PNP 2013-013, Response to Clarification Request - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors

Response to Clarification Request - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors

ML13079A090
Person / Time
Site:	Palisades
Issue date:	02/21/2013
From:	Vitale A Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
PNP 2013-013
Download: ML13079A090 (81)

Text

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Anthony J Vitale Site Vice President PNP 2013-013 February 21, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Clarification Request - License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1. Entergy Nuclear Operations, Inc. 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 No. ML12348A455)

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request to adopt the National Fire Protection Association (NFPA) 805 performanced-based standard for fire protection for light water reactors.

On February 5, 2013, a conference call was held with the NRC to discuss clarification questions which were sent via electronic mail on February 4, 2013. A follow-up call was conducted with the NRC on February 6, 2013, to confirm the clarification questions and required response timeframe.

Attachment 1 provides the ENO responses to the clarification questions.

A copy of this response has been provided to the designated representative of the State of Michigan.

This letter contains no new or revised commitments.

PNP 201 3-013 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 21, 2013.

Sincerely, ajv471

Attachment:

1. Response to Clarification Requests License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors A request for clarification was received from the Nuclear Regulatory Commission (NRC), by electronic mail on February 4, 2013. Subsequent conference calls with the NRC on February 5, 2013 and February 6, 2013 were conducted to confirm the clarification questions and required response timeframe.

The Entergy Nuclear Operations, Inc. (ENO) response is provided below.

NRC Request

1. Several critical review elements from the last full-scope fire PRA peer review were either incomplete or received a significant number of findings, indicating the fire PRA was not able to be fully reviewed by the peer review team. As such, a focused-scope peer review is needed for the following elements to support the close out of the licensee proposed dispositions/resolutions: FSS (Fire Scenario Selection), FQ (Fire Quantification), HRA (Human Reliability Analysis) and UNC (Uncertainty Analysis). A list of the findings includes, but is not necessarily limited to, the following: FQ-C1-01, HRA-A2-01, HRA-A3-01, HRA-A4-01, HRA-B3-01, HRA-C1-01, HRA-D2-01, HRA-E1-01, PRM-B11-01, CS-A9-01, CS-C1-01, FSS-B1-01, FSS-E3-01, FSS-H5-01, CS-B1-01, PRM-B3-02, PRM-B9-01, PRM-B5-01, FQ-A4-01, ES-A3-01 and UNC-A2-01.

ENO Response

1. Attachment V of the Palisades license amendment request (LAR), presents the cumulative results of three independent Peer reviews of the Palisades fire probabilistic risk analysis (PRA) model and supporting documentation; two in-process Peer reviews and one Final Peer review. The resulting findings and observations (F&Os), as written by the Peer review team, were presented verbatim in Attachment V. The Staff was concerned that the F&O descriptions imply several PRA elements were incomplete or received a number of findings indicating that they could not be reviewed. This document provides supplemental information to demonstrate that all applicable PRA high level requirements (HLR) were reviewed in detail by the Peer review team.

The Palisades Fire PRA Peer Review was evaluated in three phases against the requirements of ASME/ANS RA-Sa-2009, Part 4 [15] by essentially the same personnel.

1. The first in-process Peer review (Phase 1) was conducted during the week of January 18th, 2010.

2. The second in-process Peer review (Phase 2) which included two NRC observers was conducted during the week of August 27, 2010.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors

3. The final phase (Final) was conducted during the week of March 21, 2011.

The final report as described in paragraph two in Attachment V of the LAR, SCIENTECH document 17825-1, was released in July 2011.

The Peer review team consisted of subject matter experts from SCIENTECH, Edan Engineering, SAIC, and ABS Consulting; two of the team members were authors of NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities. The final report as described in paragraph two in Attachment V of the LAR, SCIENTECH document 17825-1 [16], describes the Phase 1, Phase 2 and Phase 3 (Final) findings.

The two in-process reviews were provided to assist Palisades in assessing the technical adequacy and to refine plans, if necessary, to ensure the technical requirements of the final fire PRA would meet the ASME/ANS PRA standard.

Although the in process reviews were not conducted on a completed fire PRA, the reviews were conducted in strict accordance with the standard. Not Met or Not Reviewed was assigned if tasks needed to meet the standard requirements were not complete, depending on the degree of completion. In addition, the in process reviews identified actions necessary to achieve as a minimum Category II, where deemed appropriate.

A Final Peer review, of selected technical elements, was deemed necessary to meet the intent of the standard. The final report [16] provides the results of the Final Peer review and the in-process Peer reviews for those technical elements sufficiently reviewed during the in process reviews. Findings and observations from in-process Peer reviews were revisited by the Peer review team, but the finding descriptions were not eliminated or revised due to time constraints. For example, a number of supporting requirements with associated findings in the final report were categorized as meeting CC II (capability category) or greater. In other cases, every element as required by the standard is met, however, a singular refinement or enhancement is found to be needed and hence a finding would result.

There were no changes in applied methodology from the conduct of the Final Peer review on March 21, 2011 to the formal LAR submittal release on December 12, 2012.

Table 1, below illustrates the overall results presented in the summary table from the final report [16]. These results show that 94 supporting requirements meet the ASME standard CC II or greater, 58 supporting requirements (SRs) were not met, 3 met category I, and 14 were classified as not applicable. Four SRs had a final status of not reviewed after the Final peer review; these are presented in Table 3.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional information is provided in Table 2, below to illustrate during which Peer review phase F&Os were identified and reviewed, as well as summary information from the final report to clarify the teams conclusions for each ASME standard element in which a finding was noted. This table re-presents the information provided in LAR Attachment V, Table V-1, with the addition of three new columns, annotated in bold and italics, as shown below. The SR, Topic, Status, and Finding or Suggestion columns were not changed from Attachment V, Table V-1. The disposition description for several SRs was revised to clarify the basis for status of these requirements.

SR SR Disposition Supplemental Initial Subsequent Information Peer Peer Review Review Status Status In the SR Initial Peer Review Status column, the status from when the supporting requirement (SR) was initially reviewed is provided.

In the SR Subsequent Peer Review Status column, the status from the Final Peer review for the SR is provided.

When a supporting requirement was categorized as not met this was the status at completion of the Final Peer review conducted during the week of March 21, 2011. If the supporting requirement was subsequently addressed prior to the LAR submittal in December 2012, it was categorized as closed in the status column (per the disposition discussion). In these cases the SR finding or suggestion has been fully addressed and the intent of Capability Category II has been met to properly support the LAR submittal.

In the Supplemental Information column, additional information is provided that supports the review for this supporting element was complete; especially if the F&O implies the work was not in a state that could be reviewed. This information was primarily obtained from the Summary of Review Results (Section 4) of the Final Peer review report [16].

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 1: Summary of Overall Results of the Palisades Fire PRA Peer Review Number of Supporting Requirements Meeting Each Capability Category Not Not Fire PRA Not Met Met CCI CCI/II CCII CCII/III CCIII Applicable Reviewed Total Element (NA) (NR)

PP 1 8 3 12 ES 9 2 1 1 1 14 CS 4 9 1 1 1 16 QLS 6 1 7 PRM 10 5 1 4 20 IGN 2 9 1 1 2 15 QNS* 6 6 CF 1 1 1 3 HRA 6 1 3 1 1 12 SF 6 6 FQ 4 5 1 10 FSS 13 16 3 9 6 2 1 50 UNC 2 2 Total 58 62 3 3 12 11 6 14 4 173

% of Total 34% 36% 2% 2% 7% 6% 3% 8% 2%

% excluding 37% 40% 2% 2% 8% 7% 4% 9% 3%

NA or NR

• Palisades did not perform quantitative screening so the requirements of QNS are not applicable Page 4 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status CSA401 If additional cables are selected Closed The Fire PRA cable data is Phase 1 Phase 2/ Suggestion closed by During the Phase 1 and Phase 2 reviews, (Suggestion) based on SR CSA3, VERIFY that maintained in the SAFE (reviewed Final documentation update. No this SR was classified as Not Met the adverse effects due to failure software and an adjunct not met) (met) impact to NFPA805 analysis. During the Final Peer review in March of the selected cables are Excel spreadsheet. The data Cable data from the adjunct Excel 2011, additional reviews of the cable included the Fire PRA plant should be integrated into a spreadsheet has been integrated selection element were conducted to response model. single data set within the into the SAFE database to ensure assess resolution of F&Os identified during SAFE software to ensure longterm maintenance of the the inprocess reviews. The findings from proper longterm analysis. Phase 1 and Phase 2 for this SR were maintenance of the analysis. resolved and this suggestion was identified during that review.

Per the final Scientech report 178251, The cable selection and location task is essentially complete. Future work will typically involve iterations to refine the Fire PRA.

Specifically, the Phase 1 review identified 7 findings and 5 suggestions. The Phase 2 Peer review modified 8 F&Os and added 2 additional suggestions. The Final Peer review resulted in 4 findings, 2 suggestions, and 1 best practice; supporting the fact the work had transitioned satisfactorily from the first inprocess Peer review.

CSA901 INCLUDE consideration of proper Open PLP has conducted updates Phase 1 Phase 2/ Finding open. Although the data A finding in this SR was identified during (Finding) polarity hot shorts on to the original cable (reviewed Final gathering is complete, it was not the Phase 1 Peer review. Cable Selection ungrounded DC circuits; requiring selection to ensure multiple not met) (not met) fully implemented into the model elements were subsequently reviewed in up to and including two hot short failures are used for the LAR. the Phase 2 and Final Peer reviews. The independent faults could result in identified. It is not evident Cable data for the PLP FPRA was finding in this area was revised as part of adverse consequences. that the supplemental obtained from two separate the Final Peer review, but remains open as analysis work specifically sources: the SAFE database and some minor numerical changes are looked for proper polarity NEXUS spreadsheets. The SAFE anticipated once the Fire PRA model is hot shorts on ungrounded database was populated with the updated to utilize the full set of cable data DC circuits. original Palisades Appendix R cable maintained in just one location (SAFE).

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status data, the cable data collected for offsite power components, and the initial set of components selected for cable analysis for the fire PRA.

Subsequent efforts were performed to analyze additional components, refine previously collected cable data and to revisit vintage data using modern criteria including proper polarity dc hot shorts.

CSB101 ANALYZE all electrical distribution Closed The analysis and review of Phase 1 Final Finding resolved by documentation This Finding was noted during the initial 1

(Finding) buses credited in the Fire PRA electrical overcurrent (reviewed (not met) update. No impact to NFPA805 Phase 1 Peer review. Cable selection plant response model for proper coordination and protection not met) analysis. elements were again reviewed by the Peer overcurrent coordination and has been initiated but is not Palisades has documented a review as part of the Phase 2 and Final protection and IDENTIFY any yet complete. The final complete breaker coordination Peer reviews, but this finding had not been additional circuits and cables analysis should address study for all buses considered in resolved. The breaker coordination study whose failure could challenge coordination for all Fire PRA the fire PRA as described in EA was subsequently completed and power supply availability due to electrical distribution buses. APR95004, Ref (9). modifications identified to resolve the inadequate electrical overcurrent Refer to F&O CSC401 for a finding.

protective device coordination related discussion on The following modifications will be performed to resolve the identified The finding was not fully resolved for the documentation of the Final Peer review, but was subsequently coordination and protection Electrical Coordination Challenges:

closed prior to the LAR submittal.

analysis. The circuit breakers in MCC 3 buckets (Breakers 52345 and 52325) will be replaced.

Replacement of, or supplement the overcurrent protection in DC distribution panels, 111, 112, 11A, 21 1, 212, and 21A utilizing fuses to assure coordination at higher fault currents.

Replacement of the fuses Page 6 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status currently installed in panels served by the Y01.

Adjustment of the breaker/relay settings in breakers 152201, 152115, 152108.

Plant modifications will address all buses where electrical coordination could not be demonstrated. No impact to NFPA 805 analysis.

CSC101 DOCUMENT the cable selection Open The cable selection and Phase 1 Phase 2/ Finding is open because although This finding was identified during the Phase (Finding) and location methodology location methodology is (reviewed Final the data verification is complete, 1Peer review. The CSC1 supporting applied in the Fire PRA in a documented in Section 4 not met) (not met) the results have not been fully requirement was subsequently reviewed manner that facilitates Fire PRA the Model Development implemented into the model used during both the Phase 2 and Final Peer applications, upgrades, and Peer Report (0247070005.03) for the LAR. review. This finding remains open as some review. and associated appendices. Section 4 of the Model minor numerical changes are anticipated The methodology for Development Report, Ref (3), has once the Fire PRA model is updated to completed work is been updated in a manner that utilize the full set of cable data maintained documented in a manner ensures consistent interpretation in just one location (SAFE).

consistent with this of Fire PRA applications.

supporting requirement; however, the methodology Additionally, the verification of for the supplemental cable Appendix R NonSafe Shutdown selection review Cable Routing to Support the Fire (Attachment 1) is not PRA has been separately formally documented in a documented in PLPRPT1200134, manner that ensures Ref (10).

consistent interpretation for Fire PRA applications and upgrades. Additionally, the sample cable routing verification check is not formally documented in the Page 7 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Fire PRA Report or any other plant document, and thus does not lend itself to consistent treatment for future Fire PRA applications and upgrades.

CSC201 DOCUMENT cable selection and Closed Appendix F of the Model Phase 1 Phase 2/ Suggestion resolved by This SR was categorized as Not Met by the (Suggestion) location results such that those Development Report (0247 (reviewed Final documentation update. No impact Phase 1 Peer review. The finding was results are traceable to plant 070005.03) documents the not met) (met) to NFPA805 analysis. revised to a Suggestion in the Final Peer source documents in a manner process by which the cable The sources of the cable data are review and subsequently resolved by that facilitates Fire PRA data was compiled and documented in the Fire PRA Model documentation provided in the Model applications, upgrades, and Peer organized for the PLP FPRA. Development Report, 024707 Development Report.

review. However, to facilitate FPRA 0005.03, Ref (03).

applications, upgrades, and Peer review, the consolidated cable dataset (combining the Nexus and SAFE databases) should be documented in such a format (including such information as cable ID, corresponding equipment ID, cable function, and cable fault consequences, etc.)

that provides endtoend data traceability.

CSC401 DOCUMENT the review of the Closed Unlike other elements of Phase 1 Phase 2/ Finding resolved by documentation A finding in this SR was identified during (Finding) electrical distribution system this Technical Element, the (reviewed Final update. No impact to NFPA805 the Phase 1Peer review. The CSC1 1

overcurrent coordination and Fire PRA Report does not not met) (not met) analysis. supporting requirement was subsequently protection analysis in a manner address the methodology, Palisades has documented a reviewed during both the Phase 2 and Final that facilitates Fire PRA process, or criteria for the complete breaker coordination Peer review.

applications, upgrades, and Peer electrical coordination and study for all buses considered in The finding was revised during the Phase 2 Page 8 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status review. protection analysis. This the fire PRA as described in EA Peer review, but remained open following information will need to be APR95004, Ref (9). the Final Peer reviews as the breaker co included in final documents ordination study was incomplete.

to satisfy this supporting Subsequently this study was completed requirement. and the finding resolved prior to the LAR submittal.

ESA201 REVIEW power supply, interlock Closed It is unclear at this point if Phase 1 Phase 2/ Finding resolved by documentation This SR was designated as not met in the (Finding) circuits, instrumentation, and all interlock / permissive (reviewed Final and model update. No impact to Phase 1 Peer review. The equipment 1

support system dependencies circuits which may lead to not met) (not met) NFPA805 analysis. selection (ES) element was fully reviewed and IDENTIFY additional specific consequential IEs A complete review of Safety during the Phase 2 Peer review and a equipment whose fireinduced have been properly Injection Signal (SIS), Containment limited scope review was performed during failure, including spurious captured for the functions High Pressure (CHP), Containment the Final Peer review.

actuation, could adversely affect being credited in the PRA. High Radiation (CHR), Containment The final report summary for the ES any of the equipment identified This may be particularly Isolation Signal (CIS) and element states:

per SR ESA1. important where the Recirculation Actuation Signal function credited in the Extensive modeling changes have been (RAS) logic was performed to made to explicitly represent both random Appendix R analysis is identify potential adverse different from the Fire PRA, and fire induced failures of interlock component actuations that could circuits, instrumentation and associated or auto actuation of the occur due to a spurious signal from component is required in power supplies. When this effort is any of these sources. complete the modeling of this aspect the PRA but not in Appendix R. Logic was added for 45 PRA should be among one of the most components to consider spurious comprehensive in the industry.

Need to document process operation from any of the The finding was not fully resolved for the by which all supporting automatic actuation circuits. Final Peer review, but was subsequently equipment and interlocks Report 0247070005.04, Ref (4), closed prior to the LAR submittal.

have been addressed. The was updated to reflect these PRA team appears to changes.

recognize this deficiency These logic changes were exists at present and have addressed prior to the conduct of plans in places to rectify Phase 2.

once all auto actuation modeling issues are resolved.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status ESA301 INCLUDE equipment whose fire Closed The review of initiating Phase 1 Phase 2/ Finding resolved by documentation This SR was designated as not met in the (Finding) induced failure, not including events considered in the (reviewed Final and model update. No impact to Phase 1 Peer review. The equipment 1

spurious operation, contributes internal events analysis is not met) (not met) NFPA805 analysis. selection (ES) element was fully reviewed to or causes described in Report 0247 Appendix B of Ref (3) was updated during the Phase 2 Peer review and a (a) fireinduced initiating events 070005. 03 Appendix B. A to provide additional detail as to limited scope review was performed during treated in the Fire Safe rationale for reexamining how initiating events were the Final Peer review.

