2CAN081202, Request for Extension of Enforcement Discretion

Request for Extension of Enforcement Discretion

ML12227A885
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/14/2012
From:	Schwarz C Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
2CAN081202, TAC ME6691, TAC ME6692, TAC ME8282
Download: ML12227A885 (47)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 2CAN081202 August 14, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Extension of Enforcement Discretion Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6

References:

1. Entergy letter dated March 27, 2012, License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (2CAN031201)

(ML12087A113)

2. NRC letter dated May 25, 2012, Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC No. ME8282) (ML121380395) (2CNA051202)

3. Entergy letter dated July 10, 2012, Supplemental to License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

(2CAN071202)

4. NRC letter dated July 28, 2011, Arkansas Nuclear One, Units 1 and 2 -

Commitment to Submit a License Amendment Request to Transition to 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, and Request to Extend Enforcement Discretion (TAC Nos. ME6691 and ME6692) (ML112030193) (0CNA071107)

5. Staff Requirements Memorandum SECY-12-0031, Enforcement Alternatives for Sites that Indicate Additional Time Required to Submit Their License Amendment Requests to Transition to 10 CFR 50.48(c) National Fire Protection Association Standard 805, dated February 24, 2012 (ML12025A349)

2CAN081202 Page 2 of 3

Dear Sir or Madam:

By letter dated March 27, 2012 (Reference 1), Entergy Operations, Inc. (Entergy) proposed to amend Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit 2 (ANO-2). This letter requested Nuclear Regulatory Commission (NRC) review and approval for adoption of a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide 1.205, Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants.

The letter described the methodology used to demonstrate compliance with, and transition to, National Fire Protection Association 805, and includes regulatory evaluations, probabilistic risk assessment, change evaluations, proposed modifications for non-compliances, and supporting attachments.

By letter dated May 25, 2012 (Reference 2), the NRC informed Entergy that supplemental information would be required to support completion of the NRCs acceptance review.

A draft of the supplemental information was presented to NRC staff members during public meetings held June 12 and 13, 2012, and June 29, 2012. A follow-up call with members of the NRC staff also occurred on July 2, 2012, where the NRC requested documentation of Entergys intent to address fire modeling revisions that would further support the requested supplemental information. As a result, discussion related to future fire modeling revisions was provided with the supplemental information, including a regulatory commitment to provide additional information by November 2, 2012.

Based on the above meetings and communications, Entergy submitted the supplemental information on July 10, 2012 (Reference 3). By teleconference on August 9, 2012, the NRC informed Entergy that, based on the need for additional information to allow NRC to complete its review of the ANO-2 license application request, the NRC could not complete the acceptance review at this time. Because the acceptance review cannot be completed, an extension of enforcement discretion previously granted for ANO-2 fire protection issues (Reference 4) is necessary. Given that additional time is required to understand the NRC concerns and incorporate an acceptable response into a revised submittal, Entergy requests an extension of enforcement discretion for fire protection issues until July 15, 2013.

Entergy commits to submit an ANO-2 License Amendment Request (LAR) implementing 10 CFR 50.48(c) prior to July 15, 2013 (see Enclosure 2 of this letter). Per the enforcement discretion policy, once the request is submitted and accepted, the enforcement discretion would then continue until the NRC dispositions the LAR.

By letter dated May 25, 2012 (Reference 2), the NRC outlined justification that would be required for an extension of enforcement discretion should Entergy be unable to provide sufficient supplemental information in a timely fashion that would support NRC acceptance of the LAR. Enclosure 1 to this letter contains information necessary to meet the Reference 2 requirements for enforcement discretion application.

Entergy requests the NRC issue a Confirmatory Order approving the requested enforcement discretion extension for ANO-2 as permitted by Reference 5.

Should you have any questions concerning this letter, or require additional information, please contact Stephenie Pyle at 479-858-4704.

2CAN081202 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 14, 2012.

Sincerely, ORIGINAL SIGNED BY CHRISTOPHER J. SCHWARZ CJS/dbb

Enclosures:

1. Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c)

2. List of Regulatory Commitments cc: Mr. Elmo E. Collins 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. Kaly Kalyanam MS O-8B1 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

Enclosure 1 to 2CAN081202 Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c) to 2CAN081202 Page 1 of 2 Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c)

In accordance with Section 9.1, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," of the NRC Enforcement Policy, dated July 12, 2011, and NRC letter to Entergy Operations, Inc. (Entergy) dated May 25, 2012, Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Adopt National Fire Protection Association Standard 805 (ML121380395), Entergy is providing the following justification in support of extending the current enforcement discretion period for fire protection issues for Arkansas Nuclear One, Unit 2 (ANO-2) as described in the cover letter to this Enclosure. The required information stated below is excerpted from the aforementioned NRC letter dated May 25, 2012. Key information associated with Entergys NFPA 805 transition process is included in italics.

1. Schedule of the key transition activities and major milestones for achieving the proposed new date including:

a. The preliminary design of specific plant modifications used to reduce site risk.

