2CAN051404, Response to Request for Additional Information Adoption of National Fire Protection Association Standard NFPA-805

Response to Request for Additional Information Adoption of National Fire Protection Association Standard NFPA-805

ML14142A410
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/22/2014
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN051404
Download: ML14142A410 (17)

Text

s Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One 2CAN051404 May 22, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information Adoption of National Fire Protection Association Standard NFPA-805 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

By letter dated March 28, 2014 (Reference 6), the NRC requested additional information associated with the Entergy Operations, Inc. (Entergy) request to amend the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS) and licensing bases to comply with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants. The amendment request followed Nuclear Energy Institute (NEI) 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c). The submittal (Reference 1) described the methodology used to demonstrate compliance with, and transition to, National Fire Protection Association (NFPA)-805, and included regulatory evaluations, probabilistic risk assessment (PRA), change evaluations, proposed modifications for non-compliances, and supporting attachments.

Attachment 1 includes the Entergy responses to Reference 6 questions. In addition to this response, the Nuclear Energy Institute (NEI) notified industry NFPA 805 applicants of an update to the NFPA 805 License Condition to be adopted by all NFPA 805 plants. The request adds the following sentence in the License Condition section entitled Other Changes that May Be Made Without Prior NRC Approval.

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

This statement is, therefore, added to the appropriate ANO-2 Operating License page. In addition to the above, ANO-2 TS Page 6-3 was changed by Amendment 296. The change was associated with unit staff qualifications.

2CAN051404 Page 2 of 3 of this letter includes a markup and clean (revised) Operating License and TS page associated with the changes identified above. Entergy requests the NRC replace the equivalent pages contained in Enclosures 2 and 3 of the Reference 1 letter with those provided in Attachment 2 of this letter.

Changes or additional information, as detailed in this letter, with respect to the original Entergy request (Reference 1) have been reviewed and Entergy has determined that the changes do not invalidate the no significant hazards consideration included in the Reference 1 letter.

In accordance with 10 CFR 50.91(b)(1), a copy of this application and the reasoned analysis about no significant hazards consideration is being provided to the designated Arkansas state official.

This letter contains one new commitment associated with non-cable intervening combustible configurations, included in Attachment 3 of this letter.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 22, 2014.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/dbb Attachments:

1. Responses to Request for Additional Information - ANO-2 Transition to NFPA-805

2. Markup and Clean (Revised) ANO-2 TS Replacement Pages

3. List of Regulatory Commitments

2CAN051404 Page 3 of 3

REFERENCES:

1. Entergy letter dated December 17, 2012, License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (2CAN121202)

(ML12353A041)

2. NRC letter dated September 11, 2013, Arkansas Nuclear One, Unit 2 -

Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA-805 (TAC No. MF0404)

(2CNA091301) (ML13235A005)

3. Entergy letter dated November 7, 2013, Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (2CAN111301) (ML13312A877)

4. Entergy letter dated December 4, 2013, Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (2CAN121302) (ML13338A432)

5. Entergy letter dated January 6, 2014, Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (2CAN011401) (ML14006A315)

6. NRC letter dated March 28, 2014, Arkansas Nuclear One, Unit 2 -

Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA-805 (2CNA031401)

(ML14085A225) cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Peter Bamford MS O-8B3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 to 2CAN0051404 Responses to Request for Additional Information ANO-2 Transition to NFPA-805 to 2CAN051404 Page 1 of 6 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ANO-2 Transition to NFPA-805 By letter dated March 28, 2014 (Reference 6), the NRC requested additional information associated with the Entergy Operations, Inc. (Entergy) request (Reference 1) to transition the Arkansas Nuclear One, Unit 2 (ANO-2), fire protection licensing basis to National Fire Protection Association (NFPA) Standard NFPA-805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition). The following include the responses to the subject questions. The respective question is included for convenience.

Fire Modeling (FM) RAI 01.03 In Entergy's letter dated January 6, 2014, the licensee responded to FM RAI 01.f and 01.g and stated that new zone of influence (ZOI) and hot gas layer (HGL) tables were developed that are applicable to ignition source-cable tray configurations. The ZOI and HGL were calculated for a number of ignition sources without any intervening combustibles, and in combination with various cable tray configurations. The ZOI dimensions and HGL temperatures are tabulated as a function of time, compartment volumes, vent sizes, and for different fire locations (open, wall, and corner) and ambient temperatures.