Shutdown/Appendix R analysis the screening process to screened as to their applicability The finding was not fully resolved for the (b) Internal Events PRA initiators identify new IEs which may for fire scenarios. Final Peer review, but was subsequently as identified using the IE have been screened or closed by fully documenting consequential requirements in Part 2 (including subsumed in that analysis is The success criteria for consequential LOCA events and LOCA event development in the event tree any gradations across capability discussed. No new initiating and success criteria notebook prior to the categories in that standard) as events or additional their associated pathways and sizes were updated in Section 5.0 LAR submittal.

modified per 42.5, or equipment were identified.

(c) unique fireinduced initiating However, the review of notebook NBPSAETSC, Ref events not addressed or process undertaken is not (11). The updated notebook otherwise screened from the well documented. It is details consequential LOCA events above two analyses if SR IEC4 in unclear, e.g., if multiple that may result from fire including:

Part 2 cannot be met coincident pathways were multiple primary coolant pump addressed when identifying (PCP) seal failures, demands on the the size of LOCA that may pressurizer safety valves, and be induced by fire and any spurious operation of the reactor potential success criteria head vent and letdown isolation conflicts which may arise in valves. Additional detail was also the mapping of the fire added to report 0247070005.04, induced IE to the internal Ref (4), for the PCP seal failures events IE. (e.g. very small and chemical and volume control LOCA, Small LOCA vs. system (CVCS) pathways.

medium LOCA). (Note the The modeling approach for same concerns arise when containment isolation pathways addressing the screening was updated as described in process for Containment Attachment D of EAPSAFPIEFIRE isolation pathways where 1204, Ref (12). Consequential such pathways were ISLOCA events, potentially caused screened on the size of a by fire, are specifically addressed single pathway.) in the XFRISLOCA event tree described in Section 5.6 of NBPSA Page 10 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status ETSC, Ref (11).

ESA501 CONSIDER up to and including Closed A review of the MSO report Phase 1 Phase 2/ Finding resolved by documentation This SR was designated as not met in the (Finding) two spurious actuations of 024707000504 Appendix (reviewed Final and model update. No impact to Phase 1 Peer review. The equipment 1

equipment alone or in A found several deficiencies. not met) (not met) NFPA805 analysis. selection (ES) element was fully reviewed combination with other fire These are indicated below. The MSO expert panel was during the Phase 2 Peer review and a induced loss of function failures General: The MSO panel reconvened on 03/15/2011 at the limited scope review was performed during for the special case where fire was convened in 2008. Palisades site to address all the Final Peer review.

induced failures could contribute Westinghouse published the additions, deletions and/or The finding was not fully resolved for the not only to an initiating event but latest MSO report in April changes to the MSO assessment Final Peer review, but was subsequently also simultaneously either 2009 [WCAPNP16933]. that have occurred due to post closed by incorporating modeling logic and (a) affect the The current MSO reference expert panel reviews and in updating the MSO report prior to the LAR operability/functionality of that numbers and description in consideration of the most current submittal.

portion of the plant design to be Appendix A do not match information available from the credited in response to the the list in WCAPNP16933. PWROG Owners Group. The initiating event in the Fire PRA There are some new issues results of this expert panel review (b) result in an initiating event which are not covered by are documented in 024707 where the mitigating function is the current MSO panel 0005.04, Multiple Spurious not addressed in the Fire Safe report. Operations, Ref (4).

Shutdown/Appendix R Analysis or Suggest a final reconciliation (c) result in a loss of reactor of the MSO panel results PLP1, PLP2, and PLP3 were coolant system integrity [either with a new panel updated in report 024707 meeting or a rewrite of the 0005.04. Palisades PCP seal LOCA report] with WCAPNP model has been updated to be 16933. consistent with the latest industry PLP1, PLP2,PLP3: The guidance (WCAP15749P, Revision MSO descriptions in these 1, Guidance for the WCAP issues are intended Implementation of the CEOG for Westinghouse plants Model for Failure of RCP Seals which have 2 diverse Given Loss of Seal Cooling (Task methods of seal cooling. The 2083), Combustion Engineering MSO report states the issue Owners Group (CEOG), December is notapplicable to PLP. 2008). Further detail is provided in However, it is necessary to Appendix B of 0247070005.04.

ensure that all failure PLP10 was finalized as combinations of loss of CCW documented in 0247070005.04 Page 11 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status seal cooling are included for Section 5.10. The PRA model was PLP. updated to include spurious valve PLP10: Resolution not failures to address this MSO.

final.; PLP11 is correctly evaluated in PLP11: WCAP issue report 0247070005.04 Section misunderstood by MSO 5.11. The MSO panel correctly panel. Issue is for closure of understood the scenario.

both RWST suction valves Simultaneous spurious closure of and is applicable to PLP. CV3031 and CV3057 does not Simultaneous spurious isolate charging suction from the closure of CV3031 and SIRWT as the charging suction is CV3057 is this issue. ; from a separate nozzle. Closure of PLP12: Resolution not final these valves is addressed in MSO

scenarios which impact the engineered safeguards pumps.

PLP14: In WCAPNP16933, MSO scenario PLP10 considers issue 14 is applicable to spurious isolation of charging Palisades. Issue 14 is CHP pump suction valves, including runout when RCS is those which would isolate charging depressurized. Palisades from the SIRWT.

needs to look at pump runout possibility for all The resolution of MSO scenario ECCS, CCW, AFW, and SWS PLP12 was completed in Section pumps. ; 5.12 of 0247070005.04. Spurious closure of MO2087 due to fire was PLP18: Resolution for PLP added to the PRA model.

18 states RWST may drain, which is not considered in Evaluation of PLP14 was updated PRA. If RAS occurs and CV in Section 5.14 of 024707 3029 or CV03030 opens, 0005.04. The evaluation now RWST will not drain, describes how this scenario is because of check valve in addressed in the model.

sump line. Other MSO scenario PLP18 was updated.

possibilities involving The evaluation describes model deadhead / NPSH of ECCS changes incorporated to explicitly pumps are not explored. If address early drain down of the 3029/3030 open on a SIRWT in the PRA model and dead Page 12 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status spurious signal, heading of the ECCS pumps.

CV3031/CV3057 and PLP19 was finalized per Section CV3027/3056 will receive a 5.19 of 0247070005.04. This signal to close. Power is scenario involves early drain down disabled to 3027/3056. of the SIRWT via containment Scenarios for insufficient spray and is addressed in the NPSH include a) spurious SI; resolution to scenario PLP18.

b) opening of 3029/3030; c) closure of 3031/3057. Scenarios PLP27, PLP34, PLP35 Possibilities for ECCS were revised address affects other deadhead include: a) than cooldown due to a stuck open spurious SI; b) opening of atmospheric dump valve (ADV).

3029/3030; c) operator The direct effects of a blowdown mistakenly restores power of a steam generator are modeled to 3027/3056 [based on explicitly in the PRA in terms of the false instruments] resulting impact on steam supply to the in deadhead of ECCS pumps. turbine driven AFW pump. The resulting SI signal also has PLP19: Needs final potentially negative effects such as resolution; load shed of bus 1E and isolation of PLP27, PLP34,PLP35: MSO the noncritical service water states SGADV does not header (CV1359) and on the need to be included because shrink and swell of the PCS which overcooling is not an issue could result in a potential demand at Palisades. However, need on a pressurizer safety valve (ad to consider other affects of described in scenario PLP42).

SO ADV, which are: a) AFW Appendix F was added to 024707 pump runout; b) Faulted SG 0005.04 to evaluate the potential may be unsuitable for decay for AFW pump runout on spurious heat removal in the long full opening of the AFW flow term [i.e.., not able to raise control valves to a depressurized steam].; c) Heat removal is steam generator.

less than effective and Additional evaluation was condensate inventory performed to address MSO makeup is required. scenario PLP39 and added as PLP39: Need better reason Appendix G to 0247070005.04.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status to exclude blowdown valves This evaluation provides the basis as potential flow diversion for excluding the blowdown valves rates appear to be as a potential flow diversion path.

significant. ; Additional evaluation was PLP43: Resolution for performed to address MSO pressurizer spray valves scenario PLP43 and added as states that SO spray valve Appendix I to 0247070005.04.

would lead to loss of This evaluation provides the basis subcooling. Loss of for excluding spurious opening of subcooling will lead to SI the pressurizer spray valves from signal. Spurious spray valve the PRA model.

opening will lead to SI in [on It was validated that the fault tree the order of] 5 minutes. referred to in PLP45 is correctly Spray valve spurious should identified in the CAFTA model.

be included in Fire PRA as leading to SI signal. The resolution of PLP47 was PLP45: Basic events for finalized with the addition of pressurizer heaters could evaluations in Appendices N and O not be found in CAFTA as of 0247070005.04 to describe the indicated in the resolution; treatment of boron dilution events PLP47: Resolution not final. in the PRA.

PLP57 PLP58: Effect of MSO scenarios PLP57 and PLP58 spurious operation of load have been finalized and sequencers not evaluated. incorporated into the PRA model Possible scenarios include 1) as described in Sections 5.57 and failure of cable causes 5.58 of 0247070005.04.

spurious load shed on The evaluations for MSO scenarios operating bus, 2) failure of PLP60, PLP80, and PLP84 have cable causes load of DG on been finalized.

operating bus. The modeling approach for PLP60,PLP80,PLP84: Need containment isolation pathways final resolution. was updated as described in General: No indication of Attachment D of EAPSAFPIEFIRE search for containment 1204, Ref (12). Consequential isolation failure pathways ISLOCA and containment bypass Page 14 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status which can contribute to events, potentially caused by fire, LERF. are specifically addressed in the XFRISLOCA event tree described in Section 5.6 of NBPSAETSC, Ref (11)

ESC101 IDENTIFY instrumentation that is Closed Since the full complement of Phase 1 Phase 2/ Finding resolved by documentation This SR was designated as not met in the (Finding) relevant to the operator actions OMAs to be included in the (reviewed Final and model update. No impact to Phase 1 Peer review. The equipment 1

for which HFEs are defined or fire PRA has yet to be not met) (not met) NFPA805 analysis. selection (ES) element was fully reviewed modified to account for the identified instrument set is Instrumentation relevant to during the Phase 2 Peer review and a context of fire scenarios in the incomplete. operator actions in fire scenarios limited scope review was performed during Fire PRA, per SRs HRAB1 and were identified and validated by the Final Peer review.

HRAB2. completion of PostInitiator With respect to this SR the Final Peer Operator Action Questionnaires (P review report states:

IOAQ). The identification of instrumentation to A copy of the Human Failure Event support operator actions of omission, (HFE) PostInitiator Calculation (P carried over from the internal events PRA IC) and PIOAQ were provided to model, is complete and comprehensive.

current SRO licensed onshift While additional post fire recovery actions Operations Department personnel may be identified during the refinement of and Training Department the fire PRA model, it appears unlikely that personnel for use in validating HFE significant additional instrumentation will information accuracy. be needed to support these actions.

HFEs were assigned to Operations The finding was not fully resolved for the Department Operating Crews and Final Peer review, but was subsequently

/or Operations training personnel closed prior to the LAR submittal.

for review. Their reviews included ensuring indications, procedure selection and use, and activity performance manpower and timing is correct. Training personnel reviews included ensuring procedure selection and use were consistent with current training expectations, and the Page 15 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status training type and frequency are accurate.

The final set of operator manual actions (OMA), records of the current operating crews, and training personnel are provided in notebook NBPSAHR, Ref (13).

ESC201 IDENTIFY instrumentation Closed Instruments which provide Phase 1 Phase 2/ Finding resolved by documentation This SR was designated as not met in the (Finding) associated with each operator supporting cues for (reviewed Final and model update. No impact to Phase 1 Peer review. The equipment 1

action to be addressed, based on operator actions have been not met) (not met) NFPA805 analysis. selection (ES) element was fully reviewed the following: fireinduced failure identified and are being A simulator exercise was during the Phase 2 Peer review and a of any single instrument whereby explicitly modeled in the fire performed with current Palisades limited scope review was performed during one of the modes of failure to be PRA together with their license holders in which several the Final Peer review.

considered is spurious operation associated power supplies scenarios were evaluated to With respect to this SR the Final Peer of the instrument. and fire determine how Operators would review report states:

induced failure, including Undesired operator actions respond given spurious or false spurious indication, even if they potentially occurring as a Phase 2: The identification of operator instrument indications. The results actions of commission arising due to fire are not relevant to the HFEs for result of spurious plant of these exercises were considered which instrumentation is monitoring and alarm induced spurious alarms has not been in the HFE development process. completed as yet. While this is can be a identified within the scope instruments do not appear The process and evaluation results defined by ESC1, if the failure to have been addressed at fairly extensive effort very few alarms are documented in NBPSAHR, Ref typically remain unscreened and require could cause an undesired the present time. Neither (13).

operator action related to that has a process for identifying, explicit modeling.

portion of the plant design screening and modeling Final: Extensive effort has been conducted.

credited in the analysis. such occurrences been Documentation is progressing.

discussed. This should be The finding was not fully resolved for the addressed. Final Peer review, but was subsequently closed prior to the LAR submittal.

ESD101 DOCUMENT the identified Closed Plant specific validation of Phase 1 Phase 2/ Suggestion resolved by This SR was designated as not met in the (Suggestion) equipment in a manner that the rationale for excluding (reviewed Final documentation and model update. Phase 1 Peer review. The equipment 1

facilitates Fire PRA applications, fire induced failure of trip not met) (not met) No impact to NFPA805 analysis. selection (ES) element was fully reviewed upgrades, and Peer review and is should be provided under MSO Scenario PLP38 was revised during the Phase 2 Peer review and a sufficient to support the other limited scope review was performed during Page 16 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Fire PRA tasks so that MSO PLP38. as documented in Section 5.38 of the Final Peer review.

(a) it is clear which equipment 0247070005.04, Ref (4). The PRA The suggestion was not fully resolved for will be associated with model was updated to include the Final Peer review, but was determining initiating events in spurious operation of the AFW subsequently closed prior to the LAR the Fire PRA plant response pump low suction pressure trips. submittal.

model for the postulated fires (b) the equipment and its failures including spurious operation or indication can be modeled appropriately (c) cables associated with the equipment can be identified (d) failure modes of interest for the equipment are clear so as to support circuit analyses if required Justifications are provided with regard to equipment considered but screened out of the Fire PRA including when meeting SR ESA3 relevant to meeting SR IEC4 in Part 2 for initiating events, meeting SR ESB6 for the mitigating equipment to be credited in the Fire PRA, and using the "exception" under SR ESC2 for instrumentation considerations.

FQA401 QUANTIFY the fireinduced CDF Closed Many of the accident Phase 2 Final Finding resolved by documentation The fire risk quantification (FQ) element 1

(Finding) in accordance with HLRQUA and sequences involve a Fire (reviewed (not met) and model update. No impact to was reviewed in detail in both the Phase 2 its SRs in Part 2 with the initiator which goes straight not met) NFPA805 analysis. and Final Peer reviews.

following clarification: to core damage [i.e.., there Recovery actions and proposed The finding in this SR was provided during (a) quantification is to include the is no success path]. This modifications have been the Final Peer review.

fire ignition frequency (per the implies a single fire event incorporated into the final version IGN requirements) and fire can fail both trains of safe With respect to the FQ element the Final Page 17 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status specific conditional damage shutdown capability. The of the fire PRA model. The final report states:

probability factors (per the FSS CDF is too high to accept so model has no sequences with a Overall process is consistent with prevailing requirements) many individual sequences conditional core damage good practices. Results are not final and (b) QUA4 in Part 2 is to be met with no success path. There probability of 1. Results are thus certain SRs cannot be demonstrated based on meeting HLRHRAD in has not been sufficient described in Appendix B of 0247 to have been met. Continuing the 42.10 investigation done to 070005.01, Fire Risk refinement in process and planned provides and indicate whether recovery Quantification and Summary, Ref confidence this technical element will meet DEVELOP a defined basis to actions are truly not (1). the Standard.

support the claim of possible, or simply not nonapplicability of any of the modeled yet. The finding was not fully resolved for the requirements under HLRQUA in Final Peer review, but was subsequently Part 2. closed prior to the LAR submittal.

FQB101 PERFORM the quantification in Closed QUB3 requires Phase 1 Final Finding resolved by documentation The fire risk quantification (FQ) element (Finding) accordance with HLRQUB and demonstration of (met) (met) update. No impact to NFPA805 was reviewed in detail in both the Phase 2 its SRs in Part 2 acceptable truncation value analysis. and Final Peer reviews.

and by an iterative convergence The convergence process to The finding in this SR was initially noted DEVELOP a defined basis to process. The PLP fire PRA determine acceptable truncation during Final Peer review and subsequently support the claim of does not have this process. limits for the final fire PRA model resolved by documenting the convergence nonapplicability of any of the Although there is no were documented in Section 6 of process to determine acceptable requirements under HLRQUB in indication the current 0247070005.01, Ref (1). The truncation limits.

Part 2. truncation value is not truncation levels are based on acceptable, the convergence convergence calculations per the process exercise was not ASME PRA standard, which states done. that convergence can be considered sufficient when successive reductions in truncation value of one decade result in decreasing changes in CDF or LERF, and the final change is less than 5%.

