ML20211G575

Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4

ML20211G575
Person / Time
Site:	Waterford
Issue date:	08/27/1999
From:	Chandu Patel NRC (Affiliation Not Assigned)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
GL-88-20, TAC-M83692, NUDOCS 9908310290
Download: ML20211G575 (4)

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lAr. Ch rl:s M. Dugg:r Vic) Pr:sid:nt Op:rctions Ent:rgy Op rations, Inc. August 27, 1999 P. O. Box B l Killona, LA 70066 1

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3- REQUEST FOR ADDITIONAL INFORMATION RE: INDIVIDUAL PLANT EXAMINATION OF EXTERNAL EVENTS SUBMITTAL (TAC NO. M83692)

REFERENCE:

1. Entergy Operations, Inc. letter No. W3F1-98-0030 from E. C. Ewing to the USNRC, dated February 23,1998.

2. Electric Power Research Institute (EPRI) Report " Guidance for Development of Response to Generic Request for Additional Information on Fire Individual Plant Examination for External Events (IPEEE)," dated May 1999.

Dear Mr. Dugger:

We have reviewed your response (Ref.1) to our previous request for additionalinformation (RAl) on the IPEEE, Generic Letter (GL) 88-20, Supplement 4, dated June 28,1991. Based upon our review of your response, we are unable to conclude at this time that you have met the intent of Supplement 4 to GL 88-20. Therefore, your response to the enclosed follow-up questions, considering the recently developed EPRI guidance provided in Reference 2, is necessary to complete our review.

It is requested that you provide a response to the enclosed RAI within 90 days of your receipt of this letter. If you have any questions regarding this matter, please call me at 301-415-3025.

Sincerely, ORIGINAL SIGNED BY  !

, Chandu Patel, Project Manager, Section 1 hh Project Directorate IV & Decommissioning Division of Licensing Project Management l

Office of Nuclear Reactor Regulation j i

Docket No. 50-382 DISTRIBUTION: I C Docket File . K. Brockman, RIV l

Enclosure:

As stated PUBLIC S. Black i S. Richards ACRS cc w/ encl: See next page OGC R. Hernan PDIV-1 Reading A. Rubin i

7 SCC Pvc4Ovs To receive a copy of this document, indicate "C" in the box OFFICE PDIV-1/PM, C, PDIV-1/LA PDIV-1/SC C  ; j l NAME CPatel:sk LBerryi k RGramndla '

DATE I/7/7 /99 8/W/99 6/'t/7 /99 I DOCUMENT NAME:G:\PDIV-1\Waterford\rai83692.wpd OFFICIAL RECORD COPY l Y

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9900310290 990827 PDR ADOCK 05000382 4' l l P PM

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Waterford Generating Station 3 cc:

Administrator Regional Administrator, Region IV l

Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission P. O. Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 l Vice President, Operations Support Parish President Council Entergy Operations, Inc. St. Charles Parish P. O. Box 31995 P. O. Box 302 Jackson, MS 39286 Hahnville, LA 70057 o

Director Executive Vice-President Nuclear Safety & Regulatory Affairs and Chief Operating Officer Entergy Operations, Inc. Entergy Operations, Inc.

P. O. Box B P. O. Box 31995 Killona, LA 70066 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway Chairman P. O. Box 651 Louisiana Public Service Commission Jackson, MS 39205 One American Place, Suite 1630 Baton Rouge, LA 70825-1697 General Manager Plant Operations Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Resident inspector /Waterford NPS Post Office Box 822 Killona, LA 70066 i l

l l l

May 1999 l

Waterford Steam Electric Station. Unit 3 (Waterford 3)

Supplemental Reauest for Adoitionalinformation 1

Based on our review, the Waterford 3 response dated February 23,1998 (Ref.1) to the NRC's request for additional information (RAl) dated October 27,1998, does not address the issues raised in the Individual Plant Examination for External Events (IPEEE) fire analysis-related RAI questions. A revised response to the following supplemental RAI is necessary for the NRC to complete its review of the Waterford 3 IPEEE submittal. The fire analysis guidance documented in Reference 2 should be used to address the issues raised in the original RAI questions. Please provide a revised response to the following supplemental RAI questions.

Fire events

1. The licensee's response to RAI Question 1 relating to the assumed heat release rates (HRR) from electrical cabinet fires is not acceptable. The licensee's response to RAI Question 1 reiterates information provided in the submittal and/or traceable to the EPRI Fire PRA [probabilistic risk assessment) Implementation Guide (FPIG), without responding to the issues of the question. During the period between the review of the submittal and the licensee's response to this RAl, the issue of higher HRR has been under discussion between the NRC research (RES) staff and the Nuclear Electric Institute (NEI) staff. Based on such discussions, Reference 2 has been developed by the industry that provides specific guidance on modeling of appropriate HRR for control cabinets and switchgear enclosures. Please consider the new guidance provided in Reference 2, and submit a revised response addressing the issues of RAI Question 1.

2. The licensee's response to RAI Question 2 relating to the treatment of fires involving transient combustible (TC) sources is not acceptable. NUREG-1407 notes that the fire-induced vulnerability evaluation (FIVE) methodology, which the licensee cites, was an acceptable methodology for IPEEE fire analysis submittals. The FIVE methodology clearly states that TC fires should be modeled for its impact on the overall fire core damage frequency (CDF) and included in the submittal. The licensee's response to RAI Question 2 reiterates information provided in the submittal and/or traceable to the EPRI FPlG, without responding to the issues of the question. Reference 2 provides recently developed industry guidance on explicit treatment of TC sources. Please consider the guidance provided in Reference 2, and submit a revised response addressing the issues of RAI Question 2, including the impact of TC sources on overall fire CDF.

3. The licensee's response to RAI Question 5 relating to the assumed heat loss factor (HLF) is not acceptable. The licensee's response to RAI Question 5 reiterates information provided in the submittal and/or traceable to the EPRI FPlG, without responding to the issues of RAI Question 5. In particular, the use of HLF (0.85) in some fire areas where the resulting temperature rise is 0.88 - 0.99 of that required for damage ,

is suspect. Also of interest are those fire areas that were screened when a value of 0.85 l was assumed, and the HLF values assigned to the fire analysis of the charging pump room. During the period between the review of the submittal and the licensee's response to this RAI, the issue of lower HLF has been under discussion between the RES staff and the NEl staff. Based on such discussions, Reference 2 has been Enclosure l

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developed by the industry that provides guidance on the assignment of appropriate HLF I to fire areas. Please consider the guidance in Reference 2, and submit a revised response addressing the issues of RAI Question 5, including the impact of potential use 1 of lower HLF values for 10 fire scenarios on overall fire-induced CDF.

Seismic events There are no RAls in this area.

Hiah wind. floods and other external events There are no RAls in this area.