The preliminary design of specific plant modifications that are necessary to support the ANO-2 transition to NFPA 805 is included in Attachment 1 of this Enclosure. This information was previously presented to the NRC as described in the cover letter to this Enclosure. Physical modifications are generally in the scoping phase at this time; however, the modification design phase includes verification by key ANO NFPA 805 project team personnel to ensure the final design meets the risk-based requirements credited in the ANO-2 NFPA 805 transition process.

b. Identification of all required NFPA 805 operator recovery actions.

Operator recovery actions are provided in Attachment 2 of this Enclosure. This information was previously presented to the NRC as described in the cover letter to this Enclosure. Although some unscreened scenarios have not yet been resolved, the ANO-2 NFPA 805 transition process is not expected to identify any additional operator recovery actions will be required.

c. Identification of all the NFPA 805 recovery action risk.

Recovery action risk is included in Attachment 3 of this Enclosure. This information was previously presented to the NRC as described in the cover letter to this Enclosure. The risk associated with these recovery actions is conservatively calculated within the context of the Fire Area in which they are credited.

d. Completion of the subsequent fire risk evaluations, sensitivity analyses, and formulation of the LAR.

The fire risk evaluations and any necessary sensitivity analyses have been completed. The open items recently identified by the NRC with regard to the ANO-2 NFPA 805 submittal are not expected to require changes to the fire risk evaluations or sensitivity analyses. However, the scope of the open items is not yet clearly understood.

to 2CAN081202 Page 2 of 2 In light of the above, Entergy expects to submit the ANO-2 LAR by July 15, 2013. To account for unforeseen circumstances that may arise over this time period that could have a significant, currently undefined impact on the timing of the ANO-2 LAR.

Therefore, Entergy requests an extension of enforcement discretion until July 15, 2013. Nevertheless, Entergy intends to submit the ANO-2 LAR as soon as possible, based on continuing interface with NRC personnel to support this effort.

2. Transition status should also identify and describe the additional progress that will be made in the following areas between the original ANO-2 LAR submittal date and the proposed new submittal date:

a. Classical fire protection transition.

b. Nuclear safety performance criteria transition.

c. Defining and installing transition modifications.

A summary of the ANO-2 NFPA 805 transition schedule over the requested enforcement discretion extension period is provided in Attachment 4 of this Enclosure.

Note that the uncertainties described above and accommodation of the ANO-1 NFPA 805 submittal can affect the schedule. Issues that have been raised on ANO-2 will need to be addressed for ANO-1 and will be resolved separately. The schedule is continuously updated to reflect necessary changes in start and finish dates and to reflect current plans.

The aforementioned May 25, 2012, NRC letter also requested Entergy ensure the following transition-related information remains available, on-site, for NRC staff review:

a. Listing of all fire protection-related non-compliances and the related compensatory measures for those non-compliances.

b. Documentation ensuring each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements," dated April 19, 2005 (ADAMS Accession No. ML042360547).

c. A description of the physical modifications performed, if any, to address existing fire protection issues and non-compliances.

The above information is available, on-site, for NRC staff review.

Attachments

1. ANO-2 NFPA 805 Modifications

2. ANO-2 NFPA Operator Recovery Actions

3. ANO-2 Recovery Action Risk

4. ANO-2 Transition Status

Attachment 1 ANO-2 NFPA 805 Modifications

, Attachment 1 2CAN081202 Page 1 of 23 S. Plant Modifications and Items to be Completed During Implementation Table S-1, Plant Modifications, provided below includes a description of the modifications along with the following information:

A problem statement, Risk ranking of the modification, An indication if the modification is currently included in the FPRA, Compensatory measure in place, and A risk-informed characterization of the modification and compensatory measure.

The following ranking legend should be used when reviewing the table:

High = Modification which would have an impact on FPRA and affect multiple Fire Areas.

Med = Modification which would have an impact on FPRA and affect individual Fire Areas, or include IN 92-18 modifications.

Low = Modification which would have no or insignificant impact on risk.

Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-1 Med 2 In Fire Area HH, a separation issue was ANO plans to relocate Yes Yes This modification is specifically (PRA) identified on the EFW valves interposing relays and affected credited from a PRA perspective.

2CV-1026-2 and 2CV-1076-2. During a cables associated with fire induced circuit failure the feedwater 2CV-1026-2 and 2CV-1076-2 Modification reduces the risk in valves may be impacted by a fire in Fire from Fire Area HH, Fire Zone Fire Area HH of a fire induced Zone 2096-M. 2096-M, to the adjacent room circuit failure for EFW valves in Fire Area G, Fire Zone 2CV-1026-2 and 2CV-1076-2 in LAR Source: 2098-C. Circuits for Fire Zone 2096-M.

Attachment C (NEI-04-02 Table B-3) 2CV-1026-2 and 2CV-1076-2 In accordance with station Section for EFW Valves 2CV-1026-2 are currently routed through directives, compensatory and 2CV-1076-2 in Fire Area HH Risk Fire Area G and no new measures per OP-1003.014 have Summary impacts will be generated by been established as appropriate.

this modification.