FQC101 ADDRESS dependencies during Open PRA document NBPSAHR Phase 1 Final This finding is considered open The fire risk quantification (FQ) element (Finding) the Fire PRA plant response 1, Rev 3 provides an HEP (not (reviewed given that the procedure was reviewed in detail in both the Phase 2 model quantification in dependency analysis and reviewed) not met) development, modification and Final Peer reviews.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status accordance with HLRQUC and develops adjustment factors detailed development, and This finding remains open as detailed HEPs its SRs in Part 2 to apply to the cutsets. operations reviews are ongoing. cannot be developed until updated and Multiple HFE's are evaluated A dependency analysis was procedures and modification details are DEVELOP a defined basis to for dependencies using the completed to identify complete.

support the claim of EPRI HRA calculator. combinations of human failure nonapplicability of any of the Dependency adjustment events (HFEs) in which requirements under HLRQUC in factors are developed and dependencies between actions Part 2. applied in the cutsets. may contribute to an increase in However, the "Q" model core damage frequency (CDF)

[which was reviewed] does when compared to the CDF not incorporate this work. calculated when screening values Therefore the F&O and the for human error probabilities not met assessment. (HEPs) are used.

Dependencies between actions were assigned based on sequence specific evaluations of cues, timing, location, and available resources, and the HEPs adjusted if necessary to represent the level of dependence; the CDF was then recalculated using the modified HEPs. HFEs not explicitly evaluated for dependence were assigned HEPs of 1 (i.e., the represented operator actions are assumed to fail with a probability of unity), and thus the resulting CDF represents an upper bound for the potential impact of dependencies upon the results. Shared cues conservatively assumed 100% dependence. This approach has identified important HFEs for which the completion of detailed human reliability analyses may be beneficial.

Page 19 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status The fire PRA HRA dependency analysis is documented in NBPSA HR, Ref (13).

Screening values are still applied for fire HEPs pending development of final procedures, modifications, and operations reviews.

FQE101 IDENTIFY significant contributors Closed The discussion of dominant Phase 1 Final Finding resolved by documentation The fire risk quantification (FQ) element (Finding) in accordance with HLRQUD results is not presented in (not (reviewed update. No impact to NFPA805 was reviewed in detail in both the Phase 2 1

and HLRLEF and their SRs in Part the 0247070005.01. The reviewed) not met) analysis. and Final Peer reviews.

2 with the following clarifications: results are categorized and Section 6.0 of 0247070005.01, The finding was not fully resolved for the (a) SR QUD5a and QUD5b of sorted in terms of the Fire Risk Quantification and Final Peer review, but was subsequently Part 2 are to be met including dominant contributors [as Summary, Ref (1), was revised to closed prior to the LAR submittal.

identification of which fire per FQE1], but there is no include a discussion of the scenarios and which physical discussion as required by dominant results.

analysis units (consistent with the this SR.

level of resolution of the Fire PRA such as fire area or fire compartment) are significant contributors (b) SR QUD5b of Part 2 is to be met recognizing that "component" in Part 2 is generally equivalent to "equipment" in this Standard (c) SR QUD3 for comparison to similar plants is not applicable (d) SR LEF3 including the "Note" for that SR of Part 2 is to be met (1) following HLRQUD of Part 2 with the clarifications above concerning SRs QUD5a and QU D5b.

(2) but the uncertainty Page 20 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status requirement and reference to Table 22.76(e) in Part 2 does not apply here. See 42.13.

and DEVELOP a defined basis to support the claim of nonapplicability of any of the requirements under these sections in Part 2.

FSSA101 IDENTIFY all riskrelevant ignition Closed The treatment of MCC's is Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) sources, both fixed and transient, not properly justified. FSS (met) (met) update. No impact to NFPA805 scenario selection and analysis (FSS) in each unscreened physical document 0247070005.06 analysis. element was in progress. A detailed analysis unit within the global includes the statement "All Section 6.1 of 0247070005.06, assessment of the FSS supporting analysis boundary Motor Control Centers Ref (6), has been revised to include requirements was performed during the (MCC) have been treated as a reference to the walkdown Final Peer review.

closed, sealed and robust in information and photographs This finding was identified during the Final which damage beyond the which provide a basis for this Peer review and resolved by subsequent ignition source will not be statement. documentation update.

postulated." No documentation of From the Final Peer review summary:

inspections of the MCC's, Significant progress has been made in including the top of the support of the FSS technical elements cabinets have been (Mathcad, detailed analysis on areas such provided to justify not as PAU 4 (1C); documentation is in propagating fires outside progress). This progress allowed the peer the MCC. review team to conduct a review of the fire scenario selection analysis.

• All supporting requirements in FSS have been reviewed, which is evidence of all the work conducted over the last period.

• The inconsistencies identified in earlier reviews have been generally addressed.

• The comments generated from this Page 21 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status review are for the most part directed to individual SRs and should not impact the overall technical strategy currently in placed to meet the FSS requirements.

FSSA301 If the exact routing of a cable (or Closed The process of mapping and Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) group of cables) has not been accounting for targets in the (reviewed (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) established (see SRs CSA10 and Fire PRA is not documented. not met) analysis. element was in progress. A detailed CSA11), ASSUME that those Technical discussion during In the event that a cables plant assessment of the FSS supporting cables fail for any fire scenario the review period indicates location cannot be established, the requirements was performed during the that has a damaging effect on that targets with unknown process of crediting by assumed Final Peer review.

any raceway or conduit where routing are mapped to all routing was performed. The The finding was not fully resolved for the the subject cable might the scenarios within a PAU process involved determining, with Final Peer review, but was subsequently reasonably exist. unless it has been verified a high degree of confidence, closed prior to the LAR submittal.

that the target is not in a locations in the plant that do not specific scenario. However, contain the cable in question. This this process was not clearly is accomplished by considering the demonstrated during the likely routing of a cable and was review and is not performed by experienced plant documented in report 0247 personnel. In many cases, this 070005.06. assessment was made by grouping components into an appropriate surrogate category (as described in section 5.3 of the Model Development Report # 024707 0005.03, Ref (3)). The results of this detailed assessment are provided in Appendix I of the Model Development Report 0247 070005.03.

FSSB101 DEFINE and JUSTIFY the Open The current Fire PRA does Phase 1 Final Finding open. Control room During the Phase 2 review, work on the fire (Finding) conditions that are assumed to not consider abandonment (met) (not met) abandonment scenarios with scenario selection and analysis (FSS) cause MCR abandonment and/or of the main control room respect to environmental effects element was in progress. A detailed reliance on excontrol room due to lack of have been addressed. However, assessment of the FSS supporting Page 22 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status operator actions including equipment/control due to the current model does not requirements was performed during the remote and/or alternate fire damage. specifically identify scenarios that Final Peer review.

shutdown actions. result in abandonment due to Equipment damage leading to control equipment damage. room abandonment is addressed in the Fire PRA model; however, this finding remains open pending formal development of the list of equipment whose fire induced damage could cause control room abandonment. The model includes logic at the component level for operation of key equipment outside of the control room as prescribed for control room abandonment such as local operation of equipment at EC 150, and for other local actions such as local control of P8B. These sequences are evaluated for all scenarios, not only scenarios where the control room abandonment event tree is employed (control room evacuation due to smoke or high temperature).

FSSB201 SELECT one or more fire Closed The CCDP quantification Phase 1 Final Finding resolved by documentation A finding was identified during the initial 1

(Finding) scenarios, either in the MCR or does not reflect the human (reviewed (not met) and model update. No impact to Peer review and modified as part of the elsewhere, leading to MCR error probabilities met) NFPA805 analysis. Final Peer review. As indicated the abandonment and/or a reliance associated with control Main Control room abandonment identified issue was corrected. This is on excontrol room operator room abandonment and the scenarios have been postulated consistent with the Peer review team final actions including remote and/or fire impacted cables may based on damage to equipment assessment for FSS which indicated:

alternate shutdown actions, not reflect the and controls. Postulated fires in The comments generated from this review consisting of a combination of an equipment/control that may the Control Room (CR) have the are for the most part directed toward ignition source (or group of or may not be available potential to challenge habitability individual SRs and should not impact the ignition sources), such that the after abandonment. or visibility due to smoke overall technical strategy currently in place selected scenarios provide generation or excessive heat. An to meet the FSS requirements.

reasonable assurance that the abandonment analysis MCR abandonment fire risk The specific concern cited by the peer (Attachment 1 of 0247070005.06, Page 23 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status contribution can be realistically Ref (6)) was performed to review team during the review was that characterized. determine the response of the CR only individual cabinet failures were envelope given a range of possible considered for control room abandonment fire events. The analysis scenarios. The revised treatment considered three different considers three multiple cabinet failure operating states of the CR groups which when combined encompass mechanical ventilation system and all the cabinets in the control room.

three different configurations of The quantification for these three the CR Door. Based on this scenarios reflect the human error assessment, three scenarios, each probabilities associated with control room involving multiple cabinets, were abandonment and the fire impacted cables implemented into the model. that are not available after abandonment.

Human actions that could not be performed prior to the time control room abandonment was necessary were considered failed.

FSSC301 JUSTIFY the heat release rate Closed The supporting requirement Phase 1 Final Suggestion resolved by During Phase 1 fire burnout times appear (Suggestion) profile stages included in the states that the growth (reviewed (met) documentation update. No impact not to be a factor affecting the analysis analysis (i.e., fire growth, steady stages included in the as not to NFPA805 analysis results.

burning, or decay stages). analysis should be justified. applicable) The Model Development Report, Subsequent to the Phase 1 review, the fire The justification is not Ref (3), was revised to include a growth stages were applied in the analysis.

included in the discussion of the treatment for the documentation. Hence, the Phase 1 not applicable growth stages of a fires heat determination changed to a met, release rate. satisfying capability category II/III.

This suggestion was closed prior to the LAR submittal.

FSSC401 If a severity factor is credited in Closed The severity factor for Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) the analysis, ENSURE that hotwork fires of 0.01 is not (reviewed (met) and model update. No impact to scenario selection and analysis (FSS)

(a) the severity factor remains properly justified. The not met) NFPA805 analysis. element was in progress. A detailed independent of other documentation does not The 0.01 severity factor for assessment of the FSS supporting quantification factors provide a description how hotwork is no longer applied in requirements was performed during the Page 24 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status (b) the severity factor reflects the the value was calculated final fire PRA model. Severity Final Peer review.

fire event set used to estimate and an explanation of why factors are now based on This finding was identified during the Final fire frequency the value remains NUREG/CR6850. Section 8.3 of Peer review and resolved by subsequent (c) the severity factor reflects the independent of the generic 0247070005.06, Ref (6), was documentation and model update.

conditions and assumptions of ignition frequency. updated to reflect this change.

the specific fire scenarios under analysis, and (d) a technical basis supporting the severity factors determination is provided FSSC501 JUSTIFY that the damage criteria Closed No scenario is evaluated for Phase 1 Final Finding resolved by documentation This finding was identified during the Final (Finding) used in the Fire PRA are conditions where the target (reviewed (met) update. No impact to NFPA805 Peer review. As indicated the identified representative of the damage damage criteria is that of met) analysis. issue was corrected. This is consistent targets associated with each fire sensitive electronics. Section 5.2 of 0247070005.06, with the Peer review team final Ref (6), was revised to provide assessment for FSS which indicated:

further basis for excluding The comments generated from this review scenarios with the sensitive are for the most part directed toward electronics criteria. The exclusion individual SRs and should not impact the is based primarily on physical overall technical strategy currently in place cabinet distances from fire ignition to meet the FSS requirements.

sources and that these targets are generally within an enclosure that provides some protection from the heat source.

FSSC701 If multiple suppression paths are Closed No evaluation of Phase 1 Final Finding resolved by documentation Suppression capabilities were initially not 1

(Finding) credited, EVALUATE and independence of (reviewed (not met) update. No impact to NFPA805 credited.

PROPERLY MODEL dependencies suppression paths has been as not analysis. Subsequent analysis identified the among the credited paths included in the analysis. applicable) Section 10.1 of 0247070005.06, treatment of dependence between including dependencies Fire Scenario Development, Ref suppression paths in the scenario associated with recovery of a (6), was revised to describe the suppression event tree as described in the failed fire suppression system, if treatment of dependence between disposition column.

such recovery is credited. suppression paths in the scenario The finding was not fully resolved for the Page 25 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status suppression event tree. Final Peer review, but was subsequently closed prior to the LAR submittal.

FSSC801 If raceway fire wraps are Closed The report does not discuss Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) credited, the treatment of fire (reviewed (not met) update. No impact to NFPA805 scenario selection and analysis (FSS)

(a) ESTABLISH a technical basis barriers credited in the as not analysis. element was in progress. A detailed for their fireresistance rating, analysis. applicable) Documentation was added to assessment of the FSS supporting and Section 2.2 of report 024707 requirements was performed during the (b) CONFIRM that the fire wrap 0005.02, Ref (2), which discusses Final Peer review.

will not be subject to either the treatment of fire barriers The finding was not fully resolved for the mechanical damage or direct credited in the analysis. Credit for Final Peer review, but was subsequently flame impingement from a high raceway fire barriers, thermal closed prior to the LAR submittal.

hazard ignition source unless the wraps or other localized protection wrap has been subject to features have not been credited in qualification or other proof of identifying a physical analysis unit.

performance testing under these conditions. Additionally, as can be noted in the Fire Scenario Development Report (0247070005.06, Ref (6)), no credit is taken for the presence of raceway fire wraps.

FSSD101 SELECT appropriate fire modeling Closed Although in general Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) tools for estimating fire growth appropriate fire models (reviewed (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) and damage behavior considering have been selected, the met) analysis. element was in progress. A detailed the physical behaviors relevant to justification for the use of Appendix E of 0247070005.06, assessment of the FSS supporting the selected fire scenarios. the selected tools needs to Fire Scenario Development, Ref requirements was performed during the be improved. This finding is (6), was updated to include further Final Peer review.

specifically applicable to the discussion on the applicability of The finding was not fully resolved for the use of the time to damage the MathCAD tool for calculation Final Peer review, but was subsequently models programmed in of the nonsuppression probability. closed prior to the LAR submittal.

MathCAD, which are calculations that have not been documented and Page 26 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status reviewed by the industry.

FSSD201 USE fire models that have Closed No fire detection analysis Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) sufficient capability to model the has been conducted in (reviewed (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) conditions of interest and only support of the activation of met) analysis. element was in progress. A detailed within known limits of fixed suppression systems or Section 10.1 of 0247070005.06, assessment of the FSS supporting applicability the time to smoke Fire Scenario Development, Ref requirements was performed during the detection. (6), was revised to describe the Final Peer review.

treatment of automatic The finding was not fully resolved for the suppression system activation Final Peer review, but was subsequently times on the suppression closed prior to the LAR submittal.

probability.

FSSD401 ESTABLISH a technical basis for Closed This finding is associated Phase 1 Final Finding resolved by documentation This finding was identified during the Final (Finding) fire modeling tool input values with treatment of transient (reviewed (met) update. No impact to NFPA805 Peer review. As indicated the identified used in the analysis given the fires. 1) Fire elevation for met) analysis. issue was corrected. This is consistent context of the fire scenarios transient fires has been Section 7.0 of 0247070005.06, with the Peer review team final being analyzed. assumed to be on the floor. Fire Scenario Development, Ref assessment for FSS which indicated:

2) the heat release rate for (6), was revised to describe the The comments generated from this review transient fires have been treatment of fire elevation and are for the most part directed toward assumed to be characterized heat release rate for transient individual SRs and should not impact the by electric motor fires. fires. The transient heat release overall technical strategy currently in place These are important input rate was increased to 317 kW; 98th to meet the FSS requirements.

values for determining zone percentile heat release rate for of influence. transient combustibles, in lieu of the value for electric motor fires.

FSSD701 In crediting fire detection and Closed Items a, b, and c in the Cat II Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) suppression systems, USE generic requirement are not (reviewed (met) update. No impact to NFPA805 scenario selection and analysis (FSS) estimates of total system explicitly address in the met CC I) analysis. element was in progress. A detailed unavailability provided that analysis. Section 10.1 of 0247070005.06, assessment of the FSS supporting (a) the credited system is Fire Scenario Development, Ref requirements was performed during the installed and maintained in (6), was revised to describe the Final Peer review.

accordance with applicable codes basis for availability of automatic This finding was identified during the Final Page 27 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status and standards suppression systems and the Peer review and resolved by subsequent (b) the credited system is in a impact on suppression probability, documentation update.

fully operable state during including a discussion of outlier plant operation, and behavior.

(c) the system has not experienced outlier behavior relative to system unavailability FSSD801 INCLUDE an assessment of fire Closed The Fire PRA currently does Phase Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) detection and suppression not include an assessment 1(reviewed (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) systems effectiveness in the of the effectiveness of the not analysis. element was in progress. A detailed context of each fire scenario fire suppression and applicable) Section 10.1 of 0247070005.06, assessment of the FSS supporting analyzed. detection systems credited Fire Scenario Development, Ref requirements was performed during the in the analysis. (6), was revised to provide an Final Peer review.

assessment of the effectiveness of The finding was not fully resolved for the automatic suppression systems Final Peer review, but was subsequently and the impact on suppression closed prior to the LAR submittal.

probability.