Please provide the following information:

a. An explanation regarding the extent that the new ZOI and HGL tables replace the generic fire modeling treatments (GFMTs) ZOI and HGL tables and whether the latter are still used for fires involving secondary combustibles.

b. A description concerning whether the new ZOI and HGL tables were used for the ignition sources without intervening combustibles and if so, how.

c. An explanation regarding how the effect of ambient temperature is accounted for in the ZOI and HGL determination.

Response

a) The new ZOI (developed in PRA-A2-05-017 Combined Ignition Source - Cable Tray Fire Scenario ZOIs for Arkansas Nuclear One Unit 2 Applications) and HGL tables (developed in PRA-A2-05-018 Evaluation of the Development and Timing of Hot Gas Layer Conditions in Generic ANO-2 Fire Compartments with Secondary Combustibles) are used for fire scenarios with secondary combustibles involving cable trays. The ignition sources located within the plant were walked down to identify the presence of secondary combustibles for each detailed fire scenario. The existing zone of influence developed in the Generic Fire Modeling Treatments (GFMTs), Rev. 0, which was the basis for the scenarios submitted with the LAR, was expanded to capture any new targets for scenarios where the presence of secondary combustibles resulted in non-conservative ZOIs when compared with ZOIs developed in PRA-A2-05-017. Scenarios with no secondary combustibles use the ZOIs documented in the GFMTs (including Supplement 3 to the GFMTs [Entergy Calculation PRA-ES-05-006] for ZOIs associated with 317 kW Transient Fires).

to 2CAN051404 Page 2 of 6 The timing to HGL developed in PRA-A2-05-018 completely supersedes Supplement 2 of the GFMTs in the ANO-2 Fire PRA, since Supplement 2 was based on the single configuration of two fully loaded cable trays, which is also included as a specific configuration in PRA-A2-05-018.

b) Please see response to FM RAI 01.03.a.

c) For detailed scenarios in the ANO-2 Fire PRA, the nominal ZOI is applicable within the zone boundary up to an 80 °C ambient temperature threshold (as discussed in Section 6.1.2 of the GFMT Report 1SPH02902.030, Rev. 0). The time to HGL is conservatively used as the time for the ambient temperature to reach the 80 °C threshold and a manual non-suppression probability is applied (per NUREG/CR-6850, Chapter 14) to determine the fraction of fires which would not be suppressed prior to reaching the 80 °C threshold. For the fraction of fires that are not suppressed, a larger ZOI is applied, typically and conservatively assumed to be full room burnout. The nominal ZOI can be expanded to use the ZOI associated with the non-IEEE 383 cable damage temperature which has an ambient temperature threshold of 220 °C (vs. 80 °C) when applied to scenarios with thermoset cables (see Section 6.1.2, last paragraph of the GFMT for a detailed discussion).

The use of the 220 °C threshold provides an intermediate step between the 80 °C ambient temperature threshold and a full room burnout for calculating the non-suppression probabilities for each scenario damage end state.

FM RAI 07 NFPA 805, Section 2.4.3.3, on acceptability states, in part, that The PSA [Probabilistic Safety Assessment] approach, methods, and data shall be acceptable to the AHJ [Authority Having Jurisdiction].

The NRC staff has noted the utilization of a number of accepted tools and methods in the analyses for transition, such as the Consolidated Model of Fire Growth and Smoke Transport (CFAST) and Fire Dynamic Tools (FDTs).

a. Please identify any fire modeling tools and methods that have been used in the development of the NFPA 805 LAR that are not already documented in the LAR and where their use or application is documented. Examples might include a methodology (empirical correlations and algebraic models) used to convert damage times for targets in Appendix H of NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities," September 2005 (ADAMS Accession No. ML052580075), to percent damage as a function of heat flux and time or Supplements to the GFMTs - Empirical Correlations and Algebraic Models.

b. For any tool or method identified in "a." above, provide the Verification and Validation (V&V) basis if not already explicitly provided in the LAR (for example in LAR Attachment J).