, Attachment 1 2CAN081202 Page 2 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-2 High 2 In Fire Area JJ, a separation issue was ANO plans to modify the Yes Yes This modification is specifically (PRA) identified that impacts the DC power circuits as described to credited from a PRA perspective cables control wiring on both trains. If a eliminate impacts in Fire and affects multiple fire areas.

fire event occurred, this could result in Area JJ associated with these the loss of equipment that would components. The modification limits the risk of a otherwise be available. Additional potential spurious operation and a considerations are potential spurious 2A-3, 2A-308, 2A-309, and loss of DC power to safety bus for operations at switchgear 2A-3 that may 2A-310 - The red train 125V switchgear 2A-3 due to a fire result in a loss of power to the safety DC panel 2D-23 that supplies induced circuit failure.

bus. control power for 2A-3 and 2B-5 is planned for relocation In accordance with station LAR Source: to Fire Area MM from Fire Area directives, compensatory Attachment C JJ. Control power cables are measures per OP-1003.014 have Switchgear/ (NEI-04-02 Table B-3) planned to be rerouted using been established as appropriate.

EFW Valves VFDR(s) embedded conduits from Fire Area MM to Fire Area II to 2A-3 JJ-04 avoid Fire Areas JJ and SS.

2A-308 JJ-04 This allows post-fire control of 2A-3 bus from the control 2A-309 JJ-04 room.

2CV-1036-2 JJ-01 2CV-1036 Auxiliary relays 2CV-1075-1 JJ-01 2CR1036A, B, C, and D are currently installed in MCC Attachment C (NEI-04-02 Table B-3) 2B-61 and are planned to be Fire Area JJ Risk Summary components: relocated to MCC 2B-63. This 2A-3, 2A-308, 2A-309, 2A-310, 2B-6, would eliminate cables that 2CV-1036-2, 2CV-1075-1, 2CV-4816, are routed through Fire and 2CV-4817. Area JJ associated with this valve. This eliminates a loss of 2CV-1036-2 due to a fire in Fire Area JJ.

(continued)

, Attachment 1 2CAN081202 Page 3 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-2 2CV-1075 The reroute of DC control power to bus 2A-3 and load-center 2B-5 listed above assures MCC 2B-53 remains available to power this valve. Control cables from 2C-17 to MCC 2B-53 are planned to be rerouted using an embedded conduit between Fire Area G and II to avoid Fire Areas JJ, SS, and TT.

New dedicated fuses are planned to be installed in 2C-17 for 2CV-1075-1 control relays so that failure of cables in scheme 2S113 will not impact 2CV-1075-1.

2B Cables are planned to be rerouted to control room panel 2C33-2 from 2B-6 using an embedded conduit between Fire Zone 2100-Z to the cable spreading room Fire Area G.

This eliminates an impact in Fire Area JJ.

2CV-4816 & 2CV-4817 - A reroute of cable 2I016N is planned by using embedded conduit C4080 that is located between Fire Area G (cable spreading room) to Fire Area EE-L. Cable 2I016N is also planned to be separately fused in panel C-09 to prevent failure due to a loss of cable 2I016P.

This eliminates circuit impacts in Fire Areas TT, JJ, and EE-U.

, Attachment 1 2CAN081202 Page 4 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-3 High 2 In Fire Area MM, fire induced circuit ANO plans to install backup DC Yes Yes This modification is specifically (PRA) failure could impact DC power cables control power to switchgear credited from a PRA perspective feeding circuit breakers at switchgear 2A-1, 2A-2, 2H-1 and 2H-2 with and affects multiple fire areas.

2A-1, 2A-2, 2H-1, and 2H-2. The automatic transfer capability in failure of 2A-1 and 2A-2 could prevent Modification to install an alternate the event the normal DC alignment to an offsite power source. DC power source reduces the risk control power source is lost.

The failure of 2H-1 and 2H-2 could of a fire induced circuit failure to The new backup DC power the DC power cables feeding RCP prevent tripping the reactor coolant source will be located circuit breakers 2H-1 and 2H-2 pumps (RCPs) from the control room.

completely within Fire Area B-2 which could prevent tripping the LAR Source: in proximity to the switchgear RCPs from the control room.

Attachment C either on elevation 372 or (NEI-04-02 Table B-3) below at elevation 354. This In accordance with station Switchgear VFDR(s) eliminates impacts to directives, compensatory switchgear DC control power measures per OP-1003.014 have 2A-1 JJ-04 due to a fire in any other ANO-2 been established as appropriate.

2H-1 JJ-03, MM -04, SS-03 fire area and allows tripping of the RCPs in those areas.

2H-2 JJ-03, MM -04, SS-03 Inclusive in this modification will Attachment C (NEI-04-02 Table B-3) be changes to the control globally credits DC power modification power circuits for switchgear to 2A-1, 2A-2, 2H-1, and 2H-2 in the 2H-1 and 2H-2 to allow tripping performance based Risk Summary for the RCPs in a scenario where a all fire areas. fire originates internally to a switchgear cubicle. This design will prevent fire damage to a load cubicle from disabling the ability to trip the line breakers and remove power to the RCPs.