FSSE301 PROVIDE a mean value of, and Open A qualitative Phase 1 Final Finding open as the During the Phase 2 review, work on the fire (Finding) statistical representation of, the characterization of the (reviewed (not met) characterization has not been scenario selection and analysis (FSS) uncertainty intervals for the parameters used in the fire met CC I) completed. No impact to NFPA element was in progress. A detailed parameters used for modeling modeling in significant fire 805 analysis as the results are assessment of the FSS supporting the significant fire scenarios. scenarios have not been based on the point estimate values requirements was performed during the completed as the Fire PRA which approximate the mean Final Peer review.

still needs detailed analysis values. This finding was identified during the Final to reduce the plant CDF. A characterization of the Peer review and remains open, but as The qualitative discussion parameters used in the fire indicated this finding does not impact the required to meet category 1 modeling in significant fire point estimate values used in the NFPA 805 should be completed once scenarios has not been completed. analysis.

key scenarios are identified. However, it is not expected that refinement of the parameter uncertainty intervals will impact the fire PRA conclusions.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status FSSF101 DETERMINE if any locations Closed The report 024707 Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) within the Fire PRA global 0005.08, which documents (reviewed (met) update. No impact to NFPA805 scenario selection and analysis (FSS) analysis boundary meet both of structural steel analysis, not met) analysis. element was in progress. A detailed the following two conditions: (a) does not describe what is a The definition of a significant fire assessment of the FSS supporting exposed structural steel is "high hazard fire". hazard was added to Section 2.0 of requirements was performed during the present (b) a highhazard fire Consequently, it is not clear the Exposed Structural Steel Final Peer review.

source is present in that location what specific fires where Analysis Report, 0247070005.08, The finding was not fully resolved for the and If such locations are considered as high hazard Ref (8): The following details have Final Peer review, but was subsequently identified, SELECT one or more during the walkdowns and been added to the to the report, closed prior to the LAR submittal.

fire scenario(s) that could analysis to conclude that a For the purposes of this analysis, damage, including collapse, the scenario should be a significant fire hazard was exposed structural steel for each quantified in the analysis. defined as having at least the same identified location. or greater combustible loading equivalent to 50 gallons of fuel oil, which is in excess of a heat value of 7E+6 BTU [5].

FSSF201 If, per SR FSSF1, one or more Closed The criteria for identifying Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) scenarios are selected, and analyzing fire scenarios (reviewed (met) update. No impact to NFPA805 scenario selection and analysis (FSS)

ESTABLISH and JUSTIFY criteria associated with damage to met CC I) analysis. element was in progress. A detailed for structural collapse due to fire structural steel is not clearly The appropriate criteria for fire assessment of the FSS supporting exposure. documented. The criteria damage to structural steel were requirements was performed during the utilized has been inferred added to Section 3.0 of the, Final Peer review.

from the analysis and is Exposed Structural Steel Analysis The finding was not fully resolved for the considered appropriate. Report, 0247070005.08, Ref (8). Final Peer review, but was subsequently The criteria includes 1) The following criteria guidelines closed prior to the LAR submittal.

possibility of a high hazard have been added to 1) Presence fire, 2) exposed structural of significant fire hazard (Section steel, and 3) a steel 2.0), 2) Presence of exposed temperature of 1000 F. structural steel, 3) Steel Surface temperature in excess of 1000°F for fire configuration to clearly document the criteria used for Page 29 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status identifying and analyzing fire scenarios associated with structural steel damage. The one thousand degree criteria is consistent with the statement provided in Reference 2 of the Structural Steel Analysis from NIST, Fire Protection of Structural Steel in High - Rise Buildings..

FSSF301 If, per SR FSSF1, one or more Closed The four scenarios selected Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) scenarios are selected, for evaluation have been (reviewed (met) update. No impact to NFPA805 scenario selection and analysis (FSS)

COMPLETE a quantitative screened and therefore not not met) analysis. element was in progress. A detailed assessment of the risk of the included in the CDF Section 3.2.2 of the Structural Steel assessment of the FSS supporting selected fire scenarios in a calculation for the plant. Analysis Report, Ref (8), was requirements was performed during the manner consistent with the FQ The screening process for revised using the frequencies Final Peer review.

requirements, including collapse one of the scenarios is found in NUREG/CR6850 (Vol. 2) The finding was not fully resolved for the of the exposed structural steel. based on the frequency of and EPRI TR 1016735 to calculate a Final Peer review, but was subsequently such an event (PAU23, new turbinegenerator closed prior to the LAR submittal.

turbine generator fire). The catastrophic fire frequency of calculated frequency is not 3.13E6 /yr and 1.59E6 /yr, based on fire ignition respectively. Site Specific frequencies documented in frequencies documents in the FIF current Fire PRA EPRI and Plant Partitioning Report 0247 guidance. 070005.02, Ref (2), were implemented in the quantitative assessment of the FPRA.

Quantitative calculations and factors applied are also documented in section 3.2.2 of the Structural Steel Report.

FSSG201 DEFINE screening criteria for Closed Elements of the qualitative Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) multicompartment fire scenarios criteria require further (not (met) update. No impact to NFPA805 scenario selection and analysis (FSS) that provide reasonable evaluation. Specifically, reviewed) analysis. element was in progress. A detailed Page 30 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status assurance that the contribution "exposing PAU is outdoors; The screening criteria in Table 31 assessment of the FSS supporting of the screened physical analysis no HGL postulated" and of 0247070005.07, Multi requirements was performed during the unit combinations are of low risk "exposed PAU has a Compartment Analysis, Ref (7), Final Peer review.

significance. sufficient volume that any were revised to add discussion of The finding was not fully resolved for the hot gases that may enter outdoor transformers near turbine Final Peer review, but was subsequently PAU building walls and hot gas layer. A closed prior to the LAR submittal.

would dissipate before quantitative definition for significant damage would sufficient volume was also occur." In the former, the provided. This latter criterion is qualitative assessment only applied in two areas where it should include a discussion was subsequently verified that a of yard transformer fires hot gas layer could not form in less near turbine building walls. than 60 minutes.

In the later, assessment of hot gas layer conditions should be quantitatively addressed.

FSSG202 DEFINE screening criteria for Closed The quantitative screening Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) multicompartment fire scenarios criteria do not include (not (met) update. No impact to NFPA805 scenario selection and analysis (FSS) that provide reasonable consideration for the reviewed) analysis. element was in progress. A detailed assurance that the contribution cumulative risk screened Revised Section 3.5 of 024707 assessment of the FSS supporting of the screened physical analysis out due to multi 0005.07, MultiCompartment requirements was performed during the unit combinations are of low risk compartment combinations. Analysis, Ref (7), to describe the Final Peer review.

significance. Currently, multi cumulative impact of CDF The finding was not fully resolved for the compartments are screened screening at 1E7. The total CDF Final Peer review, but was subsequently at a threshold of 1E7, but impact from the screened areas is closed prior to the LAR submittal.

there is no verification of also less than 1E7/yr.

the cumulative risk screened.

FSSG401 If passive fire barriers with a fire Closed The SR requires Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) resistance rating are credited in confirmation of allowed (not (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) the Fire PRA credit, assessment of reviewed) analysis. element was in progress. A detailed (a) CONFIRM that the allowed effectiveness and reliability, Revised Appendix A of 024707 assessment of the FSS supporting Page 31 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status credit is consistent with the fire and evaluation of random 0005.07, Ref (7), to describe the requirements was performed during the resistance rating as failures of passive barriers. applicability and basis for the Final Peer review.

demonstrated by conformance to No analysis has been random failure probability of The finding was not fully resolved for the applicable test standards presented or documented passive fire barriers from Final Peer review, but was subsequently (b) ASSESS the effectiveness addressing these NUREG/CR6850 used in the multi closed prior to the LAR submittal.

reliability, and availability of any requirements. compartment analysis.

passive fire barrier feature credited, and (c) EVALUATE the potential for fireinduced or random failure of credited passive fire barrier features FSSG501 For any scenario selected per Closed The SR requires Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire 1

(Finding) FSSG3, if the adjoining physical quantification of (not (not met) update. No impact to NFPA805 scenario selection and analysis (FSS) analysis units are separated by effectiveness, reliability and reviewed) analysis. element was in progress. A detailed active fire barrier elements, availability of the active fire Revised Appendix A of 024707 assessment of the FSS supporting QUANTIFY the effectiveness, barriers. No analysis has 0005.07, Ref (7), to describe the requirements was performed during the reliability, and availability of the been presented or applicability and basis for the Final Peer review.

active fire barrier element. documented addressing random failure probability of active The finding was not fully resolved for the these requirements in fire barriers from NUREG/CR6850 Final Peer review, but was subsequently addition of using the generic used in the multicompartment closed prior to the LAR submittal.

values in NUREG/CR6850. analysis (MCA). Table 34 of this document reflects the quantification of MCA interaction failures.

FSSG601 QUANTIFY the risk contribution Closed LERF results are not Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Suggestion) of any selected reported in the multi (not (met) update. No impact to NFPA805 scenario selection and analysis (FSS) multicompartment fire scenarios compartment analysis reviewed) analysis. element was in progress. A detailed in a manner consistent with the report, but they have been Updated report 0247070005.07, assessment of the FSS supporting FQ requirements. calculated. Ref (7), to report the LERF results requirements was performed during the from the final fire PRA model in Final Peer review.

Section 4.0 of the multi The suggestion was not fully resolved for the Final Peer review, but was Page 32 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status compartment analysis. subsequently closed prior to the LAR submittal.

FSSH201 DOCUMENT a basis for target Closed The treatment of hydrogen Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the fire (Finding) damage mechanisms and fires is incorrectly (met CC I) (met) update. No impact to NFPA805 scenario selection and analysis (FSS) thresholds used in the analysis, documented in report 0247 analysis. element was in progress. A detailed including references for any 070005.06. The documentation for treatment assessment of the FSS supporting plantspecific or targetspecific of hydrogen fires in report 0247 requirements was performed during the performance criteria applied in 070005.06, Ref (6), was updated Final Peer review.

the analysis. to be consistent with approach The finding was closed to meet CC II prior applied in the fire model which to the LAR submittal.

complies with Appendix N of NUREG/CR6850.

FSSH501 DOCUMENT fire modeling output Closed The Fire PRA is in process. Phase 1 Final Finding resolved by documentation This finding was identified during the Final (Finding) results for each analyzed fire Fire modeling results are not (met) (met) update. No impact to NFPA805 Peer review because additional scenario, including the results of complete. Documentation analysis. refinements were still anticipated following parameter uncertainty of output results should be The final fire modeling output the Final Peer review. As indicated by the evaluations (as performed) in a consistent with current results for each analyzed fire met status, however, the format of the manner that facilitates Fire PRA approach for scenarios scenario were documented in existing results discussion was acceptable.

applications, upgrades, and Peer analyzed while the fire PRA Section 6.0 of report 024707 review. is completed. 0005.01, Ref (1). Additionally, Section 7.1 of Ref (1) was revised to include a statistical representation of the uncertainty intervals used for modeling the significant fire scenarios from the final fire PRA model.

FSSH901 DOCUMENT key sources of Closed Sources of uncertainty in Phase 1 Final Finding resolved by documentation This supporting requirement was not 1

(Finding) uncertainty for the FSS technical the fire modeling analysis (not (not met) update. No impact to NFPA805 reviewed during the Phase 1 Peer review element. are not documented in reviewed) analysis. as the model progress was not sufficiently 0247070005.06. Sources of uncertainty in the fire complete. This finding was identified scenario selection process were during the Final Peer review, but was Page 33 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status documented in report 024707 subsequently addressed prior to the LAR 0005.01, Fire Risk Quantification submittal.

and Summary, Ref (1).

HRAA201 For each fire scenario, IDENTIFY Closed The identification of fire Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the (Finding) any new firespecific safe response actions is not yet (reviewed (met) and model update. No impact to human reliability analysis (HRA) element shutdown actions called out in complete. Additional fire not met) NFPA805 analysis. was in progress. A detailed assessment of the plant fire response safe shutdown actions are The final identification of fire the HRA supporting requirements was procedures (e.g., deenergizing still being identified as the response actions was completed performed during the Final Peer review.

equipment per a fire procedure Fire PRA analysis continues and documented in notebook NB The Final Peer review summary report for a specific fire location) in a to be refined. PSAHR1, Ref (13). These actions noted:

manner consistent with the were incorporated into the final scope of selected equipment The review did not identify issues with the fire PRA model where appropriate. fundamental approaches being used [for]

from the ES and PRM elements of this Standard, the completed portion of the HRA and in accordance with HLRHRE assessment.

and its SRs in Part 2 with the following clarifications:

(a) where SR HRE1 discusses procedures, this is to be extended to procedures for responding to fires (b) where SR HRE1 mentions "in the context of the accident scenarios," specific attention is to be given to the fact that these are fire scenarios (c) another source for SR HRE1 is likely to be the current Fire Safe Shutdown/Appendix R analysis and DEVELOP a defined basis to support the claim of nonapplicability of any of the requirements under HLRHRE in Page 34 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Part 2.

HRAA301 For each fire scenario, IDENTIFY Closed Section 6.3 of the HRA Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the 1

(Finding) any new, undesired operator Notebook discusses the (met CC I) (met CC I) and model update. No impact to human reliability analysis (HRA) element action that could result from review that was performed NFPA805 analysis. was in progress. A detailed assessment of spurious indications resulting with the licensed operators A simulator exercise was the HRA supporting requirements was from failure of a single for the identification of the performed with current Palisades performed during the Final Peer review.

instrument, per SR ESC2 (e.g., new, undesired operator license holders in which several The Final Peer review summary report due to verbatim compliance with actions in response to scenarios were evaluated to noted:

the instruction in an alarm spurious indications. determine how Operators would response procedure, when However, the detailed The review did not identify issues with the respond given spurious or false fundamental approaches being used [for]

separate confirmation is not documentation for the instrument indications. The results available or required). evaluation process and the the completed portion of the HRA of these exercises were considered assessment.

justifications for the in the HFE development process.

conclusion that no The process and evaluation results The finding was not fully resolved for the undesired operator actions are documented in NBPSAHR, Ref Final Peer review, but was subsequently will be taken in these (13). closed prior to the LAR submittal.

instrumentation failure conditions was not yet completed for the reviewers to confirm the conclusion that no undesired operator actions need to be considered.

HRAA401 TALK THROUGH (i.e., review in Open As the fire scenario Phase 1 Final Finding open, given that the During the Phase 2 review, work on the (Finding) detail) with plant operations and refinement continues, (reviewed (not met) procedures, modification detail, human reliability analysis (HRA) element training personnel the additional fire response not met) operations review, and detailed was in progress. A detailed assessment of procedures and sequence of actions will be identified and HRA model development are not the HRA supporting requirements was events to confirm that evaluated, which will yet complete. performed during the Final Peer review.

interpretation of the procedures require the performance of A copy of the Human Failure Event The Final Peer review summary report relevant to actions identified in additional operator (HFE) PostInitiator Calculation (P noted:

SRs HRAA1, HRAA2, and HRAA3 interviews. As such, this task IC) and associated PostInitiator is consistent with plant is not fully completed yet. The review did not identify issues with the Operator Action Questionnaire (P fundamental approaches being used [for]

operational and training Also, operator interviews for IOAQ) were provided to current the completed portion of the HRA Page 35 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status practices. those fire response actions SRO licensed onshift Operations assessment.

that are still using screening Department personnel and This finding remains open as indicated in values (e.g., ACPDGOTB5B Training Department personnel for the Disposition column.

DG, ACPPMOE38311A, use in validating HEP information ACPPMOE38312A, AFW accuracy.

PMOAP8BCRAB, etc.) may HFEs were assigned to Operations not have been completed. Department Operating Crews and

/or Operations training personnel (Note: Specific HEP basic for review. Their reviews included event identifiers cited by the ensuring indications, procedure Peer review team may have selection and use, and activity been subsequently renamed performance manpower and or removed from the model timing is correct. Training as part of the F&O personnel reviews included resolution process.) ensuring procedure selection and use were consistent with current training expectations, and the training type and frequency are accurate.

Operator comments were reviewed and discussed with PRA personnel and proposed resolutions forwarded to the comment initiator for further comment or acceptance. Comment acceptance is documented by their initialing the HFE Validation form.

Significant HFEs were evaluated and developed in further detail.

Screening values are still applied for fire HEPs pending development of final procedures, modifications, and operations reviews.

The records of the current operating crews and training Page 36 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status personnel are provided in notebook NBPSAHR, Ref (13).

HRAB201 INCLUDE new firerelated safe Closed Identification of new, fire Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the 1

(Finding) shutdown HFEs corresponding to response actions and (reviewed (not met) and model update. No impact to human reliability analysis (HRA) element the actions identified per SR HRA incorporation of the not met) NFPA805 analysis. was in progress. A detailed assessment of A2 in the Fire PRA plant response identified fire response The final identification of fire the HRA supporting requirements was model in a manner consistent actions into the Fire PRA response actions was completed performed during the Final Peer review.

with 42.2 and Section 42 and in model are not completed. and documented in notebook NB The Final Peer review summary report accordance with HLRHRF and its PSAHR1, Ref (13). These actions noted:

SRs in Part 2 and were incorporated into the final DEVELOP a defined basis to The review did not identify issues with the fire PRA model where appropriate. fundamental approaches being used [for]

support the claim of nonapplicability of any of the the completed portion of the HRA requirements under HLRHRF in assessment.

Part 2. The finding was not fully resolved for the Final Peer review, but was subsequently closed prior to the LAR submittal.

