View source for PNP 2014-008, Palisades, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin Assessments

{{Adams
| number = ML14034A168
| issue date = 01/30/2014
| title = Palisades, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin Assessments
| author name = Vitale A J
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000255
| license number = DPR-020
| contact person = 
| case reference number = PNP 2014-008
| document type = Letter type:PNP
| page count = 4
| project = 
| stage = RAI
}}

=Text=
{{#Wiki_filter:a Entergy Entergy Nuclear Operations, Inc.Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2014-008 January 30, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 

==SUBJECT:==
Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding -Review of Available Physical Margin Assessments Palisades Nuclear Plant Docket 50-255 License No. DPR-20 

==REFERENCES:==

1.NRC letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated March 12, 2012 (ADAMS Accession Number ML1 2056A046).
: 2. NRC letter to Nuclear Energy Institute, "Endorsement of Nuclear Energy Institute (NEI) 12-07, 'Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"'
dated May 31, 2012 (ADAMS Accession Number ML12144A142).
: 3. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-101,"Flooding Walkdown Report -Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated November 27, 2012 (ADAMS Accession Number ML12332A377).
: 4. NRC letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns," dated December 23, 2013 (ADAMS Accession Number ML13325A891) 
/p t Pfi PNP 2014-008 Page 2 

==Dear Sir or Madam:==
On March 12, 2012, the NRC staff issued Reference 1, which requested information pursuant to Title 10 of the Code of Federal Regulations 50.54(f).
Enclosure 4 of that letter contains specific requested information associated with Near-Term Task Force Recommendation 2.3 for Flooding.
Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features." In Reference 3, Entergy Nuclear Operations, Inc.(ENO) submitted the final report in response to the request for information.
One of the requirements of NEI 12-07 is to identify the available physical margin (APM)associated with each flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the Staff identified additional information necessary to allow them to complete its assessments.
Accordingly, by Reference 4, the NRC staff has issued a request for additional information (RAI). The RAI questions and the ENO responses for the Palisades Nuclear Plant (PNP) are provided below.RAI Number 1: Confirmation that the process for evaluating APM was reviewed.ENO Response:
ENO has completed a review of the process used at PNP to evaluate available APMs.RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.ENO Response:
The original walkdown effort followed the guidance provided in NEI 12-07, including the definition for a small margin. Additional actions have been taken to make the process consistent with the information provided in this RAI.RAI Number 3: If changes are necessary, a general description of any process changes to establish this consistency.
ENO Response:
As stated above, the original walkdown effort followed the guidance provided in NEI 12-07, including a definition for a small margin. However, a specific APM had not been assigned to the seals associated with flood protection features.
PNP 2014-008 Page 3 These items have now been addressed in accordance with the guidance provided in this RAI.RAI Number 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of"significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions: Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occuras part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take PNP 2014-008 Page 4 interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response.Report the APM as "undetermined" and provide the CAP reference in the RAI response.ENO Response:
Approach B, described above, was used to determine the APM values for seals. When the seal pressure rating was not known, the APM for these seals is assumed to be greater than the pre-established small-margin threshold value.The conditions described above were met, as the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the PNP flooding licensing basis. All of the seals were inspected as part of the original walkdowns for signs of degradation, and corrective actions were taken, when required.This letter contains no new or revised commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January 30, 2014.Sincerely,/ajv/jse cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC}}