigade drills conducted between January 25, 2012, and December 4, 2012, documents that the fire brigade response time for fires near the MCR are between 6 and 10
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between January 25, 2012, and December 4, 2012, indicates that the fire brigade response time for fires in the MCR is expected to be between 6 and 10 minutes.
Clarification Table FM01a-1 lists fire brigade arrival times at various PNP Areas versus the main control room. Since many of the listed areas are near the MCR the time to respond to a MCR fire was conservatively bounded by the largest listed time of 10 minutes which supports an assumed 15 minute response time with margin. Reference FM RAI 01.a ENO response letter dated 12/2/2013 ADAMS Accession No. ML13336A649 minutes which indicates the ability to respond to a MCR fire within 15 minutes.
76 99 3.4.2.3.2 First Bullet on Page, second paragraph, last sentence The GFMT tables are replaced only when there are secondary combustibles (cable trays) ignited in the ZOI per FM RAI 01.g.
Clarification Revise the last sentence as follows:
The licensee stated that the new ZOI and HGL tables replace those provided in the GFMTs approach when secondary combustibles are ignited in the ZOI.
77 101 3.4.2.3.2 Current wording in third paragraph:
In its response to FM RIA 01.k (Reference 12), the licensee explained that document reviews and walkdowns were In its response to FM RAI 01.k (Reference 12), the licensee explained that document reviews in combination with walkdowns were performed to identify fire areas where the involvement of non-cable secondary combustibles could
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performed to identify fire areas where the involvement of non-cable secondary combustibles could result in additional target damage.
Clarification / Editorial FM RIA should be FM RAI.
RAI response stated that a combination of document reviews and walkdowns were used to cover all fire areas versus a document review and walkdown for each fire area.
response in letter dated 12/02/2013 ADAMS Accession Number ML13336A649 result in additional target damage.
78 102 3.4.2.3.2 Current wording in third paragraph:
The licensee provided an annotated list of the six fire areas where the damage accrual method was applied.
Clarification / Reference The six fire areas are listed in FM RAI 02.b versus FM RAI 01.p. This reference should be added.
The licensee provided an annotated list of the six fire areas where the damage accrual method was applied in response to FM RAI 02.b (Reference 12).
79 103 3.4.2.3.2 Current wording in first paragraph:
Since this assumption is non-conservative, the last step of the method was revised to address the
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Since this assumption is non-conservative, the last step of the method was revised in an attempt to address the non-conservatism.
Editorial Remove in an attempt since the action referenced was taken versus attempted to be taken.
non-conservatism.
80 107 3.4.3 Current wording in Fifth paragraph:
The NRC staff concludes that the licensees methods for calculating the change in risk associated with VFDRs are acceptable because they are consistent with RG 1.205, Section 2.2.4.1, and FAQ 08-0054 Reference to FAQ 08-0054 is incorrect it should be FAQ 07-0054 as listed in ENO LAR submittal section 4.2.2 (page
- 26) Dated 12/12/2012 ADAMs Accession Number ML12348A455 The NRC staff concludes that the licensees methods for calculating the change in risk associated with VFDRs are acceptable because they are consistent with RG 1.205, Section 2.2.4.1, and FAQ 07-0054.
81 108 3.4.4 First paragraph - typo, PSC should be PCS.
Revise PSC to PCS 82 108 3.4.4 Fourth paragraph, last three sentences The draft SE sentence, According to the updated LAR Attachment W, Table W-2 (Reference 16), the licensee reported a total additional risk of RAs of 1.4E-06/year for According to the updated LAR Attachment W, Table W-2 (Reference 16), the licensee reported a total additional risk of RAs of 1.4E-06/year for CDF and 6.8E-08/year for LERF. In its
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CDF and 6.8E-08/year for LERF. Is accurate the values provided for CDF and LERF were updated as a result of the 11/4/2014 RAI response which updated the model but did not provide an updated Table W-2. because it was not requested.
The 11/4/2014 RAI response model update updated Table W-2 shows a total additional risk of RAs of 1.4E-06/year for CDF and 4.2E-07/year for LERF.
These results are less than the acceptance guidelines for Region II for both CDF and LERF (i.e., versus the stated less than Region III for LERF).