HRAB301 COMPLETE the definition of the Open The impact of loss of all Phase 1 Final Finding open, given that the During the Phase 2 review, work on the (Finding) HFEs identified in SRs HRAB1 redundant/diverse (reviewed (not met) procedures, modification detail, human reliability analysis (HRA) element and HRAB2 by specifying the instrumentation on HEPs not met) operations review, and detailed was in progress. A detailed assessment of following, taking into account the has been modeled by ORing HRA model development are not the HRA supporting requirements was context presented by the fire the instrumentation logic yet complete. performed during the Final Peer review.

scenarios in the Fire PRA: with its associated HEP. The simulator exercise performed The Final Peer review summary report (a) accident sequence specific Thus, in cases where total with current Palisades license noted:

timing of cues, and time window instrument failure (by holders evaluated operator for successful completion hardware fault or fire) The review did not identify issues with the response to several scenarios with fundamental approaches being used [for]

(b) accident sequence specific occurs (including the failure false, partial or total loss of procedural guidance (e.g., AOPs, of the only instrument the completed portion of the HRA instrument indications. The results assessment.

EOPs) available), the HEP is of these exercises were considered (c) the availability of cues or appropriately failed. in the HFE development process This finding remains open as indicated in other indications for detection However, the failure impact for purposes of developing timing the Disposition column.

and evaluation errors of partial instrumentation of cues and time windows.

(d) the specific highlevel tasks on an HEP has not yet been The final developed fire HFEs Page 37 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status (e.g., trainlevel) required to implemented. There are incorporate task complexity and achieve the goal of the response. cases in the model where procedural guidance as multiple instruments documented in the PostInitiator provide cues to the Operator Action Questionnaire (P operators to perform IOAQ) provided to current SRO actions. Operator actions licensed onshift Operations based on false indication Department personnel and have not been considered. Training Department personnel for In addition, HFEs modeled use in validating HFE information using screening values (for accuracy.

some of the fire response Significant HFEs were evaluated actions identified; e.g., ACP and developed in further detail.

DGOTB5BDG, FPSPMOE Screening values are still applied STARTL, ACPPMOE383 for fire HEPs pending development 12A, ACPPMOE38311A, of final procedures, modifications, etc.) and those fire response and operations reviews.

actions that will be identified as the fire The final list of fire HFEs and their scenario refinement associated documentation are continues have not yet provided in NBPSAHR, Ref (13).

accounted for the scenario context including timing, procedural guidance, instrumentation, task complexity, etc. Also, HRA Calculator evaluation sheets cannot be located for PCP PMOFP50XLOC and EDG PMOEPORTPUMP, and AFWAVOACV2010D, SWSAVOACV082326, and SWSAVOBCV082447M still need to be modified for fire related conditions.

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status HRAC101 For each selected fire scenario, Open Fire response HFEs modeled Phase 1 Final Finding open, given that the During the Phase 2 review, work on the (Finding) QUANTIFY the HEPs for all HFEs with screening values have (reviewed (met CC I) procedures, modification detail, human reliability analysis (HRA) element and ACCOUNT FOR relevant fire not yet been evaluated in a not met) operations review, and detailed was in progress. A detailed assessment of related effects using detailed manner accounting for HRA model development are not the HRA supporting requirements was analyses for significant HFEs and relevant PSFs (e.g., ACP yet complete. performed during the Final Peer review.

conservative estimates (e.g., DGOTB5BDG, FPSPMOE Significant HFEs were evaluated The Final Peer review summary report screening values) for STARTL, ACPPMOE383 and developed in further detail as noted:

nonsignificant HFEs, in 11A, ACPPMOE38312A, documented in NBPSAHR, Ref accordance with the SRs for HLR etc.). Also, HRA Calculator The review did not identify issues with the (13). Screening values are still fundamental approaches being used [for]

HRG in Part 2 set forth under at evaluation sheet cannot be applied for fire HEPs pending least Capability Category II, with located for PCPPMOFP the completed portion of the HRA development of final procedures, assessment.

the following clarification: 50XLOC and EDGPMOE modifications, and operations (a) Attention is to be given to PORTPUMP, and AFW reviews. This finding remains open as indicated in how the fire situation alters any AVOACV2010D, SWS the Disposition column.

previous assessments in nonfire AVOACV082326, and analyses as to the influencing SWSAVOBCV082447M factors and the timing still need to be modified for considerations covered in SRs HR fire related conditions. This G3, HRG4, and HRG5 in Part 2 task is not completed.

And (b) DEVELOP a defined basis to support the claim of nonapplicability of any of the requirements under HLRHRG in Part 2.

HRAD101 INCLUDE operator recovery Closed Identification and evaluation Phase 1 Final Finding resolved by documentation During the Phase 2 review, work on the 1

(Finding) actions that can restore the of recovery actions for risk (reviewed (not met) and model update. No impact to human reliability analysis (HRA) element functions, systems, or significant scenarios are not met) NFPA805 analysis. was in progress. A detailed assessment of components on an asneeded expected to continue as the The final identification of fire the HRA supporting requirements was basis to provide a more realistic refinement of fire scenario response actions was completed performed during the Final Peer review.

evaluation of significant accident analysis continues. and documented in notebook NB The Final Peer review summary report sequences. Currently, some of the top PSAHR1, Ref (13). These actions noted:

core damage fire scenarios were incorporated into the final still do not account for The review did not identify issues with the fire PRA model where appropriate. fundamental approaches being used [for]

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status realistic recovery actions. the completed portion of the HRA This task is not completed assessment.

yet. The finding was not fully resolved for the Final Peer review, but was subsequently closed prior to the LAR submittal.

HRAD201 INCLUDE operator recovery Open Many of the operator Phase 1 Final This finding open is treated as During the Phase 2 review, work on the (Finding) actions that can restore the recovery actions associated (reviewed (not met) open since screen values were human reliability analysis (HRA) element functions, systems, or with fire response are still not met) used as recovery values. This is a was in progress. A detailed assessment of components on an asneeded modeled with screening result given that the procedures, the HRA supporting requirements was basis to provide a more realistic values; i.e., not accounting modification detail, operations performed during the Final Peer review.

evaluation of significant accident for all of the relevant PSFs. review, and detailed HRA model The Final Peer review summary report sequences (same as HRAD101). Dependency analysis has development are not yet complete. noted:

been performed for the Screening values are still applied current set of fire scenarios The review did not identify issues with the for fire HEPs. fundamental approaches being used [for]

and operator actions in the "T" model. The results A dependency analysis was the completed portion of the HRA generated from the "Q" completed to identify assessment.

model did not incorporate combinations of human failure This finding remains open as indicated in the dependency analysis. events (HFEs) in which the Disposition column.

The dependency analysis dependencies between actions needs to be reanalyzed may contribute to an increase in before finalization of the core damage frequency (CDF)

Fire PRA model. This task is when compared to the CDF not complete yet. Also, HRA calculated when nominal screening Calculator evaluation sheets values for human error cannot be located for PCP probabilities (HEPs) are used.

PMOFP50XLOC and EDG Dependencies between actions PMOEPORTPUMP, and were assigned based on sequence AFWAVOACV2010D, specific evaluations of cues, timing, SWSAVOACV082326, and location, and available resources, SWSAVOBCV082447M and the HEPs adjusted if necessary still need to be modified for to represent the level of fire related conditions dependence; the CDF was then recalculated using the modified HEPs. HFEs not explicitly evaluated Page 40 of 79

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status for dependence were assigned HEPs of 1 (i.e., the represented operator actions are assumed to fail with a probability of unity), and thus the resulting CDF represents an upper bound for the potential impact of dependencies upon the results. Shared cues conservatively assumed 100% dependence. This approach has identified important HFEs for which the completion of detailed human reliability analyses may be beneficial; those analyses have not been completed.

The fire PRA HRA dependency analysis is documented in NBPSA HR, Ref (13).

HRAE101 DOCUMENT the Fire PRA HRA Open Documentation for HFEs Phase 1 Final Finding open, given that the During the Phase 2 review, work on the (Finding) including associated with selected fire (reviewed (not met) procedures, modification detail, human reliability analysis (HRA) element (a) those firerelated influences response HFEs (e.g., FPS not met) operations review, and detailed was in progress. A detailed assessment of that affect the methods, PMOESTARTL, ACPPMOE HRA model development are not the HRA supporting requirements was processes, or assumptions used 38311A, ACPPMOE383 yet complete. Screening values performed during the Final Peer review.

as well as the identification and 12A, etc.) in the risk are still applied for fire HEPs The Final Peer review summary report quantification of the HFEs/HEPs significant fire scenarios pending development of final noted:

in accordance with HLRHRI and need to be provided. Also, procedures, modifications, and its SRs in Part 2, and DEVELOP a HRA Calculator evaluation operations reviews. The review did not identify issues with the defined basis to support the sheets cannot be located for fundamental approaches being used [for]

claim of nonapplicability of any of PCPPMOFP50XLOC, EDG the completed portion of the HRA the requirements under HLRHRI PMOEPORTPUMP, and assessment.

in Part 2, PULLFUSE; AFWPMOTP This finding remains open as indicated in and 8BLOC seems to have been the Disposition column.

(b) any defined bases to support changed to AFWPMOTP the claim of nonapplicability of 8BSBO in HRA notebook Page 41 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status any of the referenced (but not changed in Fire PRA requirements in Part 2 beyond model); and AFWAVOACV that already covered by the 2010D, SWSAVOACV clarifications in this Part 082326, and SWSAVOB CV082447M still need to be modified for fire related conditions. This task is not complete.

IGNA1001 PROVIDE a mean value of, and a Closed The characterization of Phase 1 Final Finding resolved by documentation Review of the ignition frequency (IGN) 1 (Finding) statistical representation of, the uncertainties in the fire (reviewed (not met) update. No impact to NFPA805 element was completed during the Phase 2 uncertainty intervals for ignition frequencies has not not met) analysis. Peer review. From the final report:

significant fire ignition been addressed in the The characterization of Technical work completed and reviewed in frequencies. report qualitatively or uncertainties in the fire ignition August 2010; No additional review in quantitatively. frequencies have been addressed March 2011.

in Report 0247.07.005.01, Ref (1). The finding was closed prior to the LAR The change in ignition frequency submittal.

has a direct impact on CDF since ignition frequency is included in the calculation of CDF for every scenario. The report describes the sensitivities run by changing the bin ignition frequencies to the 5th and 95th percentile values of the original frequencies for both EPRI and NUREG/CR6850 values.

Calculating the 5th and 95th percentiles was done so using the GAMMADIST function in Excel for the EPRI frequencies and provided as BART output for the NUREG/CR 6850 frequencies. This sensitivity provides an adequate upper and lower bound of the final CDF which used the mean frequencies.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status IGNA601 When combining evidence from Closed The Bayesian update Phase 1 Final Suggestion resolved by Review of the ignition frequency (IGN)

(Suggestion) generic and plantspecific data, process used to update (met) (met) documentation update. No impact element was completed during the Phase 2 USE a Bayesian update process or generic ignition frequencies to NFPA805 analysis. Peer review. From the final report:

equivalent statistical process. to plant specific is not The Bayesian update process used Technical work completed and reviewed in JUSTIFY the selection of any documented. A question to update the generic frequencies August 2010; No additional review in informative prior distribution was submitted during the to plant specific frequencies is March 2011.

used on the basis of industry Peer review activities and documented in Section 4.2 of the experience. the response suggests that Fire Ignition Frequency and Plant the Bayesian approach is Partitioning, report 024707 documented and will be 0005.02, Ref (2). Section 4.2.1 of added to the report. the report identifies the Bayesian statistical update of the EPRI TR 1016735 generic frequencies that was performed using PLP specific fire events data. The revised fire ignition frequencies, including the frequencies calculated in Appendix G of Report 0247070005.02, have gamma uncertainty distributions.

Therefore, the prior data provided included: the mean, alpha, and beta factors. The Bayesian analysis was performed in a manner consistent with the assertion that the bin ignition frequencies were gamma distributions.

Section 4.2.2 of the report 0247.070005.02 identifies the Bayesian statistical update of the NUREG/CR6850 generic frequencies was performed using PLP specific fire events data.

NUREG/CR6850 provides the Page 43 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status mean, 5th, 50th, and 95th percentiles, and standard deviation for each bin ignition frequency.

The Bayesian analysis assumes the NUREG/CR6850 bin ignition frequencies are lognormal distributions. Frequencies for Bins 16a, 16b, 16c, and 16d are provided in FAQ 060017 and FAQ 070035. The generic frequency distributions along with the plant evidence discussed in Section 4.2 of Report 0247070005.02 were input into the Bayesian software tool BART, and the new bin frequencies developed. Table 45 of Report 0247070005.02 provides the posterior mean, 5th percentile, 95th percentile, median, and range factor values associated with each bin for use in future update.

IGNA701 USE a plantwide consistent Closed Page 31 of report 024707 Phase 1 Final Finding resolved by documentation Review of the ignition frequency (IGN)

(Finding) methodology based on 0005.02 appears to suggest (met) (met) update. No impact to NFPA805 element was completed during the Phase 2 parameters that are expected to that no frequency for analysis. peer review. From the final report:

influence the likelihood of miscellaneous hydrogen Report 0247.07070005.02, Ref Technical work completed and reviewed in ignition to apportion highlevel fires has been assigned to (2), and Fire Ignition Frequency August 2010; No additional review in ignition frequencies (e.g., plant applicable physical analysis calculation databases have been March 2011.

wide values) to estimate physical units. This may affect the updated to assign miscellaneous analysis unit or ignition source PAU level quantification by hydrogen fires to all applicable level frequencies. reducing the fire ignition Physical Analysis Units (PAUs). As frequency assigned to the noted in Section 4 of report 0247 applicable plant locations. 070005.02, the frequency associated with Bin 19, Page 44 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Miscellaneous Hydrogen Fires, has been allocated based on linear feet, valve location and tank location in PAUs where hydrogen equipment exists. Applying these criteria has apportioned miscellaneous hydrogen frequency to the following PAUs: 04 (1C Switchgear Room), 13 (Reactor Building), and 23 (Turbine Building).

IGNA901 POSTULATE the possibility of Closed The report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the ignition frequency (IGN)

(Suggestion) transient combustible fires for all does not list the transient or (met) (met) documentation update. No impact element was completed during the Phase 2 physical analysis units regardless fixed ignition source to NFPA805 analysis. Peer review. From the final report:

of the administrative restrictions. frequencies in each fire Report 0247.070005.02, Ref (2), Technical work completed and reviewed in zone. The report appears to has been updated to include August 2010; No additional review in only list the total frequency. transient and fixed ignition source March 2011.

frequencies for each PAU (fire zone). Appendix E and F of Report 0247070005.02 includes frequencies on a PAU basis broken down into Transient, Fixed and Total for each. Each Appendix provides a detailed Ignition Source Datasheet (ISDS) of frequencies by bin and PAU for the corresponding frequency. The ISDS utilizes data from the counting walkdowns, the transient and cable weighting factors, location weighting factors, and the Bayesian updated fire ignition frequencies to calculate the Fire Frequency for each Physical Analysis Unit.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status The ISDS provides the Physical Analysis Unit identification and description, the generic location categories (fixed and transient source) weighting factors and count summary necessary to calculate the fire frequency in accordance with the equations provided in the body of this notebook in accordance with the guidelines established in NUREG/CR6850.

IGNB201 DOCUMENT references for fire Closed The report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the ignition frequency (IGN)

(Suggestion) events and fire ignition frequency does not reference plant (met) (met) documentation update. No impact element was completed during the Phase 2 sources used. specific fire events used to to NFPA805 analysis. Peer review. From the final report:

update fire ignition Report 024707005.02, Ref (2), Technical work completed and reviewed in frequencies. has been updated to document the August 2010; No additional review in plant specific fire events that were March 2011.

used to update the fire ignition frequencies in Appendix A of the report. The appendix documents the review of all fire events at PLP for the dates of January 1, 2001 through December 31, 2011. This review was performed to determine if any fire events were classified as potentially challenging in accordance with NUREG 6850.

Fire events that are identified as potentially challenging required the updating of the generic fire frequencies provided in NUREG/CR6850 and EPRI TR 1016735 for use in the plant Page 46 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status specific fire PRA.

IGNB401 DOCUMENT the plantspecific Closed The report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the ignition frequency (IGN)

(Suggestion) frequency updating process. does not clearly describe (met) (met) documentation update. No impact element was completed during the Phase 2 INCLUDE in the documentation the process for classifying to NFPA805 analysis. Peer review. From the final report:

fire events as potentially The 0247070005.02, Ref (2), Technical work completed and reviewed in (a) the selected plantspecific challenging or not report documents the process of August 2010; No additional review in events challenging. The report classifying fire events as potentially March 2011.

does provide a table challenging or not challenging in (b) the basis for the selection and indicating which portion of Appendix A.

or exclusion of events the criteria was met.

However, the report should Fire event reports were obtained (c) the analysis supporting the describe how this table was from plant personnel for the plantspecific reactoryears, and populated. It is not evident station covering the period of from the table how the January 1, 2001 through December (d) the Bayesian process for criteria was met/not met 31, 2011. Plant personnel made an updating generic frequencies from the information extensive search of their provide in the event condition report and Ideas description column. databases for fire incident reports.

The search criteria included dates 1/1/01 through 12/31/11 and key words fire, heat, and smoke.

This search revealed thousands of hits but a review of each identified only a total of eleven (11) fire incidents within the protected area and in areas included in the global analysis boundary.

Each of these reports was reviewed, summarized, categorized and classified as either potentially challenging or not potentially challenging. The criteria for a fire to be deemed potentially challenging are provided in NUREG 6850.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Appendix C in 6850, Section C.3.3.1 provides criteria for classifying a fire event as "potentially challenging."