The opposite scenario where fire damages the line breakers would not prevent the RCP load breakers from being tripped.

This modification will require the line and load breakers to be separately fused and fed as described:

(continued)

, Attachment 1 2CAN081202 Page 5 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-3 2H Internal DC control wiring jumpers will be removed to isolate the line and load cubicles. The DC control power for line breakers 2H-13, 2H-14, and 2H-15 will be isolated from the DC control power for the load breakers 2H-10, 2H-11, and 2H-12.

2H Internal DC control wiring jumpers will be removed to isolate the line and load cubicles. The DC control power for line breakers 2H-23, 2H-24, and 2H-25 will be isolated from the DC control power for the load breakers 2H-20, 2H-21, and 2H-22.

, Attachment 1 2CAN081202 Page 6 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 High 2 In Fire Area TT, a separation issue was ANO plans to modify the Yes Yes This modification is specifically (PRA) identified that impacts the power cables circuits as described to credited from a PRA perspective for EFW, chemical and volume control eliminate impacts in Fire and affects multiple fire areas.

system (CVCS), and service water Area TT associated with (SW) components 2B-5, 2CV-0789-1, The modification reduces the risk these components.

2CV-1036-2, 2CV-1075-1, 2CV-4816, of a fire induced circuit failure for 2CV-4817, and 2P-7B in the fire PRA 2CV-1036 Auxiliary relays EFW/CVCS/SW components and model. 2CR1036A, B, C, and D are power cables (2B-5, 2CV-0789-1, currently installed in MCC 2CV-1036-2, 2CV-1075-1, LAR Source: 2B-61 and are planned to be 2CV-4816, 2CV-4817, and 2P-7B)

EFW/ Attachment C relocated to MCC 2B-63. This in Fire Area TT.

CVCS/SW (NEI-04-02 Table B-3) would also eliminate cables Components VFDR(s) that are routed through Fire In accordance with station Area TT associated with this directives, compensatory 2CV-1036-2 TT-01 measures per OP-1003.014 have valve. This eliminates a loss 2CV-1075-1 TT-01 of 2CV-1036-2 due to a fire in been established as appropriate.

2P-7B TT-01 Fire Area TT.

2CV-0789-1 TT-01 2CV-1075 Cables for this valve between panels 2C-39 2CV-4816 TT-02 to 2C-17 that are currently 2CV-4817 TT-02 routed through Fire Area TT 2B-5 TT-03 are planned to be rerouted to remain exclusively in the cable Note: This modification is also spreading room. Control discussed in Item S1-2 for Fire cables from 2C-17 to MCC Area JJ. Modification resolves 2B-53 are planned to be impacts in both fire areas. rerouted using an embedded conduit between Fire Area G and II to avoid Fire Areas JJ, SS, and TT. New dedicated fuses are planned for installation in 2C-17 for 2CV-1075-1 control relays so that failure of cables in scheme 2S113 will not impact 2CV-1075-1.

(continued)

, Attachment 1 2CAN081202 Page 7 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 2P-7B - Cables for this pump 2B Cables for this load center between panels 2C-39 to between panels 2C-39 to 2C-33-1 2C-17 that are currently routed that are currently routed through through Fire Area TT are Fire Area TT are planned to be planned to be rerouted to rerouted to remain exclusively in remain exclusively in the cable the cable spreading room.

spreading room. New conduits are also planned to be installed.

2CV-0789 Cables for this valve between panels 2C-39 to 2C-17 that are currently routed through Fire Area TT are planned to be rerouted to remain exclusively in the cable spreading room. Control cables from 2C-17 to MCC 2B-53 are planned to be rerouted using an embedded conduit between Fire Area G and II to avoid Fire Areas JJ and SS.

2CV-4816 & 2CV-4817 - A reroute of cable 2I016N is planned by using embedded conduit C4080 that goes between Fire Area G (cable spreading room) to Fire Area EE-L. Cable 2I016N is also planned to be separately fused in panel C-09 to prevent failure due to a loss of cable 2I016P of cable. This eliminates circuit impacts in Fire Areas TT, JJ, and EE-U.

(continued)

, Attachment 1 2CAN081202 Page 8 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 2B Cables for this load center between panels 2C-39 to 2C-33-1 that are currently routed through Fire Area TT are planned to be rerouted to remain exclusively in the cable spreading room.

, Attachment 1 2CAN081202 Page 9 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-5 High 2 In Fire Area SS, a fire induced circuit ANO plans to modify the Yes Yes This modification is specifically (PRA) failure could impact the DC power on circuits as described to credited from a PRA perspective both trains resulting in the loss of the eliminate impacts in Fire and affects multiple fire areas.

following components. Area SS associated with these components. The modification reduces the risk LAR Source: of a fire induced circuit failure that Attachment C 2A-3 and 2A-310 - The red could result in the loss of DC (NEI-04-02 Table B-3) train 125V DC panel 2D-23 power for both trains.