Clarification response to PRA RAI 30.c.01 (Reference 17), the licensee confirmed that RAs identified in the letter dated August 14, 2014 (Reference 16), were included in the updated model and meet RG 1.174 Region II guidelines for CDF and LERF respectively. se updated results. The NRC staff finds these results acceptable because they are less than the acceptance guidelines for Region II of RG 1.174.
83 109 3.4.6 Current wording in Fifth paragraph:
These calculations are consistent with the guidance in FAQ 08-0054 Reference to FAQ 08-0054 is incorrect it should be FAQ 07-0054 as listed in ENO LAR submittal section 4.2.2 (page
- 26) Dated 12/12/2012 ADAMs Accession Number These calculations are consistent with the guidance in FAQ 07-0054
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ML12348A455 84 109 3.4.6 Fourth paragraph, fourth sentence The SE discussion states three fire areas have a net positive risk increase, and that the largest fire area risk increase is 2.2E-7/year and 6.9E-10/year for CDF and LERF, respectively.
There are 5 fire areas with either a net positive CDF or LERF or both: FA-01, FA-05, FA-09, FA-21 and FA-34. The largest net positive CDF is 2.2E-07 (FA-21); the largest net positive LERF is 4.2E-7 (FA-01).
Accuracy Similar change-in-risk values are estimated for some individual fire areas but only three five of the 40 areas has have a net positive risk increase in either CDF or LERF or both. The largest fire area risk increases is are 2.2E-07/year and 6.9E-10/year 4.2E-07/year for CDF and LERF, respectively, and is well are below the RG 1.174 acceptance guidelines.
85 115 Table 3.5-1 Fire Area 9 should be Intake Structure. Delete reference to the screen house.
Accuracy Screen House (Intake Structure) 86 116 3.5.1.3 First paragraph of section states the licensee identified one exemption from Appendix R, for each fire area that was previously approved by the NRC and will be transitioned Only one exemption applicable to one fire area is being carried forward.
the licensee identified one exemption from Appendix R, for each fire area that was previously approved by the NRC and will be transitioned 87 118 3.5.1.4 Current wording in Second In LAR Section 4.2.2, the licensee
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In LAR Section 4.2.2, the licensee stated that the guidance in RG 1.205, Regulatory Position 2.3.2, and FAQ 08-0054 (Reference 63),
was followed.
Reference to FAQ 08-0054 is incorrect it should be FAQ 07-0054 as listed in ENO LAR submittal section 4.2.2 (page
- 26) Dated 12/12/2012 ADAMs Accession Number ML12348A455 stated that the guidance in RG 1.205, Regulatory Position 2.3.2, and FAQ 07-0054 (Reference 63),
was followed.
88 119 3.5.1.4 Current wording in Fifth paragraph:
Based on the NRC staffs review of the licensees methodology for review of EEEEs and identification of the applicable EEEEs in LAR Attachment C, the NRC staff concludes that the use of EEEEs meets the requirements of NFPA 805, the guidance of RG 1.205, and FAQ 08-0054.
Reference to FAQ 08-0054 is incorrect it should be FAQ 07-0054 as listed in ENO LAR submittal section 4.2.2 (page
- 26) Dated 12/12/2012 ADAMs Accession Number ML12348A455 Based on the NRC staffs review of the licensees methodology for review of EEEEs and identification of the applicable EEEEs in LAR Attachment C, the NRC staff concludes that the use of EEEEs meets the requirements of NFPA 805, the guidance of RG 1.205, and FAQ 07-0054.
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89 123 3.5.3.3 Section 3.5.3.3 refers to LAR Section 4.3.1 which should be 4.3.2.
Revise to LAR Section 4.3.2 90 124 3.5.3.3 Current wording in Second paragraph:
Furthermore, the NRC staff concludes that the licensee has a process in place to ensure that fire protection DID measures will be implemented to achieve the KSFs during plant and that any required action will be completed through an implementation item identified in LAR Attachment S, which is required by the proposed license condition.
Editorial Missing words / grammer Furthermore, the NRC staff concludes that the licensee has a process in place to ensure that fire protection DID measures will be implemented to achieve the KSFs during applicable plant modes and that any required action will be completed through an implementation item identified in LAR Attachment S, which is required by the proposed license condition.