MUA101 The PRA configuration control Closed The Palisades PRA Model Phase 1 Final Finding resolved by documentation The finding was resolved prior to the 1

(Finding) process shall include monitoring Update procedure includes (reviewed (not met) update. No impact to NFPA805 conduct of the Final Peer review. This SR of changes in design, operation, maintenance and upgrades not met) analysis. was not reexamined during the Final Peer and maintenance that could to the PRA to be consistent Section 3.3 of the configuration review. The final report is inconsistent and affect the PRA. Such changes with the asbuilt, as control notebook, NBPSACC, Ref does not reflect resolution of this finding.

shall include operating operated plant. Resolution (14), has been revised to include a procedures, design configuration, of the Full Power Internal requirement for a Peer review initiating event frequencies, Events (FPIE) Peer Review against the ASME standard for PSA unavailabilities, and component F&Os and incorporation of model upgrades.

failure rate data. design and operational information relevant to a Fire PRA should result in meeting the Standard.

PPA101 INCLUDE within the global Closed Requirement PPA01 Phase 1 Final Finding resolved by documentation Review of the plant partitioning (PP)

(Finding) analysis boundary all fire areas, includes Note PPA12 (met) (met) update. No impact to NFPA805 element was completed during the Phase 2 fire compartments, or locations which clarifies that the analysis. Peer review. From the final report:

within the licenseecontrolled intent of the requirement is At the completion of Task 1 (Plant Technical work completed and reviewed in area where a fire could adversely to include plant locations Partitioning) a set of PAUs were August 2010; No additional peer review in affect any equipment or cable with no credited plant established for the fire PRA. These March 2011.

item to be credited in the Fire equipment that may affect PAUs are evaluated and undergo PRA plant response model locations with credited plant the screening process outlined in including those locations of a equipment in multi Section 2.1 of report 024707 sister unit that contain shared compartment fire scenarios. 0005.02, Ref (2). The screening equipment credited in the Fire With respect to the multi analysis qualitatively determines PRA. compartment analysis, the the fire risk associated with each report 0247070005.02 PAU. The results of the Task 4 makes no mention on the screening are used in Task 6 (Fire treatment of qualitatively Ignition Frequency), where fire screened buildings or plant frequencies are estimated for each Page 48 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status locations. of the unscreened fire compartments.

Qualitative screening as described in Task 4 (Qualitative Screening) of NUREG/CR6850 is intended to identify those fire compartments where, according to pre determined criteria, the fire risk is expected to be relatively low or nonexistent compared to others.

This task assumes that the risk (i.e.

CDF and/or LERF) associated with the fire scenarios where a controlled manual plant shutdown may be attempted as a precautionary measure and no other fire PRA components are affected is low. If a compartments exclusion from the fire PRA is uncertain (for instance, whether an automatic or manual plant trip will occur may not be known with certainty), that compartment should be retained for quantitative analysis to better determine its contribution, if any, to the overall fire risk.

In the Palisades fire PRA there were two PAUs qualitatively screened. The qualitative screening process and criteria are described in Section 2 of report 0247070005.02.

PPB101 DEFINE Fire PRA physical analysis Closed The plant partitioning report Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP)

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status (Suggestion) units based on a combination of does not describe cable (met) (met) documentation update. No impact element was completed during the Phase 2 plant fire areas as defined in the trenches, duct banks, to NFPA805 analysis. Peer review. From the final report:

plants fire protection program manholes, etc. that may be Physical analysis units for the Technical work completed and reviewed in and physical analysis units where present in the yard. The Palisades fire PRA correspond to August 2010; No additional peer review in each physical analysis unit Fire PRA should have a Fire Areas defined in the Fire March 2011.

represents a subdivision of a fire disposition for these areas Protection Program. Confirmatory area, and If any fire area is as to why there may/may walkdown notes have been subdivided into two or more not be the need for documented in Attachment 3 of physical analysis units, ENSURE postulating fire scenarios Report 0247070005.02, Ref (2).

that the physical analysis unit and where in the yard the definitions comply with the scenarios may be Six plant locations were identified balance of the PPB SRs (PPB2 postulated. that were not specifically through PPB7). addressed in the FHA and new physical analysis units were created for use in the fire PRA.

These fire locations were the Cooling Tower Pump House, Feedwater Purity Building, Yard Area, Switchyard, Administration Building, and Service Building. The boundary requirements for a fire risk assessment were sufficiently met by the boundaries of the Feedwater Purity Building and Cooling Tower Pump House. The Yard Area and Switchyard were outdoor areas and therefore did not have any fire rated barriers except for the separations from the indoor analysis units. Spatial separation has been inherently credited with the use of current Fire Protection Program fire boundaries. Spatial separation is present between the following PAUs boundaries: Component Cooling Pump Water Rooms and Page 50 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Turbine Building, Auxiliary Building and Radwaste Addition VRS, and lastly East Engineered Safeguards Rooms and Auxiliary Building.

These boundaries have been documented and referenced in the current Fire Hazards Analysis to meet the requirements of this fire risk assessment.

The switchyard is located approximately a quarter mile outside of the protected area but within the Owner Controlled Area.

The Yard Area is defined as all outside areas within the protected area fencing. The Fire Scenario Development Report, 024707 0005.02 accounts for the presence of cables, bus ducts, etc. in the development of the postulated fire scenarios in the yard area.

PPB201 If partitioning credits wall, ceiling, Closed Report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP)

(Suggestion) or floor elements that lack a fire does not provide adequate (met) (met) documentation update. No impact element was completed during the Phase 2 resistance rating, JUSTIFY the justification for crediting to NFPA805 analysis. peer review. From the final report:

judgment that the credited barriers when outside the Physical analysis units for the Technical work completed and reviewed in element will substantially contain fire protection program. Palisades fire PRA correspond to August 2010; No additional peer review in the damaging effects of fires Fire Areas defined in the Fire March 2011.

given the nature of the fire Protection Program. Confirmatory sources present in each walkdown notes have been compartment separated by the documented in Attachment 3 of nonrated partitioning element. report 0247070005.02, Ref (2).

Credit for raceway fire barriers, thermal wraps or other localized protection features have not been Page 51 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status credited in identifying a physical analysis unit.

PPB301 If spatial separation is credited as Closed Report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP)

(Suggestion) a partitioning feature, JUSTIFY does not clearly discuss the (met) (met) documentation update. No impact element was completed during the Phase 2 the judgment that spatial credit for spatial separation. to NFPA805 analysis. Peer review. From the final report:

separation is sufficient to There are two areas noted Report 0247070005.02, Ref (2), Technical work completed and reviewed in substantially contain the that do rely on spatial has been updated to discuss the August 2010; No additional peer review in damaging effects of any fire that separation: the Switchyard credit of spatial separation in March 2011.

might be postulated in each of and Yard Area which are Section 2.2.

the fire compartments created as outdoors and thus have no a result of crediting this feature. rated fire barriers. F/O The physical analysis units used for related to the yard has been the fire risk assessment correlate documented under a to fire areas used for the Fire different SR and may Protection Program. This approach address the concern of allowed the fire risk assessment to spatial separation. rely on the existing programmatic controls and design requirements for maintaining the integrity of the associated physical analysis unit boundaries. Based on the documentation provided in the Fire Hazards Analysis (FHA), the boundaries for these PAUs had fire withstand ratings consistent with the requirements of the Fire Protection Program. The test and maintenance requirements of the Fire Protection Program were sufficient to satisfy the boundary requirements for the fire risk assessment.

In addition, utilization of the area boundaries established by the Fire Page 52 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Protection Program allows the use of previously gathered equipment and cable location data and facilitates the verification and control of the boundaries.

Walkdowns were conducted to confirm that accessible boundaries of each physical analysis unit were of substantial construction, and that physical openings in the barriers were noted. Physical analysis units for the Palisades fire PRA correspond to Fire Areas defined in the Fire Protection Program. Confirmatory walkdown notes have been documented in Attachment 3 of 0247070005.02.

Credit for raceway fire barriers, thermal wraps or other localized protection features have not been credited in identifying a physical analysis unit.

The switchyard is located approximately a quarter mile outside of the protected area but within the Owner Controlled Area.

The Yard Area is defined as all outside areas within the protected area fencing.

PPB401 DO NOT CREDIT raceway fire Closed Report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP)

(Suggestion) barriers, thermal wraps, fire does not discuss crediting of (met) (met) documentation update. No impact element was completed during the Phase 2 retardant coatings, radiant raceway fire barriers. to NFPA805 analysis. Peer review. From the final report:

energy shields, or any other Report 0247070005.02, Ref (2), Technical work completed and reviewed in localized cable or equipment has been updated to reflect that August 2010; No additional peer review in Page 53 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status protection feature as partitioning raceways fire barriers have not March 2011.

elements in defining physical been credited in the fire PRA analysis units. analysis.

The physical analysis units used for the fire risk assessment correlate to fire areas used for the Fire Protection Program. This approach allowed the fire risk assessment to rely on the existing programmatic controls and design requirements for maintaining the integrity of the associated physical analysis unit boundaries. Based on the documentation provided in the Fire Hazards Analysis (FHA), the boundaries for these PAUs had fire withstand ratings consistent with the requirements of the Fire Protection Program. The test and maintenance requirements of the Fire Protection Program were sufficient to satisfy the boundary requirements for the fire risk assessment.

In addition, utilization of the area boundaries established by the Fire Protection Program allows the use of previously gathered equipment and cable location data and facilitates the verification and control of the boundaries.

Walkdowns were conducted to confirm that accessible boundaries of each physical analysis unit were of substantial construction, and Page 54 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status that physical openings in the barriers were noted.

PPB501 DEFINE AND JUSTIFY the basis Closed Report 0247070005.02 Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP)

(Suggestion) and criteria applied when active does not discuss crediting (met) (met) documentation update. No impact element was completed during the Phase 2 fire barrier elements (such as active fire barriers. to NFPA805 analysis. Peer review. From the final report:

normally open fire doors, water Report 0247070005.02, Ref (2), Technical work completed and reviewed in curtains, and fire dampers) are has been updated to discuss the August 2010; No additional peer review in credited in partitioning. credit of active fire barriers. March 2011.

The report notes that the Physical analysis units for the Palisades fire PRA correspond to Fire Areas defined in the Fire Protection Program. Additionally, confirmatory walkdown notes have been documented in Attachment 3 of 0247070005.02. Credit for raceway fire barriers, thermal wraps or other localized protection features have not been credited in identifying a physical analysis unit.

PPB701 CONDUCT a confirmatory Closed Walkdown forms are Phase 1 Final Suggestion resolved by Review of the plant partitioning (PP) 1 (Suggestion) walkdown of locations within the referenced in report 0247 (reviewed (not met) documentation update. No impact element was completed during the Phase 2 global analysis boundary to 070005.02 but walkdown not met) to NFPA805 analysis. Peer review. Although listed in Table 416 confirm the conditions and results are not attached or Walkdowns were conducted to as not met from the final report:

characteristics of credited available. A question on this confirm that accessible boundaries Technical work completed and reviewed in partitioning elements. topic was submitted during of each physical analysis unit were August 2010; No additional peer review in the Peer review and the of substantial construction, and March 2011.

response to the question that physical openings in the clarified the concern of lack The finding was verified closed prior to the barriers were noted. These LAR submittal.

of documentation for the walkdowns are documented in walkdowns. Attachment 3 of Report 024707 0005.02, Ref (2).

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SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status PPC201 JUSTIFY the exclusion of any Closed It is not entirely clear how Phase 1 Final Finding resolved by documentation Review of the plant partitioning (PP)

(Finding) locations within the licensee some excluded areas listed (met) (met) update. No impact to NFPA805 element was completed during the Phase 2 controlled area that are not in Section 2.1.2.2 of Report analysis. Peer review. From the final report:

included in the global analysis 0247070005.02 satisfy the Report Section 2.1.2.2 of Report Technical work completed and reviewed in boundary by demonstrating that exclusion criteria, namely 0247070005.02, Ref (2), has been August 2010; No additional peer review in they do not satisfy the selection the Service Building and updated to satisfy the exclusion March 2011.

criteria as defined per PPA1. Administrative building. criteria of the Service Building and These buildings appear to Administrative Building. The share a common boundary buildings common boundary with with the Auxiliary Building. the Auxiliary Building has been For example, would not a detailed and the PAUs are retained major fire in the Service for MCA analysis.

building be designated a challenging fire requiring a plant shutdown? The report states that fires within the Administration Building, Service Building, and Service Building Addition were not expected to propagate to the included physical analysis units, cause a plant transient, or require plant shutdown.

Are excluded buildings permanently excluded, or are they considered during multicompartment evaluations?

PRMB1101 MODEL all operator actions and Open Complete work Phase 1 Final Finding open, given that the Review of the fire PRA plant response (Finding) operator influences in (reviewed (not met) procedures, modification detail, model (PRM) technical element was mostly accordance with the HRA not met) operations review, and detailed complete during the Phase 1 review. A element of this Standard. HRA model development are not limited review was conducted during the yet complete. Final.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status Screening values are still applied From the Final Peer review summary:

for fire HEPs pending development The Fire PRA plant response model was of final procedures, modifications, reviewed with very few findings. There and operations reviews. were no technical F&Os on the scope or content of the PRM model itself. The F&Os assigned to PRM were either a) cross referenced from other tasks [HRA and ES]

or b) were for incomplete documentation.

This HRA related finding remains open.

PRMB301 IDENTIFY any new initiating Closed The fault tree model Phase 1 Final Finding resolved by documentation Review of the fire PRA plant response 1

(Finding) events arising from the development omitted the (reviewed (not met) and model update. No impact to model (PRM) technical element was mostly considerations of the ES and CS DC power dependency not met) NFPA805 analysis. complete during the Phase 1 review. A technical elements that might requirement for the RCP The fault tree model applied to the limited review was conducted during the result from a fire event that were breaker trip function. fire PRA was updated to include Final.

not included in the Internal the DC power dependency for the From the Final Peer review summary:

Events PRA including those primary coolant pump breaker trip arising from the consideration of The Fire PRA plant response model was function. This logic was added at reviewed with very few findings. There spurious actuation. model gates PCPSEALSSW20, were no technical F&Os on the scope or PCPSEALSSW22, PCPSEALSSW content of the PRM model itself. The F&Os 21, and PCPSEALSSW23 for each assigned to PRM were either a) cross of the four primary coolant pumps. referenced from other tasks [HRA and ES]

or b) were for incomplete documentation.

The finding was not fully resolved for the Final Peer review, but was subsequently closed prior to the LAR submittal.

PRMB302 IDENTIFY any new initiating Closed Spurious SI is not included Phase 1 Final Finding resolved by documentation Review of the fire PRA plant response 1

(Finding) events arising from the as a potential initiating (reviewed (not met) and model update. No impact to model (PRM) technical element was mostly considerations of the ES and CS event not met) NFPA805 analysis. complete during the Phase 1 review. A technical elements that might A complete review of Safety limited review was conducted during the result from a fire event that were Injection Signal (SIS), Containment Final.

not included in the Internal High Pressure (CHP), Containment From the Final Peer review summary:

Events PRA including those Page 57 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status arising from the consideration of High Radiation (CHR), Containment The Fire PRA plant response model was spurious actuation. Isolation Signal (CIS) and reviewed with very few findings. There Recirculation Actuation Signal were no technical F&Os on the scope or (RAS) logic was performed to content of the PRM model itself. The F&Os identify potential adverse assigned to PRM were either a) cross component actuations that could referenced from other tasks [HRA and ES]

occur due to a spurious signal from or b) were for incomplete documentation.

any of these sources. The finding was not fully resolved for the Logic was added for 45 PRA Final Peer review, but was subsequently components to consider spurious closed prior to the LAR submittal.

operation from any of the automatic actuation circuits.

Report 0247070005.04, Ref (4),

Section 5.71 was updated to reflect these changes.

PRMB501 For those fireinduced initiating Closed The MSO expert panel Phase 1 Final Finding resolved by documentation Review of the fire PRA plant response 1

(Finding) events included in the Internal issues have not been (reviewed (not met) and model update. No impact to model (PRM) technical element was mostly Events PRA model, REVIEW the completely resolved and not met) NFPA805 analysis. complete during the Phase 1 review. A corresponding accident sequence incorporated into the PRA All MSO expert panel issues have limited review was conducted during the models and model. Thus, all modeling been resolved and integrated into Final.

(a) IDENTIFY any existing accident work associated with MSO the final PRA fire model as From the Final Peer review summary:

sequences that will require incorporation has not been appropriate. All MSO scenario modification based on unique done at this time. The Fire PRA plant response model was dispositions are documented in the reviewed with very few findings. There aspects of the plant fire response final MSO report 0247070005.04, procedures in accordance with were no technical F&Os on the scope or Ref (4). content of the PRM model itself. The F&Os HLRASA and HLRASB of Part 2 and their supporting assigned to PRM were either a) cross requirements referenced from other tasks [HRA and ES]

And or b) were for incomplete documentation.

(b) IDENTIFY any new accident The finding was not fully resolved for the sequences that might result from Final Peer review, but was subsequently a fire event that were not closed prior to the LAR submittal.

included in the Internal Events PRA in accordance with HLRASA Page 58 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status and HLRASB of Part 2 and their supporting requirements.