to 2CAN051404 Page 3 of 6

Response

a) The LAR Attachment J contains all of the fire modeling tools and methods used to develop the ANO-2 Fire PRA.

b) PRA-A2-05-003, Fire Scenarios Report, converts damage times for targets in Appendix H of NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, to percent damage as a function of heat flux and time. The question identifies this as an example of a method requiring V&V. However, using NUREG/CR-6850, Appendix H, the time to cable damage as a function of heat flux exposure does not constitute a new fire modeling tool or a method requiring V&V. The Appendix H data is used to establish the time to damage and the PRA uses the inverse of these values, which are damage accrual rates for the particular heat flux over time exposure condition. This approach is equivalent to the Arrhenius curve methodology used extensively for equipment qualification of nuclear power plant equipment and cables. The GFMTs have a V&V basis and provide the inputs (heat flux at a given distance) into this analysis. The heat fluxes from the GFMTs, the t2 fire growth profile, and the values from Appendix H in NUREG/CR-6850 are combined to generate a non-suppression probability (NSP) for a cable target at a given distance from the ignition source. Therefore, no fire modeling tools or methods have been used that are not already documented in the LAR.

Since no tools or methods are identified in a. above, additional V&V basis is not necessary.

FM RAI 08 In Entergy's letter dated January 6, 2014, the licensee responded to FM RAI 01.k and explained that during additional walkdowns, non-cable intervening combustibles were identified that were not considered in the FM analyses and that an implementation item was added to LAR Attachment S, Table S-2 to ensure that these combustibles will be appropriately controlled to support transition to NFPA 805.

Since non-cable intervening combustibles (e.g., fixed or in situ), are generally not subject to controls, the NRC staff questions this approach. Please provide a quantitative assessment of the impact on plant risk (core damage frequency (CDF), delta () CDF, large early release frequency (LERF) and LERF) of the fire scenarios that involve the non-cable intervening combustibles that were identified in the walkdowns.

Response

Existing non-cable intervening combustibles, as well as cable and other combustible material, that are fixed or in-situ are documented in the site Combustible Loading calculations. The installation of new non-cable intervening combustibles or other in-situ combustibles is controlled as part of the plant configuration change process in EN-DC-128, Fire Protection Impact Reviews, and EN-DC-115, Engineering Change Process. The combustible loading calculations document and monitor the total combustible loading within each fire area and are updated as plant changes occur. Therefore, control mechanisms are in place to address intervening combustibles from the aspect of total fire loading in each fire compartment. Note that the potential impact of intervening combustibles is being addressed as part of the transition to an NFPA 805 licensing basis.

to 2CAN051404 Page 4 of 6 The impact of intervening combustibles on the fire modeling used in transitioning to NFPA 805 is significant only in fire compartments in which full area burn-up is not assumed. Plant walkdowns of these fire compartments were performed recently to confirm the fire modeling is consistent with the presence, quantity, and location of non-cable intervening combustible materials.

In all cases, the identified non-cable intervening combustibles have already been addressed by the bounding combustible loading documentation for each fire area with respect to the impact on the deterministic fire analysis. Most of the identified non-cable intervening combustibles in the fire areas where full area burn-up is not assumed are considered insignificant. An insignificant combustible is considered to be one that is much smaller than the standard transient fuel package for an area and the effect of its involvement in a fire is within the uncertainty of the postulated transient fire scenario effects. In other words, an insignificant fixed or in-situ combustible is one that by itself would not support a large enough fire to damage a target, or would have a ZOI that is entirely encompassed by a transient fuel package and would not affect the dimensions of the ZOI for the postulated transient fuel package in the area, at least to the extent that exceeds the numerical uncertainty of the models used. Examples include small plastic signs, small diameter plastic tubing, small isolated plastic collection bags for drainage, eyewash stations, thin coatings of paint, etc.

A few cases of more significant non-cable intervening combustibles are being evaluated further.

Examples include open faced storage cabinets with paper storage (procedures), plastic process tubing over one-inch in diameter, worst case bounding fire loading in designated storage areas, fiberglass ladder storage areas, plastic covered radiation shielding, non-metallic shield covered piping or duct insulation, etc. The fire scenarios are being updated to incorporate the impact of these non-cable intervening combustible configurations and the numerical effects of the significant non-cable intervening combustible fire scenarios will be provided as part of the integrated analysis requested in draft PRA RAI 21.