Switchgear VFDR(s) that supplies control power for 2A-3 and 2B-5 is planned to In accordance with station 2A-3 SS-01 be relocated from Fire Area JJ directives, compensatory to Fire Area MM. Control measures per OP-1003.014 have Attachment C (NEI-04-02 Table B-3) been established as appropriate.

Fire Area SS Risk Summary power cables are planned to components 2A-4, 2A-409, 2B-6, be rerouted using embedded 2A-308, 2A-309, 2A-310, 2CV-0789-1, conduits from Fire Area MM to 2CV-1040-1, 2D-27, 2K-4A, 2P-16A, Fire Area II to avoid Fire Areas 2P-36A, 2PIS-0789-1, 2SV-0724-1, JJ and SS. This allows post-2SV-2809-1, 2SV-2810-1, and fire control of 2A-3 bus from 2SV-2811. the control room.

2A-4, 2A-409, & 2B Cables are planned to be rerouted to control room panel 2C33-2 from 2A-4 and 2B-6 using an embedded conduit between Fire Zone 2100-Z to the cable spreading room Fire Area G. This eliminates an impact in Fire Zone 2097-X and Fire Area JJ.

(continued)

, Attachment 1 2CAN081202 Page 10 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-5 The 125V DC control power from 2D-24 to 2A-4 is planned to be rerouted using a new conduit to avoid an impact against cables G2D2404A and B in Fire Zone 2097-X.

2CV-0789-1 & 2PIS-0789 The power cable for 2PIS-0789-1 (for 2CV-0789-1) is planned to be re-routed using an embedded conduit from Fire Area G to Fire Area II to avoid Fire Area SS.

2CV-1040 This valve is not directly impacted but is failed due to a loss of AC. The red train 125V DC panel 2D-23 that supplies control power for 2A-3 and 2B-5 is planned to be relocated from Fire Area JJ to Fire Area MM. Control power cables are planned to be routed using embedded conduits from Fire Area MM to Fire Area II to avoid Fire Areas JJ and SS. This assures 2CV-1040-1 will have a source of power and eliminates an impact in Fire Area SS.

(continued)

, Attachment 1 2CAN081202 Page 11 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-5 2A-308, 2A-309, 2D-27, 2K-4A, 2P-16A, 2P-36A, 2SV-0724-1, 2SV-2809-1, 2SV-2810-1, and 2SV-2811 - The cables associated with these components are planned to be re-routed to avoid Fire Area SS by using embedded conduits and as required the installation of a new raceway in Fire Area B-2 directly under Fire Area SS on elevation 372. The new raceway in Fire Area B-2 is planned to be installed above the vertical zone of influence for any postulated fire source. This eliminates impacts for 2A-308, 2A-309, 2D-27, 2K-4A, 2P-16A, 2P-36A, 2SV-0724-1, 2SV-2809-1, 2SV-2810-1, and 2SV-2811 in Fire Area SS.

, Attachment 1 2CAN081202 Page 12 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-6 Med 2 Motor Operated Valves (MOVs) listed ANO plans to modify the No Yes The NPO modification reduces the (92-18) below will be modified to meet control circuit for 2CV-5038-1 risk of fire induced MOV circuit requirements per IN 92-18. The NPO to prevent spurious closure. failures (hot shorts, open circuits assessment determined that any one of This is planned to be similar to and short to ground). This MOV the RCS drop line valves can fail in a the inhibit circuit modification modification can prevent a non-closed and unrecoverable position on CV-1275 for ANO-1. recoverable position failure resulting in a loss of SDC. Procedural controls to secure resulting in the loss of shutdown power by opening breakers cooling.

LAR Source: are planned to be Attachment D implemented for 2CV-5084-1 In accordance with station MOVs (NEI-04-02 Table F-1) and 2CV-5086-2. directives, compensatory (IN 92-18) VFDR(s) measures per OP-1003.014 have been established as appropriate.

2CV-5038-1 NPO-RCS-SDC 2CV-5084-1 NPO-RCS-SDC 2CV-5086-2 NPO-RCS-SDC

, Attachment 1 2CAN081202 Page 13 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-7 Med 2 MOVs listed below will be modified to ANO plans to modify the control Yes Yes This modification is specifically (PRA) meet requirements per IN 92-18. The circuit for MOVs 2CV-1075-1, credited from a PRA perspective.

four EFW discharge valves and two 2CV-1076-2, 2CV-1036-2, EFW pump steam supply valves can 2CV-1039-1, 2CV-0340-2, and The modification reduces the risk fail in a closed and unrecoverable 2CV-0205-2 to prevent fire of fire induced MOV circuit failures position. induced spurious closing from (hot shorts, open circuits and short the main control room, Fire to ground). This MOV modification LAR Source: Area G. This will be can prevent a non-recoverable accomplished by separating the position failure.