PRMB901 For any cases where new system Closed Failure to trip Pressurizer Phase 1 Final Finding resolved by documentation Review of the fire PRA plant response 1

(Finding) models or split fractions are heaters is not explicitly (reviewed (not met) and model update. No impact to model (PRM) technical element was mostly needed, or existing models or addressed not met) NFPA805 analysis. complete during the Phase 1 review. A split fractions need to be Fault tree PZRSPURHTRFT(45) limited review was conducted during the modified to include fireinduced was added to the fire PRA to Final.

equipment failures, firespecific model spurious operation of From the Final Peer review summary:

operator actions, and/or spurious pressurizer heaters and failure of actuations, PERFORM the The Fire PRA plant response model was pressurizer spray. Failure of this reviewed with very few findings. There systems analysis portion of the fault tree results in a potential Fire PRA model in accordance were no technical F&Os on the scope or stuck open pressurizer safety content of the PRM model itself. The F&Os with HLRSYA and HLRSYB and valve, or valves.

their SRs in Part 2 with the assigned to PRM were either a) cross following clarifications, and Section 5.45 of report 024707 referenced from other tasks [HRA and ES]

DEVELOP a defined basis to 0005.04, Multiple Spurious or b) were for incomplete documentation.

support the claim of Operation Report, Ref (4), was The finding was not fully resolved for the nonapplicability of any of these updated to reflect this change. Final Peer review, but was subsequently requirements in Part 2: closed prior to the LAR submittal.

All the SRs under HLRSYA and HLRSYB in Part 2 are to be addressed in the context of fire scenarios including effects on system operability/functionality accounting for fire damage to equipment and associated cabling.

QLSB201 DOCUMENT the disposition of Closed See PPC201. Phase 1 Final Finding resolved by documentation Review of the qualitative screening (QLS)

(Finding) each physical analysis unit (reviewed (met) update. No impact to NFPA805 element was completed during the Phase 2 defined by the plant partitioning not analysis. Peer review. From the final report:

analysis as either "screened out" applicable) Section 2.1.2.2 of Report 024707 Technical work was completed and or "retained for quantitative 0005.02, Ref (2), has been updated reviewed in August 2010; No additional analysis" and in a manner that to satisfy the exclusion criteria of review in March 2011.

Page 59 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status facilitates Fire PRA applications, the Service Building and upgrades, and Peer review. Administrative Building. The buildings common boundary with the Auxiliary Building has been detailed and the PAUs are retained for MCA analysis.

SFA101 For those physical analysis units Open The current seismic fire Phase 1 Final Finding open. No impact to NFPA Review of the seismic fire (SF) element was (Finding) within the Fire PRA global interactions analysis relies (reviewed (not met) 805 quantified results. completed during the Phase 1 Peer review.

analysis boundary, on the IPEEE study. The not met) Report 0247070005.05, Seismic From the final report:

(a) LOOK for fire ignition source report needs to Fire Interaction, Ref (5), evaluates Completed in January 2010 and not re scenarios that might arise as the demonstrate that the scope Palisades with respect to reviewed in August 2010 or March 2011.

result of an earthquake that of that work meets the NUREG/CR6850 Task 13, Seismic would be unique from those objectives of the Standard This finding remains open, but this has no Fire Interactions Assessment. . impact on the quantified results.

postulated during the general and that plant changes since analysis of each physical analysis the work was performed do The seismic fire interactions unit, not compromise the analysis has not been updated.

and conclusions. However, since the Standard only (b) PROVIDE a qualitative requires a qualitative analysis, assessment of the potential risk there is no impact on the significance of any unique fire quantified results in fire PRA ignition source scenarios model.

identified UNCA101 PERFORM the uncertainty Closed Only a limited number of Phase 1 / Final Finding resolved by documentation The uncertainty and sensitivity supporting 1

(Finding) analysis in accordance with HLR parameter and modeling Phase 2 (not met) update. No impact to NFPA805 requirements were not reviewed during QUE and its SRs in Part 2 as well uncertainties and associated (not analysis. the Phase 1 and Phase 2 Peer reviews as as SRs LEF2 and LEF3 under assumptions have been reviewed) Section 7.1 of the fire risk the model progress was not sufficiently HLRLEF in Part 2 and DEVELOP a identified. The list is summary report, 0247070005.01, complete. This finding was identified defined basis to support the incomplete and not defined Ref (1), was revised to include during the Final Peer review, but was claim of nonapplicability of any in sufficient detail to additional discussion and subsequently addressed prior to the LAR of the requirements under these support a reasonable evaluation of the stateof submittal.

sections in Part 2. characterization or knowledgecorrelation and the evaluation. Uncertainties impact of uncertainty associated have been propagated with severity factors and non Page 60 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status through a Monte Carlo suppression probability. The approach. However, discussion indicated that the correlation of state of distributions might be more broad knowledge uncertainties has if a more detailed parametric not been addressed, i.e. all uncertainty assessment were to be initiators have been treated performed.

as independent variables, Severity Factor (SF) and Non Suppression Probabilities (NSP) and spurious actuation probabilities are not correlated.

(Uncertainties carried over from the internal events analysis are correlated). This approach has led to unrealistically narrow predictions of CDF and LERF distributions (error factor of

2) and the potential underestimation of the mean values for scenarios which are quantified based on the product of like distributions (e.g. multiple spurious actuation probabilities).

UNCA201 INCLUDE the treatment of Open The uncertainty intervals Phase 1 / Final Finding open as the approach for The uncertainty and sensitivity supporting (Finding) uncertainties, including their assigned to Fire IEs, Severity Phase 2 (not met) performing the parametric requirements were not reviewed during documentation, as called out in Factors and Non (not uncertainty evaluation has not yet the Phase 1 and Phase 2 Peer reviews as SRs PRMA4, FQF1, IGNA10, Suppression Probabilities reviewed) been updated. the model progress was not sufficiently IGNB5, FSSE3, FSSE4, FSSH5, are not based on acceptable No impact to NFPA805 analysis as complete. This finding was identified FSSH9, and CFA2 and that systematic methods. the results are based on the point during the Final Peer review, but as required by performing Part 2 1) Uncertainty distributions estimate values which indicated this does not impact the point referenced requirements for fire IEs have been estimate values used in the NFPA805 Page 61 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status throughout this Standard. assigned the same error approximate the mean values. The analysis.

factor of 10 rather than parametric uncertainty analysis is This finding remains open.

using posterior distributions presented in Section 7.1 of the fire from Bayesian update risk summary report, 024707

2) SF distributions have 0005.01, Ref (1). The issues been assigned without an identified have not been fully underlying basis. addressed, but this primarily

3) NSP uncertainty impacts the potential range of the distribution has been uncertainty distribution and does derived on the basis of not have a significant impact on NUREG/CR 1278. This the mean value; and has no impact provides guidance on HEP on the point estimate mean values uncertainty assessment. used in the analysis.

However, NSP terms are an output of a combination of fire growth and suppression modeling and guidance in NUREG/CR 1278 has therefore little relevance. A valid approach would be to address the uncertainties in damage times in combination with uncertainties in suppression probabilities based on specific contributing factors.

4) Uncertainties associated with spurious actuation probabilities have been characterized according to a set of rules defined for severity factors. In this case spurious actuation probabilities with a failure probability of > 0.25 are assigned an error factor of Page 62 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 2: Supplemental Information to Table V-1 2

SR Topic (ASME Standard Category II Status Finding or Suggestion SR Initial SR Disposition Supplemental Information Text) Peer Subsequent Review Peer Status Review Status 1.0. In contrast NUREG/CR 6850 recommend use of a uniform distribution with the following limits Cables with 15 or less conductors: +20%

Cables with more than 15 conductors: +50%

Alternatively the values included in tables 101 to 105 NUREG/CR 6850 could be used where limits appear to be wider. The Palisades analysis has not accounted for larger uncertainties associated with cables with

> 15 conductors.

1) The supporting requirement was categorized as not met at completion of the Final Peer review conducted during the week of March 21, 2011. The supporting requirement was subsequently addressed and categorized as met/closed (per the disposition discussion), prior to the LAR submittal in December 2012.

2) Status Closed implies F&O disposition is sufficient to meet Category II.

Page 63 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 3: Supporting Requirements with Status of Not Reviewed SR Topic (ASME Standard Category II Text) Status Peer Review Basis for Assessment Disposition PRMA3 CONSTRUCT the Fire PRA plant response model so Not This SR is not reviewed because the sequence This supporting requirement is meant to refer to the Fire Risk Quantification that it is capable of determining the significant Reviewed infrastructure to provide this capability is not supporting requirements in Section 42.12 (as there is no Section 42.7.12 in contributors to the fireinduced risk with 42.7.12. available at this time. The capability to the PRA standard). Since the Fire Risk Quantification SRs were fully calculate risk importance in a single scenario is reviewed during the Phase 2 and Final Peer reviews, the PRMA3 supporting available at the present time. The internal requirement was implicitly reviewed during that process as the model had events PRA provides an acceptable method for to be constructed to determine the significant contributors to perform the development of risk importance. Palisades uses FQ review. For the final Peer review, FRANC was used to quantify the SAPHIRE for quantification, which claims to be Palisades Fire PRA. FRANC provides CCDP and CLERP results on a fire able to integrate all fire scenarios into a global scenario basis and, when combined with the scenario fire frequencies, core damage equation and calculate global calculates and displays CDF and LERF. These results were presented to the importance using replacement events for basic fire PRA peer review team in the initial issue of the completed Fire Risk and events that have different probabilities in Quantification Summary Report, 0247070005.01 (Rev. 0 [17], March 2011).

different rooms. Palisades claims this has been Additionally, the dispositions for the findings of the FQ element in Table 2 done in internal flooding, which has the same are applicable to PRMA3.

multipleevent quantification challenges. If this method is successful, Palisades would be an The fire risk quantification (FQ) element was reviewed in detail in both the industry leading plant in the development of Phase 2 and Final Peer reviews.

global importance. With respect to the FQ element the Final report states:

Overall process is consistent with prevailing good practices. Results are not final and thus certain SRs cannot be demonstrated to have been met.

Continuing the refinement in process and planned provides confidence this technical element will meet the Standard.

PRMB2 VERIFY the peer review exceptions and deficiencies Not Not completed yet because the final Internal The fire Peer review team did not formally review the resolution of the full for the Internal Events PRA are dispositioned, and Reviewed Events PRA Peer Review has not been provided power internal events findings and observations. The resolutions are the disposition does not adversely affect the to Palisades discussed in Attachment U of the LAR and their impacts on the fire PRA are development of the Fire PRA plant response model. noted. None of the open items impact the NFPA 805 submittal.

The full power internal events (FPIE) peer review report, dated March 12, 2010 was received between the Phase 1 and Phase 2 fire PRA peer reviews.

Resolution of findings from this report were in progress during the Phase 2 and Final fire peer reviews.

With respect to the internal events model, the Final report states:

The Fire PRA and Internal Events PRA use the same model, thus the fidelity between the two is good. The internal events PRA underwent a RG 1.200 peer review in October 2009. The F&Os have been formally addressed and incorporated into the Fire PRA model.

Page 64 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table 3: Supporting Requirements with Status of Not Reviewed SR Topic (ASME Standard Category II Text) Status Peer Review Basis for Assessment Disposition PRMB4 MODEL any new initiating events identified per SR Not No new initiating events were identified, so As stated in the peer review assessment, no new initiating events were PRMB2 in accordance with HLRIEA, HLRIEB, and Reviewed this SR was not required. However, PRMB3 identified so this SR was not required.

HLRIEC and their SRs in Part 2 with the following indicates spurious SI should be considered, so Two findings were noted in the PRMB3 SR and were closed as described in clarifications: that the SR must be completed. Table 2 above.

(a) All SRs under HLRIEA and HLRIEB, and SRs IE Review of the fire PRA plant response model (PRM) technical element was C4, IEC6, IEC7, IEC8, IEC9, and IEC12 in Part 2 are mostly complete during the Phase 1 review. A limited review was to be addressed in the context of a fire inducing the conducted during the Final.

initiating events excluding initiating events that cannot be induced by a fire From the Final Peer review summary:

and The Fire PRA plant response model was reviewed with very few findings.

There were no technical F&Os on the scope or content of the PRM model (b) DEVELOP a defined basis to support the claim of itself. The F&Os assigned to PRM were either a) crossreferenced from other nonapplicability of any of these requirements in Part tasks [HRA and ES] or b) were for incomplete documentation.

2.

The PRMB3 findings were not fully resolved for the Final Peer review, but were subsequently closed prior to the LAR submittal.

PRMB14 IDENTIFY any new accident progressions beyond the Not LERF analysis did not look for any LERF There are no open F&Os associated with the LERF element from the internal onset of core damage that would be applicable to Reviewed phenomena applicable to the fire PRA which events PRA. No new LERF phenomena were identified for the Palisades fire the Fire PRA that were not addressed for LERF were not included in the internal events PRA. PRA.

estimation in the Internal Events PRA. F&O was not written. The reviewers are not aware of any Fire PRA which looked for beyond internal events" LERF phenomena.

Page 65 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors References for Question 1 Response

1) Report 0247-07-0005.01 Rev. 1, Palisades Fire Probabilistic Risk Assessment Fire Risk Quantification and Summary.

2) Report 0247-07-0005.02 Rev. 1, Palisades Fire Probabilistic Risk Assessment Plant Partitioning and Fire Ignition Frequency Development.

3) Report 0247-07-0005.03 Rev. 1, Palisades Fire Probabilistic Risk Assessment Model Development Report.

4) Report 0247-07-0005.04 Rev. 1, Palisades Fire Probabilistic Risk Assessment Multiple Spurious Operations Report.

5) Report 0247-07-0005.05 Rev. 1, Palisades Fire Probabilistic Risk Assessment Seismic/Fire Interaction Report.

6) Report 0247-07-0005.06 Rev. 1, Palisades Fire Probabilistic Risk Assessment Fire Scenario Development Report.

7) Report 0247-07-0005.07 Rev. 1, Palisades Fire Probabilistic Risk Assessment Multi-Compartment Analysis.

8) Report 0247-07-0005.08 Rev. 1, Palisades Fire Probabilistic Risk Assessment Exposed Structural Steel Analysis.

9) EA-APR-95-004 Rev. 5, 10 CFR 50 Appendix R Safe Shutdown Associated Circuits Analysis for Common Power Supply and Common Enclosure.

10) PLP-RPT-12-00134 Rev. 0, Validation of Appendix R Non-Safe Shutdown Cable Routing to Support the Fire PRA.

11) Palisades Probabilistic Safety Assessment Notebook NB-PSA-ETSC Rev. 3, Event Trees and Success Criteria.

12) EA-PSA-FPIE-FIRE-12-04 Rev. 0, Palisades Full Power Internal Events and Fire Model.

13) Palisades Probabilistic Safety Assessment Notebook NB-PSA-HR Rev. 4, Human Reliability Analysis Notebook Volume 1 (Post Initiator Operator Actions).

14) Palisades Probabilistic Safety Assessment Notebook NB-PSA-CC Rev. 1, PSA Model Configuration Control.

15) ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, 2009.

16) SCIENTECH report 17825-1, Palisades Fire PRA Peer Review to Requirements in Part 4 of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications.

Page 66 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors

17) Report 0247-07-0005.01 Rev. 0, Palisades Fire Probabilistic Risk Assessment Fire Risk Quantification and Summary.

NRC Request

2. There is no indication which Supporting Requirements were ranked below Capability Category II by the Peer Review Team (i.e., no Table V-2,) provide Table V-2.

ENO Response

2. Table V-2 is provided below:

Page 67 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Table V-2 Fire PRA - Category I Summary 1

SR Topic (ASME Standard Category II Text) Status Finding or Suggestion Disposition HRAA3 For each fire scenario, IDENTIFY any new, undesired Closed Section 6.3 of the HRA Notebook discusses the Finding resolved by documentation and model update. No impact to NFPA operator action that could result from spurious review that was performed with the licensed 805 analysis.

indications resulting from failure of a single instrument, operators for the identification of the new, per SR ESC2 (e.g., due to verbatim compliance with the undesired operator actions in response to A simulator exercise was performed with current Palisades license holders instruction in an alarm response procedure, when spurious indications. However, the detailed in which several scenarios were evaluated to determine how Operators separate confirmation is not available or required). documentation for the evaluation process and would respond given spurious or false instrument indications. The results of the justifications for the conclusion that no these exercises were considered in the HFE development process. The undesired operator actions will be taken in process and evaluation results are documented in the Palisades Probabilistic these instrumentation failure conditions was Safety Assessment Notebook NBPSAHR, Human Reliability Analysis not yet completed for the reviewers to confirm Notebook Volume 1 (Post Initiator Operator Actions), Rev. 4.

the conclusion that no undesired operator actions need to be considered.

HRAB4 INCLUDE HFEs for cases where fireinduced Closed Same as HRAA301. This SR was assigned CC I Finding resolved by documentation and model update. No impact to NFPA instrumentation failure of any single instrument could based on the related finding HRAA301. 805 analysis.

cause undesired operator action, consistent with HLR A simulator exercise was performed with current Palisades license holders ESC of this Part and in accordance with HLRHRF and in which several scenarios were evaluated to determine how Operators its SRs in Part 2 would respond given spurious or false instrument indications. The results of and these exercises were considered in the HFE development process. The DEVELOP a defined basis to support the claim of process and evaluation results are documented in the Palisades Probabilistic nonapplicability of any of the requirements under HLR Safety Assessment Notebook NBPSAHR, Human Reliability Analysis HRF Notebook Volume 1 (Post Initiator Operator Actions), Rev. 4.

Part 2.

