ML14350A212

Regulatory Audit Plan; January 12-14, 2015 Audit in Support of the Amendment Request to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition

ML14350A212
Person / Time
Site:	Waterford
Issue date:	12/22/2014
From:	Michael Orenak Plant Licensing Branch IV
To:	Entergy Operations
Wang A
References
TAC ME7602
Download: ML14350A212 (10)

Text

UNITED STATES*

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 22, 2014 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3- REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT A RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION PROGRAM (TAC NO. ME7602)

Dear Sir or Madam:

By letter dated November 17, 2011, as supplemented by letters dated January 26, September 27, and October 16, 2012; May 16, June 26, and December 18, 2013; and June 11, 2014, Entergy Operations, Inc., submitted a license amendment request (LAR) to change its fire protection program to one based on the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated in the Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, paragraph 50.48(c).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit of the Waterford Steam Electric Station, Unit 3, LAR should be conducted in accordance with the Office of Nuclear Reactor Regulation Office Instruction, LIC-111, "Regulatory Audits," for the NRC staff to gain a better understanding of the licensee's calculations, proposed plant modifications, and other aspects of the LAR. The audit will be held the week of January 12, 2015.

A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit for the licensee's information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensee's processes or procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under 10 CFR 50.71, "Maintenance of records, making of reports," and/or 10 CFR 54.37, "Additional records and record-keeping requirements," that although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensee's submitted information.

If you have any questions, please contact me at 301-415:..3229 or via e-mail at Michaei.Orenak@nrc.gov.

Sincerely,

~ jy{)JJu Michael D. Orenak, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Audit Plan cc w/enclosure: Distribution via Listserv

REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED,*PERFORMANCE BASED FIRE PROTECTION PROGRAM ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 BACKGROUND

By letter dated November 17, 2011, as supplemented by letters dated January 26, September 27, and October 16, 2012; May 16, June 26, and December 18, 2013; and June 11, 2014 (References 1 through 8), Entergy Operations, Inc. (Entergy), the licensee for Waterford Steam Electric Station, Unit 3 (Waterford 3), submitted a license amendment request (LAR)to change its fire protection program (FPP) to one based on the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.48(c). '

In May 2012, the U.S. Nuclear Regulatory Commission (NRC) conducted a regulatory audit to verify information submitted in the licensee's original LAR. In response to NRC's feedback, audit interactions, as well as information shared regarding the basis for several requests for additional information (RAis), Entergy submitted a supplement to its original LAR on December 18, 2013 (Reference 7), t6 update selected analyses to remove reliance on any probabilistic risk assessment (PRA) unreviewed analysis methods.'

The licensee identified the following benefits associated with updating its analyses:

1. Utilizing only NRC-accepted analysis methods minimizes the need for license conditions accompanying the Safety Evaluation.

2. Results indicate improved risk metrics due to more rigorous analysis.

3. The more rigorous analysis revealed a previously unidentified vulnerability to transient combustibles in one fire area, allowing the plant to promptly address the issue.

4. Updating the Internal Events PRA (necessary to support the Fire PRA) provides a sound basi~ for future analyses.

The NRC staff's review of the supplement has commenced in accordance with the Office of Nuclear Reactor Regulation's (NRR's) Office Instruction LIC-1 01, "License Amendment Review Procedures." The NRC staff has determined that an additional regulatory audit of the Enclosure

supplement to the original Waterford 3 LAR should be conducted in accordance with the NRR Office Instruction LIC-111, "Regulatory Audits," for the NRC staff to gain a better understanding of the licensee's calculations, proposed plant modifications, and other aspects of the LAR.

This regulatory audit is a planned, LAR-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is usually conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit of the licensee's information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensee's processes or procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under 10 CFR 50.71, "Maintenance of records, making of reports," and/or 10 CFR 54.37, "Additional records and record-keeping requirements," that although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensee's submitted information.

The objectives of this additional regulatory audit are to:

• Gain a better understanding *of the detailed calculations, analyses and bases underlying the NFPA 805 LAR and to confirm the NRC staff's understanding of the LAR;

• Identify additional RAis necessary for the NRC staff to reach the licensing decision on the LAR;

• Verify that the licensee's planned process for self-approval of FPP changes will meet the proposed NFPA 805 license condition and quality requirements;

• Establi.sh an understanding of proposed plant modifications necessary to implement NFPA 805; and,

• Verify the implementation of processes and/or procedures that the licensee committed to as part of NFPA 805 implementation.

2.0 REGULA TORY AUDIT BASIS The basis of this audit is the licensee's supplements to the original LAR (References 2 through

8) and the NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," (SRP) Section 9.5.1.2, "Risk-Informed, Performance-Based Fire Protection Prog~am," Revision 0 (Reference 9). References 10 through 14 provide additional information that will be used to support the audit.

