ML18305B322
| ML18305B322 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/01/2018 |
| From: | Entergy Nuclear Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18305B320 | List: |
| References | |
| PNP 2018-040 | |
| Download: ML18305B322 (23) | |
Text
PNP 2018-040 ATTACHMENT 1 Description and Evaluation of Proposed Operating License Change 22 pages follow
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE 1.0
SUMMARY
DESCRIPTION Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) requests to amend the Renewed Facility Operating License (RFOL)
DPR-20 for Palisades Nuclear Plant (PNP). ENO is requesting review and approval of a proposed amendment to the RFOL to clarify ten modifications and cancel six modifications from Attachment S, Table S-2, "Plant Modifications Committed," which is referenced in the National Fire Protection Association (NFPA) 805 transition license condition, 2.C(3)(c)2.
2.0 DETAILED DESCRIPTION Description of Proposed Change In Reference 1, ENO submitted a license amendment request (LAR) to adopt the NFPA 805 performance-based standard for fire protection for light water reactors. In Reference 2, ENO submitted a response to a request for additional information (RAI) which included submittal of an updated LAR Attachment S, "Plant Modifications Committed," and an updated Attachment W, "Fire PRA Insights," Table W-1, "Fire Initiating Events Contributing> 1 % to the Calculated Fire Risk," and Table W-2, "PNP Fire Area Risk Summary." During the NRC review of Reference 2, another RAI was issued by the NRC. This additional RAI required a revision to the probabilistic risk assessment (PRA) model to address the impact of the treatment of the potential for fire damage external to well-sealed cabinets.
ENO provided a response to this additional question in Reference 3.
Reference 3 did not include updated Attachment W tables, but it did provide revised risk results for core damage frequency (CDF) and large early release frequency (LERF). In Reference 4, the NRC issued the safety evaluation report (SE) for Reference 1, which approved the addition of the NFPA 805 license condition to the PNP RFOL.
The PRA model of record used to support Reference 3 is the same PRA model used to evaluate the cancellation of the six modifications proposed in this request. This PRA model of record uses the accepted fire PRA methods and approaches as summarized in the NRC NFPA 805 SE (Reference 4).
In Reference 5, ENO submitted a LAR to change the full compliance implementation date for the fire protection program transition license condition for required modifications. In Reference 6, the NRC issued the SE for Reference 5. The issuance of this LAR revised the NFPA 805 license condition in the PNP renewed facility operating license (RFOL).
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE ENO is requesting review and approval of a proposed amendment to the RFOL to clarify ten modifications and cancel six modifications in Attachment S, Table S-2, which is referenced in the NFPA 805 transition license condition, 2.C(3)(c)2, as follows:
The licensee shall implement the modifications to its facility, as described in Table 8-2, "Plant Modifications Committed," of END 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 refueling outage following the third full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
This LAR proposes a revision to the PNP RFOL fire protection condition to add references for this request and the future approving NRC SE. In addition, the transition license condition, 2.C(3)(c)2, will be revised to reflect an updated reference to Attachment S, Table S-2, as follows:
The licensee shall implement the modifications to its facility, as described in Table 8-2, "Plant Modifications Committed," of END letter PNP 2018-040 dated November 1, 2018, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the third full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
The guidance provided in Reference 7 was used to develop this LAR. ENO is submitting this LAR per Option A of this guidance. The removal of the plant modifications has been evaluated using the accepted fire PRA methods and approaches as summarized in Reference 4.
Per this guidance, the following information should be provided for an Option A approval:
- i.
A summary of all changes to the modifications; ii.
A summary of all changes to the PRA models and explanation for each change; iii.
New, updated versions in their entirety of: the license condition (Attachment M), list of plant modifications (Attachment S), and the summarizing area wide change-in-risk result tables (Attachment W); and iv.
A statement that the defense-in-depth (DID) and safety margin evaluations associated with the original LAR have been completed on the proposed changes.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The information described in items i, ii, iii and iv is addressed below.