HRAC1 For each selected fire scenario, QUANTIFY the HEPs for Open Fire response HFEs modeled with screening Finding open, given that the procedures, modification detail, operations all HFEs and ACCOUNT FOR relevant firerelated effects values have not yet been evaluated in a review, and detailed HRA model development are not yet complete.

using detailed analyses for significant HFEs and manner accounting for relevant PSFs (e.g., ACP Significant HFEs were evaluated and developed in further detail as conservative estimates (e.g., screening values) for DGOTB5BDG, FPSPMOESTARTL, ACP documented in the Palisades Probabilistic Safety Assessment Notebook NB nonsignificant HFEs, in accordance with the SRs for HLR PMOE38311A, ACPPMOE38312A, etc.). PSAHR, Human Reliability Analysis Notebook Volume 1 (Post Initiator HRG in Part 2 set forth under at least Capability Also, HRA Calculator evaluation sheet cannot Operator Actions), Rev. 4. Screening values are still applied for fire HEPs Category II, with the following clarification: be located for PCPPMOFP50XLOC and EDG pending development of final procedures, modifications, and operations (a) Attention is to be given to how the fire situation PMOEPORTPUMP, and AFWAVOACV2010 reviews.

alters any previous assessments in nonfire analyses as D, SWSAVOACV082326, and SWSAVOBCV to the influencing factors and the timing considerations 082447M still need to be modified for fire covered in SRs HRG3, HRG4, and HRG5 in Part 2 And related conditions. This task is not completed.

(b) DEVELOP a defined basis to support the claim of nonapplicability of any of the requirements under HLR HRG in Part 2.

1) Status Closed implies F&O disposition is sufficient to meet Category II.

Page 68 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors NRC Request

3. Individual VFDRs and the associated disposition are documented for each fire area in LAR Attachment C. However, the dispositions of the VFDRs in Attachment C state no modifications are required and the fire area Risk Summary in Attachment C contains the following generic statement: There were no additional modifications identified that are specific to a given VFDR resolution in this fire area. However, LAR Attachment S, Table S-2, contains modifications that are described as resolving VFDRs. Clarify the discrepancy in Attachment S wherein certain modifications are identified as resolving VFDRs and Attachment C where no VFDRs are identified as being resolved by modifications.

ENO Response

3. Based on plant knowledge and risk analysis insights, it was decided to identify and evaluate modifications for overall plant fire risk reduction, prior to an evaluation of specific variances from deterministic requirements (VFDRs). These plant modifications were developed independently of whether or not specific VFDRs may or may not have been resolved. Modifications identified with this approach, in combination with modifications identified to resolve code-compliance issues, lowered overall plant fire risk and eliminated the need for any additional modifications to be postulated to address specific VFDRs during the fire risk evaluation process.

In the Palisades LAR, Attachment C was meant to communicate that no additional modifications were required - beyond the set of modifications identified in Attachment S - to address any residual risk from any given VFDR.

Attachment S indicated whether a modification explicitly modeled in the PRA resolved any VFDRs, but did not identify the specific VFDRs resolved or distinguish between partial and full resolution. Attachment S therefore designated modifications that partially resolve VFDRs as modifications required for compliance. Modifications that partially resolve VFDRs are considered required (necessary) but not alone sufficient for compliance.

The tables below provide the correlation of each modification to specific VFDRs resolved, either partially or fully. The first column, Item, contains a modification identifier corresponding to the modification identifier in Attachment S. The second column contains the set of VFDRs by fire area (if any) that are fully or partially resolved by the modification. The third column contains additional clarifying comments.

As discussed above, not all modifications were designed to resolve VFDRs:

some were designed for overall plant fire risk reduction (and intentionally, risk Page 69 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors reduction with respect to other hazards), while others were purely code-compliance type modifications. Likewise, not all VFDRs are fully or partially resolved by a modification.

The residual risk of all VFDRs not resolved fully by modification has been evaluated as acceptable, either with our without credit for recovery actions, as indicated in the Palisades LAR, Attachments G and W.

Page 70 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-1: Plant Modifications Completed VFDRs Resolved /

Item Comments

• Partially Resolved S1-1 None Completed modification resolved an Appendix R non-compliance issue.

S1-2 None Completed modification resolved an NFPA code non-compliance issue.

S1-3 FA-01: Completed modification resolved an Appendix R non-VFDR-0231/ENP-1270* compliance issue.

FA-02:

VFDR-0232/ENP-1269* Modification does not eliminate need for ex-primary control FA-04: station actions to align fire protection pumps for long term AFW supply.

VFDR-0177/ENP-1177*

FA-09:

Therefore, no VFDRs are fully resolved by this VFDR-0091/ENP-1348* modification. Modification ensures survivability of fire pump FA-23: such that ex-primary control station action remains VFDR-0218/ENP-1195* feasible.

However, since modification partially resolves the indicated VFDRs it is considered a modification required for compliance.

Page 71 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved S2-1 None Modification provides overall plant risk reduction for combinations of failures of recovery actions, fire-induced failures and random failures in secondary side decay heat removal.

S2-2 FA-03: Modification addresses some but not all conditions that VFDR-0146/ENP-1092* require ex-primary control station actions for EDG alignment to safety-related 2400 VAC buses.

VFDR-0343/ENP-1408*

FA-04:

VFDR-0350/ENP-1417* Therefore, no VFDRs are fully resolved by this modification.

However, since modification partially resolves the indicated VFDRs it is considered a modification required for compliance.

S2-3 FA-03: Modification addresses some but not all conditions that VFDR-0146/ENP-1092* require ex-primary control station actions for EDG VFDR-0343/ENP-1408* alignment to safety-related 2400 VAC buses.

FA-04:

Therefore, no VFDRs are fully resolved by this VFDR-0350/ENP-1417*

modification.

However, since modification partially resolves the indicated VFDRs it is considered a modification required for compliance.

S2-4 FA-01: Modification fully resolves the indicated VFDRs.

VFDR-0323/ENP-1387 FA-02:

VFDR-0330/ENP-1394 FA-03:

VFDR-0134/ENP-1078 S2-5 FA-01: Modification fully resolves the indicated VFDRs.

VFDR-0086/ENP-1051 FA-02:

VFDR-0055/ENP-1007 FA-03:

VFDR-0154/ENP-1100 FA-04:

VFDR-0188/ENP-1128 FA-06:

VFDR-0364/ENP-1470 FA-13:

VFDR-0362/ENP-1467 FA-14:

VFDR-0247/ENP-1210 FA-21:

VFDR-0363/ENP-1468 FA-23:

VFDR-0216/ENP-1193 S2-6 FA-03: Modification addresses some but not all conditions that VFDR-0128/ENP-1071* require ex-primary control station actions for AFW pump operation.

Page 72 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved FA-04:

VFDR-0166/ENP-1138* Therefore, no VFDRs are fully resolved by this FA-13: modification.

VFDR-0266/ENP-1256*

However, since modification partially resolves the indicated VFDRs it is considered a modification required for compliance.

S2-7 FA-13: Modification addresses some but not all conditions that VFDR-0272/ENP-1262* require ex-primary control station actions to align and support HPSI pump operation for inventory control.

Therefore, no VFDRs are fully resolved by this modification.

However, since modification partially resolves the indicated VFDR it is considered a modification required for compliance.

S2-8 None Modification ensures additional time margin is available for ventilation alignment for EDG room cooling.

S2-9 FA-04: Modification addresses some but not all conditions that VFDR-0350/ENP-1417* require ex-primary control station actions for EDG alignment to safety-related 2400 VAC buses.

Therefore, no VFDRs are fully resolved by this modification.

However, since modification partially resolves the indicated VFDR it is considered a modification required for compliance.

S2-10 FA-01: FA-22: Modification fully resolves the indicated VFDRs.

VFDR-0231/ENP-1270 VFDR-0197/ENP-1184 VFDR-0307/ENP-1351 FA-23:

FA-02: VFDR-0218/ENP-1195 VFDR-0232/ENP-1269 VFDR-0306/ENP-1350 VFDR-0308/ENP-1352 FA-24:

FA-03: VFDR-0202/ENP-1199 VFDR-0151/ENP-1097 FA-25:

FA-04: VFDR-0208/ENP-1236 VFDR-0177/ENP-1177 FA-26:

VFDR-0309/ENP-1353 VFDR-0234/ENP-1205 FA-05: FA-27:

VFDR-0097/ENP-1107 VFDR-0195/ENP-1203 FA-06: FA-28:

VFDR-0108/ENP-1150 VFDR-0235/ENP-1208 FA-07: FA-29:

VFDR-0189/ENP-1154 VFDR-0275/ENP-1220 FA-08: FA-30:

VFDR-0191/ENP-1156 VFDR-0276/ENP-1221 FA-09: FA-31:

VFDR-0091/ENP-1348 VFDR-0278/ENP-1223 FA-10: FA-32:

Page 73 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved VFDR-0209/ENP-1160 VFDR-0125/ENP-1266 FA-11: FA-33:

VFDR-0290/ENP-1271 VFDR-0200/ENP-1267 FA-12: FA-34:

VFDR-0292/ENP-1272 VFDR-0282/ENP-1227 FA-13: FA-35:

VFDR-0263/ENP-1253 VFDR-0284/ENP-1229 FA-14: FA-36:

VFDR-0243/ENP-1212 VFDR-0285/ENP-1230 FA-15: FA-38:

VFDR-0221/ENP-1161 VFDR-0286/ENP-1231 FA-16: FA-39:

VFDR-0212/ENP-1171 VFDR-0287/ENP-1232 FA-17: FA-40:

VFDR-0112/ENP-1158 VFDR-0288/ENP-1233 FA-18: FA-41:

VFDR-0116/ENP-1174 VFDR-0289/ENP-1234 FA-19: FA-56:

VFDR-0211/ENP-1175 VFDR-0359/ENP-1469 FA-21:

VFDR-0118/ENP-1178 S2-11 FA-01: Modification fully resolves the VFDRs that involve charging VFDR-0088/ENP-1054* pump spurious actuation / loss of control only (i.e., those without asterisks).

FA-02:

VFDR-0058/ENP-1010*

FA-03: Modification addresses some but not all conditions that require ex-primary control station actions to eliminate VFDR-0143/ENP-1089 spurious charging pump operation and support inventory VFDR-0144/ENP-1090* control.

VFDR-0361/ENP-1464*

FA-04: Therefore, only some VFDRs (those without asterisk) are VFDR-0180/ENP-1120 fully resolved by this modification.

FA-05:

VFDR-0101/ENP-1111 Since the modification partially resolves the VFDRs FA-06: indicated with asterisk and fully resolves VFDRs without asterisks it is considered a modification required for VFDR-0109/ENP-1151*

compliance.

FA-13:

VFDR-0257/ENP-1247 FA-16:

VFDR-0026/ENP-0975*

FA-21:

VFDR-0193/ENP-1268*

S2-12 None Modification provides overall plant risk reduction by supporting steam generator depressurization to provide alternate means of secondary side decay heat removal.

S2-13 FA-13: Modification addresses some but not all conditions that VFDR-0272/ENP-1262* require ex-primary control station actions to align and support HPSI pump operation for inventory control.

Therefore, no VFDRs are fully resolved by this modification.

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ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved However, since modification partially resolves the indicated VFDR it is considered a modification required for compliance.

S2-14 None Modification provides overall plant risk reduction by preventing spurious isolation of CCW to containment due to fire-induced valve-related cable faults.

S2-15 FA-01: Modification fully resolves the indicated VFDRs.

VFDR-0322/ENP-1386 FA-02:

VFDR-0329/ENP-1393 FA-03:

VFDR-0156/ENP-1102 FA-04:

VFDR-0176/ENP-1116 FA-14:

VFDR-0248/ENP-1211 FA-26:

VFDR-0241/ENP-1207 FA-34:

VFDR-0280/ENP-1225 S2-16 None Modification increases availability of a Non-Power Operation credited component under certain conditions.

S2-17 None Modification increases availability of a Non-Power Operation credited component under certain conditions.

S2-18 None Modification resolves an NFPA code non-compliance issue.

S2-19 None Modification extends operation of EC-150 panel under certain conditions.

S2-20 None Modification resolves an NFPA code non-compliance issue.

S2-21 FA-01: Modification does not eliminate need for ex-primary control VFDR-0077/ENP-1044* station actions to align charging suction from the SIRWT.

FA-02:

VFDR-0042/ENP-0994* Therefore, no VFDRs are fully resolved by this modification. Modification ensures survivability of valve FA-03:

such that ex-primary control station action remains VFDR-0140/ENP-1086* feasible.

FA-04:

VFDR-0165/ENP-1137* However, since modification partially resolves the indicated FA-06: VFDRs it is considered a modification required for VFDR-0104/ENP-1146* compliance.

FA-11:

VFDR-0006/ENP-0951*

FA-15:

VFDR-0224/ENP-1164*

FA-21:

VFDR-0122/ENP-1182*

Page 75 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved S2-22 None Modification resolves an NFPA code non-compliance issue.

S2-23 None Modifications prevent overall plant risk increase by ensuring electrical coordination remains consistent with PRA assumptions.

S2-24 None Modification resolves an NFPA code non-compliance issue.

S2-25 None Modification resolves an NFPA code non-compliance issue.

S2-26 FA-01: Modification resolves VFDRs that exist during cross-train VFDR-0070/ENP-1037 charger alignment only. Cross-train alignment is not the standard alignment modeled in the PRA.

VFDR-0071/ENP-1038 FA-02:

VFDR-0050/ENP-1002 VFDR-0051/ENP-1003 FA-05:

VFDR-0095/ENP-1105 FA-11:

VFDR-0008/ENP-0954 FA-12:

VFDR-0012/ENP-0962 FA-21:

VFDR-0360/ENP-1463 S2-27 None Modification resolves an NFPA code non-compliance issue.

S2-28 None Modification resolves an NFPA code non-compliance issue.

S2-29 None Modification resolves an NFPA code non-compliance issue.

S2-30 None Modification resolves an NFPA code non-compliance issue.

S2-31 None Modification resolves an NFPA code non-compliance issue.

S2-32 None Modification resolves an NFPA code non-compliance issue.

S2-33 None Modification eliminates 3-phase proper polarity hot short potential for FOGG valves.

S2-34 None Modification resolves an NFPA code non-compliance issue.

S2-35 None Modification resolves an NFPA code non-compliance issue.

S2-36 None Modification resolves an NFPA code non-compliance issue.

Page 76 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors Additional Information for Table S-2: Plant Modifications Committed VFDRs Resolved /

Item Comments

• Partially Resolved S2-37 None Modification resolves an NFPA code non-compliance issue.

S2-38 FA-32: Modification resolves an NFPA code non-compliance VFDR-0123/ENP-1264 issue, and in addition modification fully resolves the VFDR-0124/ENP-1265 indicated VFDRs.

S2-39 None Modification resolves an NFPA code non-compliance issue.

S2-40 None Modification resolves an NFPA code non-compliance issue.

S2-41 None Modification resolves an NFPA code non-compliance issue.

S2-42 None Modification resolves an NFPA code non-compliance issue.

Page 77 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors NRC Request

4. LAR Attachment F describes the process for evaluating MSOs at Palisades, including use of the expert panel approach per FAQ 07-0038, Revision 3. In the Results of Step 1 section, generic industry sources of information used for both MSO reviews are cited but no plant-specific sources are cited. Describe how plant-specific insights were used to identify and evaluate MSOs at Palisades.

ENO Response

4. Experienced, multi-disciplined expert panel review teams at Palisades utilized the following types of plant-specific knowledge bases to postulate possible fire damage scenarios and brainstorm possible plant consequences involving multiple spurious operations:

first-hand operating experience, typical and off-normal equipment performance, original and as-modified plant design, actual and potential plant consequences resulting from upset conditions, thermal-hydraulic/neutronic licensing basis safety analysis, boundary conditions and assumptions, and integrated plant and operator response experience.

The expert panel included personnel with extensive Palisades-specific expertise in:

Operations, Fire Fighting (Fire Marshall),

Design Engineering, Electrical Engineering, System Engineering, Safe Shutdown Analysis, Circuit Analysis, Thermal-Hydraulic Analysis, Neutronics Analysis, and Probabilistic Risk Assessment The expert panel and/or multiple spurious operation (MSO) development teams included many of the same plant individuals that developed detailed logic models, containment analysis, and source term modeling supporting historic licensing basis activities, such as a 1982 SEP issue. The expert panel and/or MSO development teams also included individuals responsible for several areas Page 78 of 79

ATTACHMENT 1 Response to Clarification Request License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors of the FSAR Chapter 14 licensing analysis and basis, Appendix R, and Fire Protection safety reviews.

Plant specific data sources included:

piping and instrumentation diagrams (P&IDs),

electrical single line and circuit drawings, training documents, internal and external events PRA models and insights, safe shutdown equipment list, safe shutdown logic diagrams, post-fire safe shutdown analysis (SSA),

plant operating procedures (normal, emergency, post-fire and abnormal operating procedures),

self-assessment results, operating experience, and walk-down notes and pictures.

These information sources provided insights that were used in conjunction with the expertise of the team and generic industry information sources to identify potential MSO scenarios of concern for Palisades. Plant-specific and generic industry information sources are explicitly referenced in Report #: 0247 0005.04, Multiple Spurious Operations (MSO) Report, which was authored by plant personnel.

The effort to identify and evaluate potential MSOs did not end with the conclusion of the expert panel. NFPA 805 project staff continually evolved and refined the MSO work during NFPA 805 model development and analysis. The expert panel was re-convened at the conclusion of the work to ensure concurrence with any new MSOs, insights and evaluations, as documented in Report #: 0247 0005.04.

This report was then used to identify component MSO failure combinations to be included in the safe shutdown analysis to develop VFDRs and ensure the nuclear safety capability assessment also identified these MSO conditions. The results of this work are outlined in PLP-RPT-12-00110, Multiple Spurious Operation (MSO) Identification and Evaluation.

Page 79 of 79