3.0 REGULATORY AUDIT SCOPE OR METHOD The NRC staff will review the licensee's NFPA 805 transition as proposed in the LAR, as supplemented. The NRC staff may review a sample of fire risk assessments and fire risk evaluations for one or more fire areas, the evaluation of the additional risk of recovery actions, the licensee's process for self-approving post-transition FPP changes, cumulative risk and

combined changes, as well as uncertainty and sensitivity analyses. The review may also include licensee risk-informed (RI) evaluations to ensure that defense-in-depth and safety margins have been evaluated.

The NRC staff will also review the licensee's assessment of the technical adequacy of the PRA model used for risk evaluations required to transition to a Rl/performance-based (RI/PB) FPP, including resolution of peer review findings and licensee self-assessments. This effort may include auditing a sample of logic models and calculations in the Fire PRA (FPRA) model as well as the Internal Events PRA model. The review will include, as necessary, the licensee's process that has been or will be implemented to maintain the quality of the Internal Events PRA and FPRA models to support self-approval using the Plant Change Evaluation process for post-transition Rl changes.

The scope may also include, as appropriate, selected plant modifications to confirm they have been appropriately characterized in the LAR. The NRC staff may review the process for controlling compensatory measures to confirm their adequacy while they remain in effect until.

the modifications are completed.

In addition, the audit may review program documentation, configuration control, and the FPP quality assurance program. The FPP design basis document may be reviewed, as well as other documentation of fire hazards identification and nuclear safety capability assessments. The review may include configuration control of the FPP design basis document, the FPRA methods and model, and other relevant documentation as necessary. The NRC staff may also review the FPP quality assurance program, and sample fire models and fire model calculations.

Walkdowns may be performed as necessary to observe features of the licensee's FPP and' design elements of buildings within the power block.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC audit team will require access to licensee personnel who are knowledgeable regarding the technical aspects of the supplemented Waterford 3 LAR. At a minimum, a hard copy and electronic copy of the following documentation should be available to the audit team:

• Calculation models and supporting documentation for PRA models used in support of the LAR, including peer review history and resolution of peer review significant findings;

• Calculation models and supporting documentation for fire models used in support of the LAR; . .

• Procedures that have been modified or developed to transition to the NFPA 805 licensing basis;

• Procedures that have been modified or developed to maintain the NFPA 805 licensing basis after transition is completed;

• Documentation of changes made to PRA models in support of change analysis;

• Documentation about PRA configuration control and procedures to support self-approval of risk-informed plant changes for post-transition Plant Change Evaluations.

• Documentation of plant modifications or operational changes identified, screened, and considered (or planned for) during the licensee's transition to NFPA 805;

• Calculations and evaluations used to transition to NFPA 805 such as plant change evaluations, engineering equivalency evaluations, and recovery action evaluations; and,

• Other documents that the licensee deems necessary to support the NRC staff's audit activities.

5.0 TEAM ASSIGNMENTS The audit will be conducted by NRC staff from NRR, Division of Risk Assessment, Fire Protection Branch and the PRA Licensing Branch that are knowledgeable in PRA, fire modeling, and fire protection engineering. Contractors from the Pacific Northwest National Laboratory and the Center for Nuclear Waste Regulatory Analysis will be utilized to augment the technical team members. Observers at the audit may include NRR Program Managers and various Regional Inspectors.

The NRC Audit Team Leader will be Leslie Fields and the NRC Technical Lead will be

• Paul Lain. The team leader will conduct daily briefings on the status of the review and coordinate audit activities while on site. The tables below show (1) audit milestones and schedule, and (2) planned audit team composition and their assigned areas for review during the audit.

Audit Milestones and Schedule Relative to First Audit Day Onsite (01/12/15)

Activity Time Frame Comments Request licensee to provide an NFPA 805 LAR overview Onsite Audit Kick-Off Meeting 01/12/15 presentation with important site-specific information.

Onsite Escorted Tour 01/13/15 Tours of risk significant power block areas.

01/12/15- Meet with licensee to provide a summary of any End of Day Summary Meeting 01/13/15 significant findings and requests for additional assistance.

01/12/15- Facilitate discussion between site and staff technical Provide Break-out Areas 01/14/15 areas.

Onsite Audit Exit Meeting 01/14/15 Reviewers at licensee location for 3 days.

Audit Summary (see 8.0) 02/28/15 To document the audit.