3.0 TECHNICAL EVALUATION
Item i. - Summary of Changes to the Modifications ENO proposes to cancel six modifications in Attachment S, Table S-2, as follows:
S2 Bypass for AFW Pumps Low Suction Pressure Trips The proposed modification would have provided the ability to block spurious low suction pressure trips of operating auxiliary feedwater (AFW) pumps from the control room. The risk ranking of this modification was low given other failures of the AFW pumps in fire scenarios which impacted the cables associated with low suction pressure trip. In addition, the benefit of modification S2-1 (diesel-driven auxiliary feedwater pump) offsets the benefit of this modification. The impact of cancelling this modification was considered in aggregate with the other modifications being cancelled. The impact of the change is represented in the updated Attachment W which demonstrates no change in aggregate core damage frequency (CDF) and large early release frequency (LERF). Therefore, cancellation of this modification is proposed.
S2 Manual Control of Component Cooling Water (CCW) and SeNice Water (SW) for Engineered Safeguards System (ESS) Pumps The proposed modification would have supported a control room action to align SW cooling to ESS pumps using a nitrogen supply installed by the modification.
The risk ranking of this modification was low given other failures of the ESS pumps in fire scenarios which impacted the CCW source to the pumps. Restoration of pump cooling as an independent strategy did not provide a significant benefit in the recovery of ESS pumps due to other fire induced faults causing pump failure.
The impact of cancelling this modification was considered in aggregate with the other modifications being cancelled. The impact of the change is represented in the updated Attachment W which demonstrates no change in aggregate CDF and LERF. Therefore, cancellation of this modification is proposed.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE S2 Insulate Emergency Diesel Generator (EDG) Exhaust Pipe The proposed modification would have added insulation to a portion of the exhaust piping for each EDG to reduce the rate at which the two EDG rooms heat up on loss of ventilation. This would have increased the available time for operator action to implement alternate diesel room cooling strategies. The risk ranking of this modification was low given other failures of the diesels in fire scenarios which impacted the room cooling. Restoration of cooling as an independent strategy did not provide a significant benefit in the restoration of AC power. The impact of cancelling this modification was considered in aggregate with the other modifications being cancelled. The impact of the change is represented in the updated Attachment W which demonstrates no change in aggregate CDF and LERF. Therefore, cancellation of this modification is proposed.
S2 Prevent Spurious Energization of CCW Solenoid Valves The proposed modification would have replaced existing control cables for the air-operated valves (CV-091 0, CV-0911 and CV-0940) controlling CCW flow to containment. The intent of the modification was to prevent spurious closure of these valves due to fire induced faults on control circuit cables. The risk ranking of this modification was high. The original benefit of this modification was predicated on the initial assumed failure of these valves due to fire induced cable faults.
Application of the methodology of NUREG/CR-7150 (Reference 8) lowered the impact of these cable faults to an unimportant risk contribution. In addition, the benefit of modification S2-5 (alternate primary coolant pump trip) offsets the benefit of this modification. The impact of cancelling this modification was considered in aggregate with the other modifications being cancelled. The impact of the change is represented in the updated Attachment W which demonstrates no change in aggregate CDF and LERF. Therefore, cancellation of this modification is proposed.
S2 Provide Same Train Power to Battery Chargers The proposed modification would provide a second power source to the cross-train battery chargers. The second power source would have provided the ability to power these battery chargers from the appropriate power division in addition to the current cross-train source. Providing a second power source was not identified as a risk reduction modification. However, the PRA model was modified to incorporate this modification, which demonstrated no risk benefit. The impact of cancelling this modification was considered in aggregate with the other modifications being cancelled. The impact of the change is represented in the updated Attachment W which demonstrates no change in aggregate CDF and LERF. Therefore, cancellation of this modification is proposed.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE S2 Turbine Building Fresh Air Fan V-21 0 Fire Rating This modification was intended to restore the fire rating of the exterior wall associated with fan (V-21 D). Subsequent re-evaluation of the plant exterior walls was completed and determined that the current fan configuration is adequate for the hazard. Therefore, cancellation of this modification is proposed.