FM RAI 09 Please explain how high energy arcing fault (HEAF) initiated fires were addressed in the HGL calculations and multi-compartment analysis (MCA) and provide technical justification for the approach that was used to calculate HGL development timing. More specifically, please confirm whether the guidance provided in NUREG/CR-6850, page 11-19, fourth bullet regarding the fire growth, and the guidance provided on page M-13, sixth bullet regarding delay to cable tray ignition was followed. Also, considering the energetic nature of the HEAF events, provide justification for the heat release rate used in the HGL calculations for electrical cabinet fires following a HEAF.

Response

Electrical cabinet fires with the potential for HEAF can occur in six ANO-2 fire compartments. In two of these compartments, INTAKE and 2200-MM (turbine building), the compartment volumes and interaction with the outside atmosphere preclude development of a hot gas layer. Thus, HGL development timing is not calculated for these compartments. The non-HGL fire scenarios initiating in electrical cabinets with the potential for HEAF in INTAKE and 2200-MM assume instantaneous damage to all targets, including overhead cable trays, within a ZOI consistent with the peak heat release rate (HRR) for a 98th percentile medium voltage switchgear or load to 2CAN051404 Page 5 of 6 center fires in conjunction with the additional HRR due to the presence of any secondary combustibles. Use of the 98th percentile HRR for these scenarios is appropriate given the energetic nature of the HEAF events.

In the remaining four compartments (2091-BB, 2100-Z, 2101-AA, and 2108-S), HGL fire scenarios are calculated assuming an instantaneous full-room burnout with no credit for a time delay due to fire growth in the calculation of the NSP. Since all targets in the room are assumed to fail instantaneously, the guidance in NUREG/CR-6850 on page M-13, sixth bullet regarding no delay to cable tray ignition was followed. Also, since no credit was taken for a time delay due to fire growth in the NSP, the guidance in NUREG/CR-6850, page 11-19, fourth bullet regarding fire growth was also followed. Since an instantaneous full room burnout is assumed in the HEAF HGL scenarios, the HEAF HRR does not affect the HGL calculations; therefore, no additional justification for the HRR in the HGL scenarios is necessary.

The NSP for the MCA related to the HEAF fire scenarios are calculated based on a peak HRR (98th percentile as described above) at the time of the HEAF event (t=0) with no credit for the twelve minutes to peak fire growth.

Fire Protection Engineering (FPE) RAI 11.01 In Entergy's letter dated November 7, 2013, the licensee responded to FPE RAI 11 and stated that the fire brigade leader and fire brigade members are required to maintain non-licensed operator (NLO) qualifications. This qualification requires completion of plant systems training as part of a qualification program designed to give the NLO an understanding of the integrated nature and design of plant systems and structures.

NFPA 805 Section 3.4.1 (c) states, in part, that

...the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria.

In Section 1.6.4.1, "Qualifications," of NRC Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2, September 2009 (ADAMS Accession No. ML092580550), the NRC staff has acknowledged the following example for the fire brigade leader as sufficient:

The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems.

Please describe the training provided to the fire brigade leader that addresses their ability to assess the effects of fire and fire suppressants on nuclear safety performance criteria.

Response

As stated in procedure OP-1063.020, Fire Brigade Training Program, the fire brigade leader is qualified as a Waste Control Operator (WCO), the most qualified NLO. In addition, the fire brigade leader is required to complete fire brigade leader training and an associated practical examination prior to becoming the leader, and is required to maintain fire brigade member to 2CAN051404 Page 6 of 6 training requirements. The fire brigade training program ensures that the fire brigade leader is capable of taking charge at the scene of the fire affecting the respective unit to direct the fire brigade members and to coordinate fire brigade actions with the Control Room staff.

The scope of WCO training requirements is included in A2QC-WCO-QUAL, Unit 2 Waste Control Operator Systems Qualification Guide. A WCO will have completed Auxiliary Operator training prior to the WCO training and thus upon completion of WCO training is knowledgeable of both primary and secondary systems, as well as emergency and abnormal operating procedures. Examples of ANO-2 plant systems included in WCO training are reactor coolant, chemical and volume control, emergency feedwater, boron management, high pressure safety injection, low pressure safety injection/shutdown cooling, auxiliary building service water, electrical distribution, fire protection, ventilation, and radiation monitoring. The ANO approach meets the RG 1.189 guidance to comply with, or equivalent knowledge of plant systems.