Attachment C (NEI-04-02 Table B-3)

Section for EFW MOVs 2CV-1075-1, cable conductors, inclusive of In accordance with station 2CV-1076-2, 2CV-1036-2, 2CV-1039-1, internal panel wiring, that can directives, compensatory 2CV-0340-2, and 2CV-0205-2 in Fire cause spurious valve closing measures per OP-1003.014 have Area G Risk Summary and protecting them with been established as appropriate.

grounded metallic raceway and the use of grounded metallic barriers. This will prevent contact with potentially energized conductors from both intracable and intercable hot shorts.

MOV 2CV-1075-1 control cables R2B53J2C and R2B53J2N that enter panel 2C-17 or 2C-39 from floor penetrations have been identified as the cables of concern applicable to this modification.

MOV 2CV-1076-2 control cables G2D26C1D, G2D26C1E, and G2D26C1L that enter panel 2C-16 or 2C-40 from floor penetrations have been identified as the cables of concern applicable to this modification.

(continued)

, Attachment 1 2CAN081202 Page 14 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-7 MOV 2CV-1036-2 control cable G2B63H1E that enters panel 2C-40 from a floor penetration has been identified as the cable of concern applicable to this modification.

MOV 2CV-1039-1 control cable R2D27B2E that enters panel 2C-39 from a floor penetration has been identified as the cable of concern applicable to this modification.

MOV 2CV-0340-2 control cable G2D26B1E that enters panel 2C-16 from a floor penetration has been identified as the cable of concern applicable to this modification.

MOV 2CV-0205-2 control cables G2D26C2C, G2D26C2E, and G2D26C2F that enter panel 2C-16 or 2C-18 from floor penetrations have been identified as the cables of concern applicable to this modification.

, Attachment 1 2CAN081202 Page 15 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-8 Med 2 In Fire Area B-3, spurious opening of ANO plans to modify the control Yes Yes This modification is specifically (PRA) MOV 2CV-4698-1 pressurizer low circuit for 2CV-4698-1 to credited from a PRA perspective.

temperature - overpressure (LTOP) prevent fire induced spurious relief can result from a fire in motor opening in Fire Area B-3. This The modification in Fire Area B-3 control center (MCC) 2D-27. will be accomplished by to install flexible metallic conduit separating the cable protects the valve control cable in LAR Source: conductors, inclusive of internal MCC 2D-27 which reduces the risk panel wiring, that can cause of fire induced circuit failures (such Attachment C (NEI-04-02 Table B-3) as spurious opening). This Section for Fire Area B-3 Risk spurious opening and protecting the conductors with a grounded modification can prevent a non-Summary recoverable position failure.

metallic raceway and the use of grounded metallic barriers. This In accordance with station will prevent contact with directives, compensatory potentially energized measures per OP-1003.014 have conductors from both intracable been established as appropriate.

and intercable hot shorts.

Control cable R2D27A3J that enters MCC 2D-27 from a floor penetration has been identified as the cable of concern applicable to this modification.

, Attachment 1 2CAN081202 Page 16 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-9 Med 2 In Fire Area G, spurious opening of ANO plans to modify the control Yes Yes This modification is specifically (PRA) valves 2CV-1002 (in cabinet 2C02), circuit for MOVs 2CV-1002, credited from a PRA perspective.

2CV-1052 (in cabinet 2C02), 2CV-1052, 2CV-0714-1, and 2CV-0714-1 (in cabinet 2C17), and 2CV-4698-1 to prevent fire The modification in Fire Area G to 2CV-4698-1 (in cabinet 2C09) can induced spurious opening in the install flexible metallic conduit result from a fire in the control room. main control room, Fire Area G. protects the valves control cable This will be accomplished by which reduces the risk of fire LAR Source: separating the cable induced circuit failures (such as conductors, inclusive of internal spurious opening). This Attachment C (NEI-04-02 Table B-3) modification can prevent a non-Section for MOVs 2CV-1002, panel wiring, that can cause spurious valve opening and recoverable position failure.

2CV-1052, 2CV-0714-1, and 2CV-4698-1 in Fire Area G Risk protecting the conductors with a In accordance with station Summary grounded metallic raceway and directives, compensatory the use of grounded metallic measures per OP-1003.014 have barriers. been established as appropriate.

(continued)

, Attachment 1 2CAN081202 Page 17 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-9 This will prevent contact with potentially energized conductors from both intracable and intercable hot shorts.

MOV 2CV-1002 control cable G2B63A3D that enters panel 2C-02 from a floor penetration has been identified as the cable of concern applicable to this modification.

MOV 2CV-1052 control cable R2B53D3D that enters panel 2C-02 from a floor penetration has been identified as the cable of concern applicable to this modification.

Valve 2CV-0714-1(2SV-0714-1) control cable R2S066E that enters panel 2C-17 from a floor penetration has been identified as the cable of concern applicable to this modification.

MOV 2CV-4698-1 control cable R2D27A3J that enters panel 2C-09 from a floor penetration has been identified as the cable of concern applicable to this modification.

, Attachment 1 2CAN081202 Page 18 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-10 Med 2 In Fire Area B-4 an incipient fire ANO plans to provide a Yes Yes This modification is specifically (PRA) detection system is not installed in modification in the CEDM credited from a PRA perspective.

control element drive mechanism room in Fire Area B-4 to install (CEDM) room panels 2C-70, 2C-71, incipient detection in cabinets The early warning fire detection 2C-72, 2C-73, and 2C-80. 2C-70, 2C-71, 2C-72, 2C-73, system modification in Fire 2C-80, and 2C-409. Area B-4 reduces the risk of a fire However an early warning fire detection induced circuit and equipment system in accordance with NFPA 72, Fire detection signal cable is failures that could result in the loss Fire Alarm Detection Code, is required planned to be routed from of CEDM room panels 2C-70, by the PRA in accordance with FRE each air sampling detector to 2C-71, 2C-72, 2C-73, 2C-80, and CALC-09-E-0008-05. the control room fire panel 2C-409.

2C-343-3.

LAR Source: In accordance with station directives, compensatory Attachment C (NEI-04-02 Table B-3) measures per OP-1003.014 have Section for CEDM Room Panels 2C-70, been established as appropriate.

2C-71, 2C-72, 2C-73, and 2C-80 in Fire Area B-4 Risk Summary S1-11 High 2 At ANO the availability of feedwater to ANO plans to install a new Yes Yes The AFW modification is (PRA) ANO-2 SGs was identified as an issue AFW pump in ANO-1 capable specifically credited from a PRA by PRA. of feeding one of the ANO-2 perspective to provide a reliable SGs. additional source of feedwater.

Also identified by PRA was ANOs inability to perform high risk and time The AFW would be designed The local control panel modification sensitive actions, such as control of to meet or exceed the flow is specifically credited from a PRA auxiliary feedwater (AFW), outside of requirements of ANO-2 perspective to provide an alternate the ANO-2 Control Room. Emergency Feedwater (EFW) means to perform required actions Pump 2P-7B (380 gpm @ outside the ANO-2 Control Room.

LAR Source: 1100 psig).

This modification reduces the risk Attachment C (NEI-04-02 Table B-3) The new pump, controls and of not being able to perform Fire Area G Risk Summary and motor operated valves would necessary operator actions to VFDR G-01 be designed to be installed in shutdown the plant, if either ANO-1. The preferred source Control Room cant be manned.

of suction for the new pump is planned to be from ANO-1. (continued)

(continued)

, Attachment 1 2CAN081202 Page 19 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-11 The discharge piping is planned Also, the local control panel to be routed through the ANO-1 modification reduces the risk of and ANO-2 Turbine Buildings to availability issue with of feedwater ANO-2 Auxiliary Building supply to the ANO-2 SGs.

Rooms 2081 and 2084 for the tie-ins to the EFW System Manual actions are credited in fire piping. The AFW tie-ins are areas that contain redundant safe planned to discharge into the shutdown equipment. These ANO-2 EFW downstream of all actions have been demonstrated EFW injection valves to ensure feasible and are therefore a single area fire does not considered adequate disable AFW. compensatory measures until The AFW pump would be compliance can be achieved by designed to have the capability transitioning to a 10CFR50.48(c) to be operated from the ANO-2 licensing basis.

Control Room and locally in ANO-1. The design will ensure electrical isolation from Control Room functions to prevent a fire in the ANO-2 Control Room from affecting local control of AFW components.

The AFW pump and associated motor operated valves would be designed to be powered by diverse ANO-1 non-safety related power sources to prevent a single failure from disabling equipment operation.

The AFW pump would be designed to include controls and monitoring instrumentation to ensure proper water flow to the SGs. The local controls and monitoring instrumentation are planned to be located in ANO-1, powered from ANO-1 sources and have backup DC power.

, Attachment 1 2CAN081202 Page 20 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-12 Med 2 In Fire Area B-3, excessive ANO plans to modify the Yes No This modification supports a basic (PRA) temperatures have been identified in control wiring for fans 2VEF-63 assumption from a PRA Fire Zone 2091-BB following a loss of and 2VEF-64 to isolate the perspective.

ventilation. control room and allow the local controls to override a LAR Source: stop signal generated from Attachment C (NEI-04-02 Table B-3) within Fire Area G, either from Fire Area B-3 handswitch positioning or fire-induced circuit damage. This eliminates fire impacts in Fire Area G and assures either 2VEF-63 or 2VEF-64 will remain available except for a fire in Fire Area B-3, Fire Zone 2091-BB.

S1-13 Med 2 In Fire Area MM, excessive ANO plans to provide a Yes No This modification supports a basic (PRA) temperatures have been identified in modification to fire door assumption from a PRA Fire Zone 2099-W following a loss of DR 265 to allow normally open perspective.

ventilation. positioning with automatic closure features in the event of LAR Source: a fire. This allows natural Attachment C (NEI-04-02 Table B-3) circulation to prevent long term Fire Area MM room overheating impact on equipment located in Fire Zone 2099-W, West DC Equipment Room, by allowing an opening to Fire Zone 2109-U, Corridor, in Fire Area JJ.