Attachment S, Table S-2 wording has been revised to reflect that the above modifications are no longer being pursued. The updated Attachment S, Table S-2 is provided in Attachment 3 of this LAR. This attachment contains security related information and should be withheld from public disclosure under 10 CFR 2.390.
ENO proposes to clarify ten modifications, as follows:
S2 Spurious Operation of Reactor Head/Pressurizer Vent Valves Original Modification S2-15 Wording:
This is a modification to replace the existing cabling to the reactor head vent valves and pressurizer vent valves with fire-rated cables.
Revised Modification S2-15 Wording:
This modification will modify the control circuit and replace existing cabling to the reactor head vent and pressurizer vent isolation valves.
Justification:
The original benefit of this modification was predicated on the initial assumed failure of these valves due to fire induced cable faults. Application of the methodology of NUREG/CR-7150 (Reference 8) lowered the impact of these cable faults to an unimportant risk contribution, which negates the need for a fire rated cable.
This modification will alter the control circuit for the isolation valve in each of the two vent paths such that the risk of spurious operation of these valves to provide an uncontrolled release path is reduced to an acceptable risk level.
The modification will alter cables to the isolation valve in each release path such that cables to the solenoids will not include potentially energized conductors. A second set of contacts will be added to the control switch to make the circuit
'double break'. These changes reduce the risk of spurious operation (opening) of a valve in each path that is capable of maintaining the vent paths isolated.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE This modification is considered functionally equivalent to the original modification.
82 Fire Detection 8ystem Replacement/Upgrade This modification will be implemented as described in Item 82-18 with the exception of the following clarification.
Original Modification 82-18 Wording:
Additionally, Fire Panel C49 and C49A will be replaced with a NFPA 72 compliant fire alarm control panel.
Revised Modification 82-18 Wording:
Additionally, Fire Panel C-47A and C-47B will be replaced with a NFPA 72 compliant fire alarm control panel.
Justification:
The discussion provided in the original LAR incorrectly identified the control room fire alarm panels as C-49 and C-49A. The correct equipment identification is C-47A and C-47B.
82 Motor Operated Valve (MO-2160) Manual Operation Capability Original Modification 82-21 Wording:
Modify the MOV circuitry such that the torque switch is not disabled due to a fire that could also cause the MOV to spuriously operate.
Revised Modification 82-21 Wording:
Modify the MOV actuator such that actuator and valve internals are not damaged due to a fire that could cause the MOV to spuriously stroke open or closed simultaneous with loss of the MOV limit and torque switch protections.
Justification:
The modification problem statement identified that the potential of valve failure due to issues identified in Information Notice (IN) 92-18 can be resolved by modifying the valve via changes to the valve control circuitry. The intent of the modification was to provide assurance that credited actions to manually operate motor-operated valve MO-2160 in certain fire areas/scenarios is not precluded by failure mechanisms identified in IN 92-18.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The replacement of the valve actuator such that it remains capable of being manually operated is considered functionally equivalent to the original proposed modification.
82 8eismic Gap Fire Rating Original Modification 82-24 Wording:
Fill and/or cover the seismic gaps with a rated material. The proposed modification will remove the Flexcell Bond material from the seismic gaps in several Fire Areas and replace it with a fire-rated configuration.
Revised Modification 82-24 Wording:
Evaluate the seismic gaps that serve as fire barriers to determine if they are adequate for the hazard. Those determined not adequate for the hazard in the current configuration will be modified such that the final configuration is adequate for the hazard.
Justification:
The Flexcell Bond material was determined to contain asbestos and will not be removed. The identified seismic gaps were re-evaluated to determine whether they were adequate for the hazard. Those determined not adequate for the hazard will have rated material applied to the existing gap material to provide a configuration determined to be adequate for the hazard.
This modification is considered to be equivalent to the original modification for the purposes of providing adequate fire barriers between the Containment Building and the Auxiliary Building walls and floors.
