ML060800653

Application for Amendment to the Facility Operating License for Proposed Resolution of Kaowool Issues, Request for Additional Information (RAI)

ML060800653
Person / Time
Site:	Grand Gulf
Issue date:	03/24/2006
From:	Bhalchandra Vaidya Plant Licensing Branch III-2
To:	Gerald Williams Entergy Operations
vaidya B, NRR/DLPM, 415-3308
References
TAC MC8180
Download: ML060800653 (7)

Text

March 24, 2006Mr. George A. Williams Site Vice President Grand Gulf Nuclear Station Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 (GGNS), RE: APPLICATION FORAMENDMENT TO THE FACILITY OPERATING LICENSE (FOL) FOR PROPOSED RESOLUTION OF KAOWOOL ISSUES, REQUEST FOR ADDITIONAL INFORMATION (RAI) (TAC NO. MC8180)

Dear Mr. Williams:

By letter dated August 17, 2005, Entergy Operations, Inc. (the licensee) submittedan amendment request to the FOL for the proposed resolution of Kaowool issues at GGNS. The NRC staff reviewed the request and determined that additional information is required inorder to complete its evaluation. The NRC staff forwarded the draft RAIs to your MattCrawford, Ron Byrd, and Bill Brice, on February 1, 2006, and forwarded additional draft RAIs toMatt Crawford on February 24, 2006, along with a follow-up RAI on the draft response for RAI question number 1 on February 27, 2006. The above mentioned RAI questions are enclosed. At the request of Matt Crawford, the NRC staff has made several attempts to schedule atelephone discussion on the proposed responses to the RAIs without success. In order to complete NRC staff review of GGNS's request by July 1, 2006, please submit thesupplemental letter with responses to the RAIs by April 15, 2006. If you have any questions, please contact me promptly at (301) 415-3308.Sincerely,/RA/

Bhalchandra Vaidya, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-416 cc: See next page

Enclosure:

As stated March 24, 2006Mr. George A. Williams Site Vice President Grand Gulf Nuclear Station Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 (GGNS), RE: APPLICATION FORAMENDMENT TO THE FACILITY OPERATING LICENSE (FOL) FOR PROPOSED RESOLUTION OF KAOWOOL ISSUES, REQUEST FOR ADDITIONAL INFORMATION (RAI) (TAC NO. MC8180)

Dear Mr. Williams:

By letter dated August 17, 2005, Entergy Operations, Inc. (the licensee) submittedan amendment request to the FOL for the proposed resolution of Kaowool issues at GGNS. The NRC staff reviewed the request and determined that additional information is required inorder to complete its evaluation. The NRC staff forwarded the draft RAIs to your MattCrawford, Ron Byrd, and Bill Brice, on February 1, 2006, and forwarded additional draft RAIs toMatt Crawford on February 24, 2006, along with a follow-up RAI on the draft response for RAI question number 1 on February 27, 2006. The above mentioned RAI questions are enclosed. At the request of Matt Crawford, the NRC staff has made several attempts to schedule atelephone discussion on the proposed responses to the RAIs without success. In order to complete NRC staff review of GGNS's request by July 1, 2006, please submit thesupplemental letter with responses to the RAIs by April 15, 2006. If you have any questions, please contact me promptly at (301) 415-3308.Sincerely,/RA/

Bhalchandra Vaidya, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-416 cc: See next page

Enclosure:

As statedDISTRIBUTION

PUBLICRidsNrrDorlLplgRidsRgn4MailCenter (KKennedy)RidsOgcRpLPLIV r/fRidsNrrPMBVaidyaRidsAcrsAcnwMailCenterRidsNrrLADJohnsonRidsNrrDorlDprSWeerakkodyACCESSION NO: ML060800653* No substantial change from RAI MemoOFFICELPL4/PMLPL4/LAAFPB/BC *LPL4/BCNAMEBVaidyaDJohnsonSWeerakkodyDTeraoDATE03 / 23/200603 / 23/200602/16/200603 / 24/2006OFFICIAL RECORD COPY Enclosure Page 1 of 3GRAND GULF NUCLEAR STATION, UNIT 1APPLICATION FOR AMENDMENT TO THE FACILITIES OPERATING LICENSEREGARDING PROPOSED RESOLUTION OF KAOWOOL ISSUESTAC NO. MC8180REQUESTS FOR ADDITIONAL INFORMATIONRAI-1.In Section 4.2.3.3 on PSA [Probabilistic Safety Assessment] Quality, the licensee statesthat "... [R]evision [2] of the [GGNS] PSA addressed most of the important observationsresulting from the peer review and updated various elements of the analysis. This internal events model was used along with the detailed fire scenario and cable routing information from the GGNS Fire IPEEE [Individual Plant Examination of External Events]

analysis to develop an updated Fire PSA model that was used in the risk calculations for this analysis." Since the preceding seems to imply that, while most of the important observations from the peer review had been addressed prior to using the updated internal events model for this analysis, some important observations still remain to beaddressed. Please provide a list of these remaining important observations and discuss if failure to have addressed them in any way affects the results of this analysis. If there are any effects, how have they been accounted/compensated for in this analysis?RAI-2.In Section 4.2.3.1 on Core Damage Frequency (CDF) and the Risk Analysis portion ofAttachment 3, the licensee states that "[t]he transient fire frequency for each scenario isweighted based on the area that a fire must be in to result in damage to a given division

... [a]ccording to the Inspection Manual Chapter 0609, Appendix F [Fire ProtectionSignificance Determination Process (FPSDP)]." Has the licensee performed analternate evaluation for transient fire frequency, including weighting, using the more detailed reference which is the basis for the FPSDP, namely NUREG/CR-6850(Electrical Power Research Institute (EPRI) Topical Report (TR)-1011989), EPRI/NRC-RES [Office of Nuclear Regulatory Research] Fire PRA [Prababilistic Risk Assessment]Methodology for Nuclear Power Facilities? In Volume 2, Chapter 6, of this reference,both a different transient fire frequency and weighting scheme are recommended. A comparison between the results from the licensee's Fire Protection Significance Determination Process (FPSDP)-based estimates and those using NUREG/CR-6850should be provided, at least for sensitivity purposes.RAI-3.The table Determination of CDF on page 24 of Attachment 3, Change Analysis, lists theConditional Core Damage Probability (CCDP) for Scenario 316, Non-failed Division 2,as 1.62E-03. Table 3-12, Refined Results of Fire PRA, on page 19 of Enclosure 2,Grand Gulf [Nuclear Station] Fire PRA Quantitative Refinements, lists this same CCDPas 1.62E-04. Please correct whichever table is in error.RAI-4.Fire modeling analysis of cable interactions in the auxiliary building is based onthermoset cables. In a situation where cables are mixed in a cable tray, this would allow Enclosure Page 2 of 3a lower threshold for failure and ignition of thermoplastic cables. Thermoplastic cablescan provide a path for ignition of adjacent thermoset cables. Are there any situations with mixed cable types in a tray? What failure temperature was used in the fire modeling to damage redundant cables?RAI-5.Fire modeling results will always have a level of uncertainty. Uncertainties in thepredications of fire models arise from modeling simplifications employed by an analystor are inherent to the modeling tools used due to a lack of knowledge concerning the values of key model parameters. Discuss uncertainties associated with the fire modeling results presented in the evaluation.RAI-6.The column line labeling on the various drawings is difficult to read, which inhibits crossreferencing with the Background Section (pp. 7-13) of the submittal. Verify that eachfire scenario presented is protected by an automatic suppression system and anautomatic detecti on system. Are the fire areas under consideration protectedthroughout by automatic suppression and detection? Note any other defense-in-depth measures present for each fire scenario.RAI-7.The section Fire Scenarios on pages 16 and 17 of Attachment 3, Change Analysis

,describes two different types of miscellaneous fuel packages: trash bags and Class Acombustibles. The trash bags have unit heat release rates (kW/m

2) between 1.5 and 4 times that of the Class A combustibles, based on orientation. Provide a more specific reference for the unit heat release rate for the Class A material. Discuss the difference in unit heat release rates between the miscellaneous Class A fuel packages in the combustible storage areas and the trash bags assumed to be located in the combustible exclusion zones. Are any of the trash bags ever expected to be located in the combustible storage areas? What effect would this have on the fire scenarios presented?RAI-8.Describe the material composition of the trash collection bins referenced in the sectionFire Scenarios on page 16 of Attachment 3, Change Analysis. If the collection bins aremade from combustible material, discuss their effect on the appropriate fire scenarios. RAI-9.On page 21 of the section CDF of Attachment 3, Change Analysis, the assumption ismade that the "plausible floor area" used in the calculation of the Weighting Factor forTransient Fires is equal to 50% of the total floor area. This assumption is characterized as conservative. Estimate the actual plausible area in each of the fire zones. RAI-10 : Follow-up Question based on the review of Draft Response to RAI Question 1Are the unresolved deficiencies, cited as not appearing in or affecting the fire PRA, of apurely calculational nature such that (1) these initiators CANNOT be induced by fire, or (2) even if they could be induced by fire, the calculational deficiency would not carry over into the resulting accident sequence (i.e., event/fault trees)? For example, referencing the Facts and Observations (F&O) for Element AS-7, if a fire induced a T3B event and fire water was being used to suppress the fire, would there be some limit on the fire water's ability to also provide low pressure makeup to the Reactor Pressure Enclosure Page 3 of 3Vessel (RPV)? If so, is this degradation of the fire water capability (if any) reflected inthe fire CDF for a T3B fire-induced initiating event?

The response must ensure that, although the affected events cited in the F&O's are notfire initiators or fire-related failures, they CANNOT be induced or affected by fire-related failures that, on the surface, would appear to be totally unrelated but, under the surface, somehow could be connected (as discussed in the example for AS-7).

November 2005Grand Gulf Nuclear Station cc:Executive Vice President & Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205Winston & Strawn1700 K Street, N.W.

Washington, DC 20006-3817ChiefEnergy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P. O. Box 10385 Jackson, MS 39289-0385PresidentClaiborne County Board of Supervisors P. O. Box 339 Port Gibson, MS 39150Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 399 Port Gibson, MS 39150 General Manager, GGNSEntergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150Attorney GeneralDepartment of Justice State of Louisiana P. O. Box 94005 Baton Rouge, LA 70804-9005State Health Officer State Board of Health

P. O. Box 139 Jackson, MS 39205Office of the Governor State of Mississippi Jackson, MS 39201Attorney GeneralAsst. Attorney General State of Mississippi P. O. Box 220 Jackson, MS 39205Vice President, Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995DirectorNuclear Safety Assurance Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150DirectorNuclear Safety & Licensing Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213-8298