ML16344A088
| ML16344A088 | |
| Person / Time | |
|---|---|
| Site: | Palisades  (DPR-020) |
| Issue date: | 12/07/2016 |
| From: | Entergy Nuclear Operations |
| To: | Jennivine Rankin Plant Licensing Branch III |
| Rankin J, NRR/DORL/LPL3-1, 415-1530 | |
| References | |
| CAC MF8486 | |
| Download: ML16344A088 (20) | |
Text
LAR on Proposed Modification Changes to Support Implementation of NFPA 805 at Palisades December 7, 2016 1
Introduction of Entergy Team
- Otto Gustafson - Director, Regulatory Assurance and Performance Improvement
- Kevin OConnor - Manager, Design Engineering
- Bob White - Supervisor, Programs Engineering
- Jim Miksa - Licensing
- Rick Nance - NFPA 805 Project Manager
- Frank Yanik - Technical Lead
- Amy Hazelhoff - Licensing Support 2
Agenda
- Meeting Purpose
- Background
- LAR Scope
- LAR Submittal Schedule 3
Meeting Purpose
- Present Modification Changes included in LAR Scope
- Discuss Impact of Modification Changes on PRA results
- Discuss Submittal Schedule 4
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Background===
Risk-Informed Resolution
- Per PNPs NFPA 805 Transition License Condition, 2.C.(3).(c).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.
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Background===
- Original Attachment W (Fire PRA Insights) submitted
- Revised Attachment W submitted
- RAI response included aggregate total CDF/LERF
- Revised Attachment W not submitted
- 2/27/15 - Received NFPA 805 Safety Evaluation
- 8/27/15 - Implemented NFPA 805 Program 6
LAR Scope
- NRC Guidance on NFPA 805 License Condition Changes Issued March 2, 2016
- Option A Request
- Summary of Modification Changes
- Summary of Changes to PRA model
- Updated LAR Attachments:
- Attachment M - License Condition
- Attachment S, Table S Modifications Committed
- Attachment W - Fire PRA Insights
- Defense-In-Depth & Safety Margin 7
LAR Scope
- NRC Guidance on NFPA 805 License Condition Changes Issued March 2, 2016 (contd)
- Option A Request
- Summary of Changes to PRA Model
- LAR uses Safety Evaluation PRA Model
>> Results provided in LAR are based on the PRA model to support the Safety Evaluation
>> Only changes made were to remove logic related to modification cancellations
>> No new methods used 8
LAR Scope
LAR Scope
- S2 Bypass for AFW Pumps Low Suction Pressure
- S2 Manual Control of CCW and SW for ESS Pumps
- S2 Insulate EDG Exhaust Pipe
- S2 Prevent Spurious Energization of CCW Solenoid Valves
- S2 Provide Same Train Power to Battery Chargers
- S2 V-21D Fire Barrier Penetration 10
LAR Scope
- Modification Cancellation Basis:
- PRA Strategy
- Original LAR submittal of Attachment S provided risk ranking per individual modification
- PRA RAI 30 Final Quantification submittal of Attachment S provided risk ranking per individual modification
- PNP subsequently evaluated modifications in aggregate and determined these 6 modifications provided minimal risk benefit 11
LAR Scope
- Modification Cancellation Basis (contd):
- S2 Bypass for AFW Pumps Low Suction Pressure
- S2 Manual Control of CCW and SW for ESS Pumps
- S2 Insulate EDG Exhaust Pipe
- Modifications assigned a Low risk rank in Table S-2
- Modifications intended to improve the ability to perform an existing action
- Modifications provided no risk benefit when considered in aggregate 12
LAR Scope
- Modification Cancellation Basis (contd):
- S2 Prevent Spurious Energization of CCW Solenoid Valves
- Modification originally assigned a High risk rank in Table S-2
- Modification has a synergistic relationship with modification S2-5 (Alternate Primary Coolant Pump Trip)
- S2-14 modification importance reduced to a level that is no longer risk beneficial when considering the modification in aggregate with S2-5 13
- Modification Cancellation Basis (contd):
- S2 Provide Same Train Power to Battery Chargers
- Modification included in S-2 for deterministic reasons
- Not a risk reduction modification, aggregate results show no risk benefit
- S2 V-21D Fire Barrier Penetration
- Adequate for the hazard evaluation performed
LAR Scope
- Attachment W Table Comparison
- PRA RAI 30 Final Quantification
- Included a revised Attachment W
- PRA RAI 01.j.01.01 on Well-Sealed MCCs
- Revised Attachment W not submitted
- Several fire areas had increased CDF & LERF due to the addition of new scenarios related to MCCs
- Only total CDF/LERF results provided in response to RAI 15
LAR Scope
- Attachment W Table Comparison (contd)
- LAR for Modification Changes
- Including a revised Attachment W
- Attachment W Tables being provided mostly impacted by PRA RAI 01.j.01.01 on Well-Sealed MCCs
- Total CDF/LERF results are unchanged from those provided in response to MCC RAI
- PRA Summary
- Total CDF and LERF remain within RG 1.174 guidelines
- Defense-In-Depth & Safety Margin not affected 16
LAR Scope
- S2 CVCS Letdown
- S2 PCP Trip
- S2 Charging Pump Trip
- S2 Replacing Cabling to Rx Head & PZR Vent Valves
- S2 Install New Detection System
- S2 Alternate Supply of AC and DC Power to EC150
- S2 Modify MO-2160 Actuator
- S2 Seismic Gaps 17
LAR Scope
- Modification Statement Clarification Basis:
- Table S-2 administrative revisions due to statements that are not applicable
- Table S-2 modification statement revisions due to detailed design findings
- Modifications remain functionally equivalent and address the problem statement in Table S-2
- Future Table S-2 clarifications would be covered per new Attachment S note:
- The Proposed Modification statements in Table S-2 provide conceptual design to address the Problem Statement. The final design and installation to resolve the Problem Statement will be developed and approved in accordance with ENO processes, hence implementation details may vary.
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LAR Submittal Schedule
- Submittal of LAR ~January 2017
- Approval needed to support Fall 2018 Outage Milestones 19
Questions/Discussion 20