82 Diesel Generator Room Ventilation Recirculation Damper (D-25)
Original Modification 82-25 Wording:
D-25, EDG 1-1 Room Ventilation Recirculation damper was permanently disabled.
Damper D-25 will be removed and replaced with a fire-rated barrier.
Revised Modification 82-25 Wording:
Existing D-25 damper will be enclosed by a steel plate with fire sealant applied at the edges of the plate.
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Justification:
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The intent of the modification was to establish an acceptable fire barrier. This will be accomplished by the installation of a steel cover plate with dimensions that exceed the size of the damper opening. The cover plate is bolted to the wall and sealed at the plate edges by an acceptable fire-rated material. This configuration was justified as adequate for the hazard.
This configuration is considered to be equivalent to the original proposed modification for the purposes of providing an acceptable fire barrier at the boundary of established fire areas.
S2 Separation of Electrical Ignition Sources from Hydrogen Vent Original Modification S2-29 Wording:
Modify the current configuration of the electrical switches and cabling to remove the ignition source as a hazard to the hydrogen system.
A modification will be performed to move the hydrogen vent discharge line 15 feet from electrical equipment, extending upward while being appropriately protected against weather intrusion.
Revised Modification S2-29 Wording:
Move the identified electrical components and cabling to a distance greater than 25 feet from the hydrogen system.
The hydrogen bottle backup storage vent line was moved to meet the code requirement.
Justification:
The electrical equipment will not be modified to code requirements. The electrical equipment will be relocated to satisfy the separation requirements of the code.
Moving the electrical equipment to a new location that satisfies the code required separation is considered equivalent to modifying the components to remove the ignition hazard to achieve compliance.
The hydrogen bottle backup storage vent line was moved to meet the code requirement.
This modification is considered to be equivalent to the original proposed modification for the purposes of meeting the code requirements.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE 82 Exterior Door Replacement for Hydrogen 8torage Area Original Modification 82-30 Wording:
The exterior doors into Room 139 will be replaced with "lightly fastened" doors that meet the requirement of this code section.
Revised Modification 82-30 Wording:
The exterior doors into Room 139 were replaced with lightly fastened, 1.5-hour fire-rated doors that were determined to be adequate for the hazard.
Justification:
The exterior doors into Room 139 were replaced with a lightly fastened, 1.5-hour fire-rated door that was determined to be adequate for the hazard.
This modification is considered to be equivalent to the original proposed modification for the purposes of providing explosion venting capability in exterior walls of hydrogen storage areas.
82 Replacement of Doors for NFPA-80 Compliance Original Modification 82-31 Wording:
Repair or replace fire doors to ensure compliance with NFPA 80.
Revised Modification 82-31 Wording:
Repair or replace fire doors to ensure compliance with NFPA 80 or justify as adequate for the hazard.
Justification:
A subset of doors required to be 3-hour rated that will be replaced with 1.5-hour rated doors were determined to be adequate for the hazard.
The modification is considered to be equivalent to the original proposed modification for the purposes of maintaining acceptable fire rated barriers.
82 Turbine Building East Wall-Transformer Fire Wall 80uth End Original Modification 82-37 Wording:
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Three-hour fire rated dampers on the Turbine Building Fresh Air Fan (V-21 P, V-21Q, V-21 U, V-21V, V-21W) will be installed.
Revised Modification 82-37 Wording:
The fan starting circuits will be modified to trip the fans and close the dampers on detection of a fire.
Justification:
Three-hour fire dampers are not being installed. The modification will provide inputs to the fan control circuits to shut off the fans and close the current dampers on activation of the transformer deluge systems. The existing dampers were determined to be adequate for the hazard.
The modification is considered to be equivalent to the original proposed modification for the purposes of maintaining acceptable fire barriers for exterior walls.
82 Upper CCW Room Exterior Wall Original Modification 82-38 Wording:
A fire door and barrier will be installed above the door at the north end of the missile shield/valve gallery area.
A fire rated barrier will be installed around the ventilation duct from fan V-78.
Revised Modification 82-38 Wording:
The CCW room west exterior wall fire barrier was repaired and justified as adequate for the hazard.
Justification:
The stated fire door and fire barrier at the north end of the missile shield/valve gallery area will not be installed. A new 3-hour rated fire damper is not installed in the discharge ductwork from V-78 Fan within the missile shield, as the missile shield will not be treated as a fire barrier. The fire barrier between FA-32 and FA-16 will remain the CCW West wall.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The original modification would have replaced a portion of the CCW West wall as an 'exterior' wall with the wall enclosing the missile shield/valve gallery being credited as the exterior wall at this location. Not completing this modification as stated requires the upper CCW room west wall to continue to be the exterior wall at this location. This exterior wall was repaired and justified as adequate for the hazard.
The modification is considered to be equivalent to the original proposed modification for the purposes of maintaining an appropriate fire rating for plant exterior walls in the power block.
Attachment S, Table S-2 wording has been revised to reflect the clarifications described above. The updated Attachment S, Table S-2 is provided in Attachment 3 of this LAR. This attachment contains security related information and should be withheld from public disclosure under 10 CFR 2.390.
Item ii. - Summary of Changes to the PRA Model Updated Attachment W, Tables W-1 and W-2 were last docketed in Reference 2.
The PRA model used to support the last docketed Attachment W tables provided the following CDF/LERF risk results, which reflected incorporation of NUREG/CR-7150 (Reference 8) methodology:
CDF = 4.1 E-05 LERF = 3.5E-06 During the NRC review of Reference 2, an additional RAI was issued by the NRC related to well-sealed cabinets. This additional RAI required a revision to the PRA model to address the impact of the treatment of the potential for fire damage external to well-sealed cabinets. ENO provided a response to this additional RAI in Reference 3. This response did not include an updated Attachment W. The following revised risk results for CDF/LERF were provided:
CDF = 4.4E-05 LERF = 3.8E-06 The PRA model of record used to support Reference 3 is the same PRA model used to evaluate the cancellation of the six modifications proposed in this request. This PRA model of record uses the accepted fire PRA methods and approaches as summarized in the NRC NFPA 805 safety evaluation provided per Reference 4.
The PRA model was revised to remove logic associated with modifications that were identified as no longer required for risk reduction or compliance. An updated 11 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Attachment W, Table W-1 and Table W-2, is provided in Attachment 4 of this LAR.
The updated Attachment W risk values are consistent with the values developed to support Reference 3. The removal of the six modifications from the PRA model reflected no change in the CDF/LERF reported in the Reference 3.
In the updated Attachment W, Table W-1, "Fire Initiating Events Contributing >1%
to the Calculated Fire Risk," the identified scenarios remain the same with the same order of importance. There are minor reductions in percent contribution to the calculated fire risk.
Modification 82-6 would have modified AFW pump control circuits to allow bypass of a low suction pressure trip from the control room for trips determined to be spurious as a consequence of fire induced cable faults. The PRA model logic for the modification established credit for the control room action. Logic associated with credit for the control room circuit modification has been removed. The original local action to clear a low suction pressure trip remains in the model. The human error probability associated with this local event is set to 1.0 for fire conditions. Consequently, credit for the benefit of the modification has been removed.
Modification 82-7 would have provided the means of aligning alternate cooling from the service water system to engineered safeguards pump cooling when component cooling water is unavailable to provide cooling due to a fire. The PRA model credited the action to complete this alignment as feasible in fire conditions.
Control logic in the PRA model for this modification was removed. The local operator to complete this action is retained but considered not feasible. The human error probability associated with this local event is set to 1.0 for fire conditions. Consequently, credit for the benefit of the modification has been removed.
Modification 82-8 would have added insulation to the exhaust piping of the emergency diesel generators to provide a basis for additional time to complete a local operator action to align alternate room cooling to the emergency diesel generator rooms. The benefit of the modification was accomplished via control logic to allow credit for the local action when the modification was complete.
Without the modification the action was considered not feasible. Control logic associated with this modification was removed and the human error probability associated the local operator action has been set to 1.0. This assumes the local action is not feasible and provides no benefit.
Modification 82-14 would have replaced cables in the control circuits of air-operated valves controlling component cooling water flow to containment. The benefit of the modification was established in the PRA model by controlling where fire induced cable faults on the valve control cables could result in spurious 12 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE closure of the valves. The PRA model was modified by removing this control logic.
Consequently, the removal of this modification results in restoration of all scenarios which can spurious closure of anyone of these valves.
Modification 82-26 would have provided a second power source to the cross-train battery chargers. The second power source would have provided the ability to power these battery chargers from the appropriate power division in addition to the current cross-train source. This was not a risk reduction modification. However, the PRA model was updated to include the addition of the alternate power sources to the chargers. The model logic representing the alternate power sources was removed.
Modification 82-39 was not a risk reduction modification and, therefore, removal of this modification does not impact the PRA model.
Attachment W, Table W-1 and Table W-2, has been revised to reflect the changes described above. The updated Attachment W, Table W-1 and Table W-2, is provided in Attachment 4 of this LAR. This attachment contains security related information and should be withheld from public disclosure under 10 CFR 2.390.
Item iii. - Updated LAR Attachments Updated Attachment M, "License Condition Changes" ENO is requesting review and approval of a proposed amendment to the RFOL to clarify ten modifications and cancel six modifications in Attachment 8, Table 8-2, which is referenced in the NFPA 805 transition license condition, 2.C(3)(c)2, as follows:
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 S0.48(c) before the end of the refueling outage following the third full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
This LAR proposes a revision to the PNP fire protection RFOL to add references for this request and the future approving NRC 8E. In addition, the transition license condition, 2.C(3)(c)2, will be revised to reflect an updated reference to, Table 8-2, as follows.
The licensee shall implement the modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of ENO letter PNP 2018-040 dated November 1, 2018, to complete the transition to full compliance 13 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE with 10 CFR 50.48(c) before the end of the refueling outage following the third full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
ENO is providing the proposed RFOL changes (markup & clean) in Attachment 2 of this LAR. These RFOL pages meet the intent of an updated Attachment M.
Updated Attachment S, Table S-2, "Plant Modifications Committed" Attachment S, Table S-2 has been revised to reflect the cancellation of the six modifications described above and the clarification of the ten modifications described above. In addition, a note has been added to the end of Table S-2 as follows:
Note: The Proposed Modification statements 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 END processes, hence implementation details may vary.
This note will allow future design flexibility for NFPA 805 modification implementation as some design scope remains conceptual at this time.
Several modifications in Attachment S, Table S-2 have been implemented since Table S-2 was last submitted per Reference 2. The scope of the changes to Attachment S, Table S-2 in this LAR is intentionally limited to the cancellation of the six modifications and the clarification of the ten modifications. Therefore, Table S-2 was not updated to reflect modifications that have already been installed and could be transferred to Table S-1, "Plant Modifications Completed."
The updated Attachment S, Table S-2 is provided in Attachment 3 of this LAR.
This attachment contains security related information and should be withheld from public disclosure under 10 CFR 2.390.
Updated Attachment W, Table W -1, "Fire Initiating Events Contributing> 1 % to the Calculated Fire Risk," and Table W-2, "PNP Fire Area Risk Summary" Attachment W, Table W-1, "Fire Initiating Events Contributing> 1 % to the Calculated Fire Risk," and Table W-2, "PNP Fire Area Risk Summary," has been revised to reflect the removal of the six modifications described above. The removal of the six modifications from the PRA model reflected no change in the CDF/LERF reported in Reference 3. The updated Attachment W, Table W-1 and Table W-2, is provided in Attachment 4 of this LAR. This attachment contains 14 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE security related information and should be withheld from public disclosure under 10 CFR 2.390.
Item iv. - Defense-in-Depth and Safety Margin The removal of credit of these modifications has no impact on any of the defense-in-depth (DID) echelons which are to: (1) prevent fires from starting, (2) rapidly detect, control, and extinguish promptly those fires that do occur thereby preventing fire damage, and (3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.