Regulatory Audit Team and Assignments SRP Section 9.5.1.2 Audit Plan Review Areas Lead Support 111.1.2 Modifications Team Team 111.3.2.2 Operations guidance for fire modeling PB method B. Metzger M. Janssens 111.5.3-5.6 Risk assessments D. Gennardo G. Coles 111.5.1 PRA technical adequacy D. Gennardo G. Coles 111.5.2 . Defense-in-depth and safety margins Team Team Plant walk-downs As needed As needed 6.0 LOGISTICS This regulatory audit is planned to take place during the week of January 12, 2015, and last approximately 2.5 days. This date is subject to change based on mutual agreement between the licensee and the NRC. An entrance meeting for this audit will be held on the first day at 1:00 p.m., and an exit meeting will be held the final audit day at 4:00p.m. to provide preliminary feedback to the licensee. The NRC audit leader plans to provide a daily progress update to licensee personnel on the second and third day of the audit.

The audit will take place at a location agreed upon by the licensee and NRC audit leader where

( 1) the necessary reference material and (2) appropriate analysts will be available to support the review. Because the audit scope includes NRC staff walkdowns of selected fire areas in the

\ power block, the regulatory audit must be conducted in a location that supports escorted access to the plant protected area.

7.0 SPECIAL REQUESTS The regulatory audit team requests the following to support the regulatory audit:

• Escorted access to fire areas within the protected area.

• Two computers, internet access, site portal access, and printing capaqility.

• A main NRC conference room set up for 8-10 NRC staff and contractors. An additional conference room to accommodate up to 15 people for PRA technical discussions. Each room should have conference call capability.

• Access to FPP documentation, including but not limited to: plant drawings depicting fire area boundaries, the Fire Hazards Analysis, and the Internal Events PRA and FPRA.

• Access to licensee personnel knowledgeable in the NFPA 805 FPP: FPRA and Internal Events PRA, Fire Modeling and the NFPA 805 fire protection design-basis document.

8.0. DELIVERABLES A regulatory audit summary will be issued and placed in the Agencywide Documents Access and Management System (ADAMS) within approximately 30 business days after the completion of the audit. The summarywill use the guidance of NRR Office Instruction LIC-111 for content.

9.0 REFERENCES

1. Jacobs, Donna, Entergy Operations, Inc.; letter to U.S. Nuclear Regulatory Commission, "License Amendment Request to Adopt NFPA .805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition), Waterford Steam Electric Station, Unit 3," dated November 17, 2011*(ADAMS Accession No. ML113220230).

2. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information in Support of the NRC Acceptance Review of Waterford 3 License Amendment Request to Adopt NFPA 805, Waterford Steam Electric Station, Unit 3,"

dated January 26, 2012 (ADAMS Accession No. ML12027A049).

3. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, J "Response to Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request, Waterford Steam Electric Station, Unit 3," dated September 27, 2012 (ADAMS Accession No. ML12272A099).

4. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "90-Day Response to Request for Additional Information Regarding Adoption of National

• Fire Protection Association Standard NFPA 805, Waterford Steam Electric Station, Unit 3,"

dated October 16, 2012 (ADAMS Accession No. ML12290A215).

5. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to 2nd Round R~quest for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA 805, Waterford Steam Electric Station, Unit 3,"

dated May 16, 2013 (ADAMS Accession No. ML13137A128).

6. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Milestones for Schedule of Attachment Revisions to NFPA 805 License Amendment Request (LAR), Waterford Steam Electric Station, Unit 3 (Waterford 3)," dated June 26, 2013 (ADAMS Accession No. ML13178A141).. .

7. Jacobs, Donna, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplement to NFPA 805 .License Amendment Request (LAR), Waterford Steam Electric Station, Unit 3 (Waterford 3)," dated December 18, 2013 (ADAMS Accession No. ML13365A325).

8. Chisum, Michael, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Updated Responses to Request for Additional Information Regarding Adoption of National

• Fire Protection Association Standard NFPA 805 License Amendment Request (LAR),

Waterford Steam Electric Station, Unit 3 (Waterford 3)," dated June 11, 20-14 (ADAMS

• Accession No. ML14162A506).

9. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 9.5.1.2, "Risk-Informed, Performance-Based Fire Protection Program," Revision 0, December 2009 (ADAMS Accession No. ML092590527).

10. Title 10 of the Code of Federal Regulations, Part 50, Section 50.48, "Fire protection."

11. National Fire Protection Association, NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Stations," 2001 Edition. *

12. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,"

December 2009 (ADAMS Accession No. ML092730314).

13. Nuclear Energy Institute, NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2, April 2008 (ADAMS Accession No. ML081130188).

14. Nuclear Energy Institute, NEI 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," Revi~ion 2, May 2009 (ADAMS Accession No. ML091770265).

ML14350A212 *via memo **via email OFFICE NRR/DORLILPL4-2/PM NRR/DORL/LPL4-2/PM NRR/DORLILPL4-2/LA NRR/DORLILPL4-2/LA**

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