91 124 3.5.3.3 Second paragraph contains an incomplete statement -
will be implemented to achieve the KSFs during plant and that Revise sentence for completeness:
Furthermore, the NRC staff concludes that the licensee has a process in place to ensure that fire protection DID measures will be implemented to achieve the KSFs during Revise sentence for completeness
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plant and that any required action will be completed through an implementation item identified in LAR Attachment S, which is required by the proposed license condition.
92 127 3.6 Items (1) and (2) appear to come from NFPA 805, Section 1.4.2, but do not include the complete wording. Include additional wording for completeness.
Include complete wording for Radioactive Release Objectives 93 127 3.6 Second to last paragraph states that the licensees buildings and structures provide sufficient capacity to contain the liquid and gaseous firefighting effluents such that there are no offsite releases.
Subsequent discussion mentions offsite release.
Include text, No offsite releases in excess of 10CFR20 limits 94 132 3.8.2 Third paragraph refers to Table S-2 and Implementation Item S2-7. This is in error since Table S-2 identifies mods to be completed.
Revise to:
LAR Attachment S, Table S-23 includes Implementation Item S23-7 to update configuration control procedures to reflect the new NFPA 805 licensing bases requirements.
95 133 3.8.3.2.1 Fifth paragraph, first sentence Reference range should be 95
- 106.
Editorial Revise reference range as follows:
(References 94 - 105 95 - 106) 96 133 3.8.3.2.1 Fifth Table 3.8-2 also applies.
Clarification Please add Table 3.8-2 to the sentence:
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paragraph, last sentence SE Table 3.8-1 in SE Attachment A and Table 3.8-2 in SE Attachment B summarizes the additional fire models, and the NRC staffs evaluation of the acceptability of each.
97 134 3.8.3.2.1 First paragraph, first sentence Clarify wording Editorial The FM employed by the licensee in the development of the FRE used empirical correlations that provide bounding solutions for the ZOI and used conservative input parameters that which, produced conservative results for the FM analysis.
98 136 3.8.3.2.4 Second paragraph Should include other peer reviewed documents, to match the appendix Table 3.8-1 in Attachment A.
Clarification Consider revising sentence as follows:
The NRC staff concludes that the licensees FM approach used in the development of the fire scenarios for the FPRA is appropriate and thus acceptable for use in transition to NFPA 805 because the V&V of the empirical correlations used by the licensee were consistent with approved uses in either NUREG-1824, or the Society of Fire Protection Engineers (SFPE)
Handbook of Fire Protection Engineering, or other acceptable peer reviewed documents.
99 137 3.8.3.3.2 Current wording in first bullet, second paragraph The licensee identified and explained five basic limitations that should be considered when applying the original GFMT ZOIs that represent The licensee identified and explained six basic limitations that should be considered when applying the original GFMT ZOIs that represent conditions or configurations for which the GFMT ZOI data may potentially be non-conservative if applied outside the
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conditions or configurations for which the GFMT ZOI data may potentially be non-conservative if applied outside the particular limitation.
Editorial RAI response listed six limitations versus five Reference FM RAI 04.a ENO response dated 12/02/2013 ADAMS Accession Number ML13336A649 particular limitation.
100 137 3.8.3.3.2 Bullet, 2nd paragraph Insert may Editorial The licensee also identified the CFAST limitations that apply to the HGL and MCR abandonment calculations, and explained that the FPRA was updated to account for uses of CFAST outside its range of applicability that may lead to non-conservative results.
102 141 3.8.3.5.2 First bullet, second paragraph, last sentence Appears some wording from RAI Response RAI 06b was used in SE write for PRA RAI 06a:
The characterization of the MCR abandonment sensitivity analysis is not quite how it was performed and implemented. First, there are 6 transient cases that exceed 15% increase in total probability of control room abandonment out of a total of
- 58. This is about 10.3%, rather than 16.75%. Second, Suggest replacing last sentence with the following:
For the MCR abandonment analysis, the licensees sensitivity assessment was used to limit the increase in the probability of abandonment to fifteen percent or less for credible model input parameter variations. Cases in which the sensitivity is shown to be greater than fifteen percent were used to establish model application limits or a basis that the parameter variation was not applicable was provided. partly based on the fact
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Second, of the 6 cases that showed sensitivity greater than fifteen percent, 3 are eliminated by specific limitations on the results (ambient temperature limitation). The remaining three that exceed the limit is obtained from a model input that does not apply to the fuel packages modeled. The way the sensitivity analysis is conducted is to iteratively limit the uncertainty to fifteen percent or place an application limit on the results so that the variation is less than fifteen percent.