Adequate safety margins are maintained because elimination of these modifications does not impact compliance with any codes and standards, or their alternatives accepted for use by the NRC, and these changes do not impact any safety analysis acceptance criteria used in the licensing basis.
A review of the prior determinations for DID and safety margins, taking into account the modifications being eliminated, established that the DID and safety margins continue to meet the acceptance criteria of NFPA 805, Section 4.2.4, with no change to the required modifications or DID actions. Recovery actions identified as required previously are not impacted by the modification elimination and remain capable of being performed. Consequently, it was determined that no changes to the existing evaluations are required.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE 4.0 REGULATORY EVALUTION 4.1 Applicable Regulatory Requirements/Criteria The changes described in the LAR comply with the following regulations and continue to meet the intent of the applicable General Design Criteria.
The construction permit for Palisades Nuclear Plant (PNP) was issued by the Atomic Energy Commission (AEC) on March 14, 1967, and an Interim Provisional Operating License was issued by the AEC on March 24, 1971. In the request for a full term operating license and application for an increase in power level, which was submitted to the NRC on January 22,1974, Consumers Power Company (previous PNP owner) provided a discussion to compare the PNP design with the General Design Criteria (GDC) as they appeared in 10 CFR 50 Appendix A on July 7, 1971. It was this discussion, including the identified exceptions, which formed the original plant licensing basis for compliance with the GDC. This discussion is contained in Updated Final Safety Analysis Report (UFSAR) Chapter 5.1, "General Design Criteria," with more details provided in other UFSAR sections. As described in UFSAR Section 5.1.1, changes have been made to the original UFSAR GDC discussions to reflect commitments and changes made to the facility over the life of the plant. Therefore, the GDC discussions in the UFSAR constitute the PNP licensing bases with respect to compliance with the GDC.
An assessment of the proposed changes concluded that there are no exceptions to ENO compliance with any of the following regulations, as described in the UFSAR:
GDC-3 requires that SSCs important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
GDC-4 requires that SSCs important to safety be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents including loss of coolant accidents. These structures, systems and components shall be appropriately protected against dynamic effects, including the effect of missiles, pipe whipping and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit.
GDC-23 requires that the protection system be designed to fall into a safe state or into a state demonstrated to be acceptable on some other defined basis if conditions such as disconnection of the system, loss of energy (e.g., electric 16 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE power, instrument air), or postulated adverse environments (e.g., extreme heat or cold, fire, pressure, steam, water and radiation) are experienced.
GDC-25 requires that the protection system be designed to assure that specified acceptable fuel design limits are not exceeded for any single malfunction of the reactivity control systems, such as accidental withdrawal (not ejection or dropout) of control rods.
GDC-26 requires that two independent reactivity control systems of different design principles be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operations, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.
GDC-27 requires that reactivity control systems be designed to have a combined capability, in conjunction with poison addition by the emergency core cooling system, of reliably controlling reactivity changes to assure that under postulated accident conditions and with appropriate margin for stuck rods the capability to cool the core is maintained.
GDC-28 requires that reactivity control systems be designed with appropriate limits on the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents can neither (1) result in damage to the reactor coolant pressure boundary greater than limited local yielding nor (2) sufficiently disturb the core, its support structures or other reactor pressure vessel internals to impair significantly the capability to cool the core. These postulated reactivity accidents shall include consideration of rod ejection (unless prevented by positive means), rod dropout, steam line rupture, changes in reactor coolant temperature and pressure, and cold water addition.
GDC-29 requires that protection and reactivity control systems be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE 4.2 Precedent The requested changes to the NFPA 805 modifications are similar in nature to the NFPA 805 modification change approved by the NRC and implemented by Ginna Nuclear Plant (Reference 9).
4.3 No Significant Hazards Consideration Determination Pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90), Application for amendment of license, construction permit, or early site permit, Entergy Nuclear Operations, Inc. (ENO) requests an amendment to the Renewed Facility Operating License (RFOL) for the Palisades Nuclear Plant (PNP). The amendment would revise the fire protection sections of the RFOL to reflect an updated Attachment S, Table S-2 revised to reflect the cancellation of six modifications and the clarification of ten modifications.
Pursuant to 10 CFR 50.92, Issuance of amendment, ENO has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration since the proposed changes satisfy the standards in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of the no significant hazards criteria and demonstrates that the proposed amendment does not constitute a significant hazard.
Entergy Nuclear Operations, Inc. (ENO) requests to amend Renewed Facility Operating License (RFOL) DPR-20 for the Palisades Nuclear Plant (PNP). The proposed amendment requests Nuclear Regulatory Commission (NRC) approval to revise the existing RFOL Fire Protection license condition and transition license condition.
ENO has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:
- 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE The proposed change to the PNP RFOL to change the Attachment 8, Table 8-2 modification scope does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents, and has no impact on the probability or consequences of an accident previously evaluated. The impact of cancelling these modifications was considered in aggregate with the other modifications being cancelled. The probabilistic risk assessment (PRA) model impact of removing these modifications demonstrates no change in aggregate core damage frequency (CDF) and large early release frequency (LERF).
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change to the PNP RFOL to change the Attachment 8, Table 8-2 modification scope does not create the possibility of a new or different kind of accident from any accident previously evaluated. This change does not alter accident analysis assumptions, add any initiators, or create the possibility of a new or different kind of accident. The proposed change does not eliminate any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents, and has no impact on the probability or consequences of an accident previously evaluated.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change to the PNP RFOL to change the Attachment 8, Table 8-2 modification scope does not involve a significant reduction in a margin of safety. Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in 19 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE the technical specifications. Because there is no change to established safety margins as a result of these changes, the proposed change does not involve a significant reduction in a margin of safety.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the evaluation above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4 Conclusions In conclusion, based on the considerations described above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:
(i) The amendment involves no significant hazards consideration.
As described in Section 4.3 of this evaluation, the proposed change involves no significant hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed amendment does not involve any physical alterations to the facility configuration that could lead to a change in the type or amount of effluent released offsite.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.
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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with the issuance of this amendment.
6.0 REFERENCES
- 1. ENO letter, PNP 2012-106, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors,"
dated December 12,2012 (ADAMS Accession Number ML12348A455)
- 2. ENO letter, PNP 2014-080, "Response to Request for Additional Information -
License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors," dated August 14, 2014 (ADAMS Accession Number ML14226A498)
- 3. ENO letter, PNP 2014-097, "Response to Request for Additional Information -
License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors," dated November 4, 2014 (ADAMS Accession Number ML14308A228)
- 4. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)," dated February 27, 2015 (ADAMS Accession Number ML15007A191)
- 5. ENO letter, PNP 2017-066, "License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated November 1, 2017 (ADAMS Accession Number ML17306A086)
- 6. NRC letter, "Palisades Nuclear Plant - Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications," dated February 27, 2018 (ADAMS Accession Number ML18039A244)
- 7. NRC letter to NEI, "Recommended Content for License Amendment Requests that Seek Changes to License Conditions that were Established in Amendments to Adopt National Fire Protection Association Standard 805 But 21 of 22
ATTACHMENT 1 DESCRIPTION AND EVALUATION OF PROPOSED OPERATING LICENSE CHANGE Have Yet to be Fully Implemented," dated March 2, 2016 (ADAMS Accession Number ML16015A416)
- 8. NUREG/CR-7150, "Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE)," Volume 2, "Expert Elicitation Exercise for Nuclear Power Plant Fire-Induced Electrical Circuit Failure," dated May 2014
- 9. NRC letter, "R.E. Ginna Nuclear Power Plant -Issuance of Amendment Related to Request to Delete a Modification Associated with the Risk-Informed, Performance-Based Fire Protection Program In Accordance with 10 CFR 50.48(c)," dated June 25, 2018 (ADAMS Accession Number ML18114A025) 22 of 22