Summary This letter provides the requested responses to NRC RAIs (Reference 6) associated with the ANO-2 NFPA-805 LAR dated December 17, 2012 (Reference 1). One new commitment is included in Attachment 3 of this letter:

With regard to the impact of non-cable intervening combustible configurations, the numerical effects of the significant non-cable intervening combustible fire scenarios will be provided as part of the integrated analysis requested in draft PRA RAI 21.

REFERENCES

1. Entergy letter dated December 17, 2012, License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (2CAN121202) (ML12353A041)

2. NRC letter dated September 11, 2013, Arkansas Nuclear One, Unit 2 - Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA-805 (TAC No. MF0404) (2CNA091301) (ML13235A005)

3. Entergy letter dated November 7, 2013, Response to Request for Additional Information -

Adoption of National Fire Protection Association Standard NFPA-805 (2CAN111301)

(ML13312A877)

4. Entergy letter dated December 4, 2013, Response to Request for Additional Information -

Adoption of National Fire Protection Association Standard NFPA-805 (2CAN121302)

(ML13338A432)

5. Entergy letter dated January 6, 2014, Response to Request for Additional Information -

Adoption of National Fire Protection Association Standard NFPA-805 (2CAN011401)

(ML14006A315)

6. NRC letter dated March 28, 2014, Arkansas Nuclear One, Unit 2 - Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA-805 (2CNA031401) (ML14085A225)

Attachment 2 to 2CAN051404 Markup and Clean (Revised) ANO-2 TS Replacement Pages

5 Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and, Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated ___________ to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. NPF-6 Amendment No.

Revised by letter dated July 18, 2007

5 Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and, Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated _________________ to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. NPF-6 Amendment No.

Revised by letter dated July 18, 2007

ADMINISTRATIVE CONTROLS 6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM).

6.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 6.3.1, perform the functions described in 10 CFR 50.54(m).

6.4 PROCEDURES 6.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978;

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Section 7.1 of Generic Letter 82-33;

c. Fire Protection Program implementation;Deleted

d. All programs specified in Specification 6.5; and

e. Modification of core protection calculator (CPC) addressable constants. These procedures shall include provisions to ensure that sufficient margin is maintained in CPC type I addressable constants to avoid excessive operator interaction with the CPCs during reactor operation.

Modifications to the CPC software (including changes of algorithms and fuel cycle specific data) shall be performed in accordance with the most recent version of CPC Protection Algorithm Software Change Procedure, CEN-39(A)-P, which has been determined to be applicable to the facility. Additions or deletions to CPC addressable constants or changes to addressable constant software limit values shall not be implemented without prior NRC approval.

ARKANSAS - UNIT 2 6-3 Amendment No. 255,296,

ADMINISTRATIVE CONTROLS 6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM).

6.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 6.3.1, perform the functions described in 10 CFR 50.54(m).

6.4 PROCEDURES 6.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978;

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Section 7.1 of Generic Letter 82-33;

c. Deleted

d. All programs specified in Specification 6.5; and

e. Modification of core protection calculator (CPC) addressable constants. These procedures shall include provisions to ensure that sufficient margin is maintained in CPC type I addressable constants to avoid excessive operator interaction with the CPCs during reactor operation.

Modifications to the CPC software (including changes of algorithms and fuel cycle specific data) shall be performed in accordance with the most recent version of CPC Protection Algorithm Software Change Procedure, CEN-39(A)-P, which has been determined to be applicable to the facility. Additions or deletions to CPC addressable constants or changes to addressable constant software limit values shall not be implemented without prior NRC approval.

ARKANSAS - UNIT 2 6-3 Amendment No. 255,296,

Attachment 3 to 2CAN051404 List of Regulatory Commitments to 2CAN051404 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE With regard to the impact of non-cable intervening combustible configurations, the In conjunction numerical effects of the significant non-with response to cable intervening combustible fire scenarios PRA RAI 21 will be provided as part of the integrated analysis requested in draft PRA RAI 21.