A suggested way to describe this may be to state that the MCR abandonment uncertainty assessment is used to limit the increase in the probability of abandonment to fifteen percent or less for credible parameter variations.
Accuracy that less than 16.75 percent of the transient fire scenarios, and almost no panel fire scenarios in the sensitivity analysis resulted in a relative increase of the probability for abandonment over the baseline exceeding 15 percent.
103 148 9.0 Current wording in reference 11 License no. DPR-20 Editorial / Grammer Number abbreviation should be a capital letter.
License No. DPR-20
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104 149 9.0 Current wording in reference 17 (ADAMS Package Accession No. ML14308A228)
Reference ADAMS Accession No. listed is for the ENO cover letter and ML14308A247 is for the attachment. A package number is not available in ADAMS List both ADAMS accession numbers or the correct package number.
105 152 9.0 Current wording in Fifth paragraph:
63 Klein, Alexander R., U.S.
Nuclear Regulatory Commission, memorandum to file, Close-out of National Fire Protection Association Frequently Asked 08-0054 on Demonstrating Compliance with Chapter 4 of National Fire Protection Association 805, dated February 17,2011 (ADAMS Accession No. ML110140183).
Reference to FAQ 08-0054 is incorrect it should be FAQ 07-63 Klein, Alexander R., U.S.
Nuclear Regulatory Commission, memorandum to file, Close-out of National Fire Protection Association Frequently Asked 07-0054 on Demonstrating Compliance with Chapter 4 of National Fire Protection Association 805, dated February 17,2011 (ADAMS Accession No. ML110140183).
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0054 as listed in ENO LAR submittal section 4.2.2 (page
- 26) Dated 12/12/2012 ADAMs Accession Number ML12348A455 106 154 9.0 Current wording in Reference 93:
Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG)
Topical Report WCAP-16175-P Clarification/Correct reference Match RAI response PRA RAI 01.e.02 ENO letter dated 6/17/2014 ADAMS Accession No. ML14169A046. SE for endorsement of WCAP-16175-P gave PWROG owners group specific direction to create a WCAP-16175-P-A document which included the approved SE for specific applications like PNPs.
WCAP-16175-P-A (Formerly CE NPSD 1199 P, Revision 1), Model for Failure of RCP Seals Given Loss of Seal Cooling in CE NSSS Plants, March 2007.
107 155 REF.
109 The listed names In Ref. 109 are incorrect. Should be G.Zucal, J.Voskuil, D.Vanover, and S.Hunt Revise Ref 109 names to:
G.Zucal, J.Voskuil, D.Vanover, and S.Hunt 108 156 ATT.B The Attachment B title listed is not consistent with the title on the actual Attachment.
Revise Title to match 109 A4 ATT.A The last row/last column typo
- PNP application Revise to:
Entergy Comments on Palisades DRAFT NFPA 805 Safety Evaluation Page 41 of 41 Comment No:
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SE Section No:
Comment:
Suggested Revision:
NRC Disposition:
acceptable. Should read PNP application is acceptable.
PNP application is acceptable.
110 N/A ATT.B Attachment B is missing the B1 thru B2 page numbers.
Add Page Numbers B1 and B2 111 N/A ATT.B The last column typos -
PNP application acceptable. Should read PNP application is acceptable. Three of four rows are missing the is.
Revise to:
PNP application is acceptable.
In all appropriate locations.
112 N/A ATT.C Attachment C is missing the C1 thru C3 page numbers.
Add Page Numbers C1 thru C3 113 N/A ATT.C Abbreviations and acronyms include NPO and PCS with multiple definitions.
Consider alternate to duplicate acronyms to avoid confusion 114 N/A ATT.C VEWFDS is defined as Very Early Warning Fire Detectors and should be Very Early Warning Fire Detection System Revise to: