ML14296A478

RAI - License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactors (MF0382)

ML14296A478
Person / Time
Site:	Palisades
Issue date:	10/23/2014
From:	Jennivine Rankin Plant Licensing Branch III
To:	Miksa J Entergy Nuclear Operations
References
MF0382
Download: ML14296A478 (4)

Text

1 NRR-PMDAPEm Resource From: Rankin, Jennivine Sent: Thursday, October 23, 2014 8:21 AM To:MIKSA, JAMES P (jmiksa@entergy.com); Smith, Keith E (ksmit21@entergy.com); Hazelhoff, Amy C (ahazelh@entergy.com)

Cc: Hardy, Jeffery A (jhardy@entergy.com); ERICKSON, JEFFREY S (JERICKS@entergy.com)

Subject:

Palisades Nuclear Plant - RAI - Lic ense Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Prot ection for Light Water Reactors (MF0382)

Attachments:RAIs.docx Mr. Miksa and Mr Erickson, By letter dated December 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12348A455), as supplemented by letters dated February 21, September 30, October 24, December 2, 2013, April 2, May 7, June 17, and August 14, 2014 (ADAMS Accession Nos. ML13079A090, ML13273A469, ML13298A044, ML13336A649, ML14092A126, ML14127A152, ML14169A046, and ML14226A498, respectively), Entergy Nuclear Operations, Inc. (ENO or the licensee) submitted a license amendment request (LAR) to revise Facility Operating License No. DPR 20 for Palisades Nuclear Plant. The LAR would permit transition of the fire protection licensing basis from Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(b), to 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805."

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided and determined that additional information is needed to complete the review.

A clarification teleconference was held on October 21, 2014. During the teleconference, it was agreed that ENO would provide the response to the attached RAIs by November 7, 2014. Please treat this e-mail as formal transmittal of the Request for Additional Information.

Thanks, Jennie Jennie Rankin, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Hearing Identifier: NRR_PMDA Email Number: 1659 Mail Envelope Properties (Jennivine.Rankin@nrc.gov20141023082100)

Subject:

Palisades Nuclear Plant - RAI - License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactors (MF0382) Sent Date: 10/23/2014 8:21:15 AM Received Date: 10/23/2014 8:21:00 AM From: Rankin, Jennivine Created By: Jennivine.Rankin@nrc.gov Recipients: "Hardy, Jeffery A (jhardy@entergy.com)" <jhardy@entergy.com> Tracking Status: None "ERICKSON, JEFFREY S (JERICKS@entergy.com)" <JERICKS@entergy.com> Tracking Status: None "MIKSA, JAMES P (jmiksa@entergy.com)" <jmiksa@entergy.com>

Tracking Status: None "Smith, Keith E (ksmit21@entergy.com)" <ksmit21@entergy.com> Tracking Status: None "Hazelhoff, Amy C (ahazelh@entergy.com)" <ahazelh@entergy.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 1479 10/23/2014 8:21:00 AM RAIs.docx 33415

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Request for Additional Information

PRA RA 01.j.01.01

By letter dated August 14, 2014 (ADAMS Accession No. ML14226A498), the response to PRA RAI 01.j.01 states that several 480V motor control centers (MCCs) do not postulate damage beyond the ignition source given that the MCCs are considered by the licensee to be well-sealed and robustly secured. Note that with respect to this issue, new guidance is being developed in draft FAQ 14-0009 to provide clarification of NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Assessing Software Quality" guidance on well-sealed and robustly secured cabinets housing circuits with voltages of greater than 440V. Relevant NRC Staff comments are provided in "NRC Comments on MCC Treatment White Paper August 29, 2014" (Comments) (ADAMS Accession number ML14245A133). The NRC comments support the use of a value of 0.1 to characterize the likelihood that such a fire can breach a well-sealed MCC cabinet and damage all cables within 6" from the top of the cabinet. While the NRC staff acknowledges that this guidance is considered draft, it may be used to determine the acceptability of transition risk.

i) Describe how fires breaching well-sealed cabinets are modelled consistent with current draft guidance; and, ii) Provide updated aggregate NFPA-805 Transition PRA results (currently summarized in the response to RAI 30) including fires that breach well-sealed cabinets. NFPA-805 Transition PRA results include total fire CDF and LERF, and CDF and LERF associated with transition. Confirm this update will be in the Fire PRA model to be used for self approval (i.e., implementation item).

PRA RAI 30.01 The response to PRA RAI 30 suggests that weaknesses associated with the Fire Probabilistic Risk Assessment (FPRA) HRA dependency analysis, namely PRA RAIs 01.h and 03 regarding updating the dependency analysis and PRA RAI 01.h.01 regarding its treatment of location, have not been incorporated in FPRA or the updated Attachment W results provided as to the letter dated August 14, 2014.

i) Are the updated dependency and location evaluations included in the updated Attachment W?

ii) If not, indicate whether incorporating the updated evaluations might cause the RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" acceptance guidelines to be exceeded and provide confidence (e.g., with an updated Implementation Item 3) that these evaluations will be completed before using the PRA to support self-

approval.

PRA RAI 30.a.01 The response to PRA RAI 30 states that the FPRA model to be used at the beginning of the self-approval of post-transition changes "would exclude modifications not implemented at the time". Noting that all PRA-credited implementation items and modifications must be completed prior to use of the FPRA model for self-approval, clarify this statement.

PRA RAI 30.c.01

With respect to PRA RAI 30 and Attachment W:

a. Confirm that the updated Attachment W results provided in Attachment 4 to the letter dated August 14, 2014 reflect all the revisions to VFDRs and recovery actions identified in Attachment 2 to the same letter.

b. The revised Attachment W, Table W-2, provides negative CDF and LERF Transition risk. Implementation Item 8 indicates that the final risk estimates that will be developed after all modifications and method changes associated with transition are completed will be assessed against these negative values instead of the RG 1.174 acceptable risk increase guidelines. RG 1.174 acceptance guidelines may also be used. If changes to the proposed language in Implementation Item 8 are desired to reflect this, please provide updated proposed language for Implementation Item 8.