, Attachment 1 2CAN081202 Page 21 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-14 Low C With regard to NFPA 50A, Gaseous ANO plans to provide a No No The subject hydrogen gas system (Code) Hydrogen Systems, code non- modification to move the bottle storage area is not credited compliance issues were identified in the hydrogen bottles and manifold by the PRA.

Hydrogen Gas Bottle Storage Room from the Hydrogen Gas Bottle related to inadequate vent piping and Storage Room to a concrete This modification will be completed room ventilation. The hydrogen storage slab located outside this room to meet NFPA 805 code room light switch was identified as not and open to atmosphere. This requirements.

meeting Article 501 for Class I, addresses hydrogen Division II locations of the National ventilation concerns and Electric Code (NEC). eliminates the need for electrical upgrades.

LAR Source:

Attachment A (NEI-04-02 Table B-1)

Section 3.3.7.1

, Attachment 1 2CAN081202 Page 22 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-15 Med C NFPA 805 non-compliance issues were ANO plans to provide an Yes Yes This modification will be completed (PRA) encountered when smaller fire areas adequate-for-the-hazard to meet NFPA 805 code were defined such that multiple walls, evaluation and if necessary a requirements.

dampers, penetration seals, and doors modification to upgrade fire were credited and used in the PRA barrier walls, dampers, In accordance with station model as rated fire barriers in the NRC penetration seals, and doors directives, compensatory regulatory basis for NFPA 805. to rated barriers for those measures per OP-1003.014 have barriers credited for been established as appropriate.

Multiple walls and doors barriers will deterministic compliance and require upgrading to comply with subsequently credited in the NFPA 805. Fire PRA analysis.

LAR Source: These barriers have been Attachment A (NEI-04-02 Table B-1) previously identified as NRC Section 3.11.2 regulatory basis to ensure compliance with NFPA 805 and have compensatory measures established. The barriers to be addressed as identified by EC-1956 are 2005-2, 2005-3, 2067-4, 2082-3, 2091-1, 2091-2, 2091-3, 2091-4, 2107-4, 2110-2, 2110-4, 2110-7, 2112-2, 2112-8, 2112-10, 2133-5, 2133-6, 2147-8, 2148-4, 2148-5, 2149-5, 2152-2, 2154-2, 2154-3, 2154-5, 2158-10, 2224-2, 2224-3, 2228-10, 2239-4, 2239-5, 2256-4, 2256-5, 2256-6, 2256-8, 2134-1, and 2155-1.

, Attachment 1 2CAN081202 Page 23 of 23 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-16 Low C NFPA 10 non-compliance issues (such ANO plans to provide a No No The subject fire extinguishers are (Code) as incorrect number of fire modification to resolve the not credited in the FPRA.

extinguishers for travel distance, NFPA 10 code deficiencies incorrect type and size for the hazard identified in CALC-ANOC- This modification will be completed area) were identified with ANO portable FP-09-00009. to meet NFPA 805 code fire extinguishers. requirements.

In general, this modification LAR Source: would involve portable fire extinguisher physical Attachment A (NEI-04-02 Table B-1) relocation, substitution of Section 3.7 existing extinguishers, and documentation updates to reflect these plant changes.

The results will ensure the proper number of fire extinguishers to meet travel distance requirements in coverage areas, adequately sized fire extinguishers, and the correct type of extinguisher that is rated for the fire hazard in each area.

Attachment 2 ANO-2 NFPA Operator Recovery Actions

, Attachment 2 2CAN081202 Page 1 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area De-energize DC Control Power to 2A-309 at 2A-3, 2A-309 B-2 2A-309 2A-3 SUPPLY BREAKER located in Fire Area II, Fire Zone 2101-AA. Then verify open/ N/A RA manually open 2A-309 in Fire Area II, Fire Zone 2101-AA.

2P-32A 2P-32B Call dispatcher to isolate transformers 2X-03 (SU-3) and X-04 B-2 REACTOR COOLANT PUMP B2-03 RA 2P-32C (SU-2).

2P-32D EFW PUMP 2P-7B De-energize 2CV-0789-1 at panel 2B-5, breaker 2B-514, B-3 2CV-0789-1 CONDENSATE SUCTION located in Fire Area II, Fire Zone 2101-AA. Verify open/ B3-01 RA VALVE manually open 2CV-0789-1 in Fire Area FF, Fire Zone 2025-JJ.

Manually trip 2P-32A at breaker 2H-11, local panel 2H-1, in Fire B-4 2P-32A REACTOR COOLANT PUMP B4-01 RA Area B-2, Fire Zone 2200-MM.

Manually trip 2P-32B at breaker 2H-21, local panel 2H-2, in Fire B-4 2P-32B REACTOR COOLANT PUMP B4-01 RA Area B-2, Fire Zone 2200-MM.

Manually trip 2P-32C at breaker 2H-22, local panel 2H-2, in B-4 2P-32C REACTOR COOLANT PUMP B4-01 RA Fire Area B-2, Fire Zone 2200-MM.

Manually trip 2P-32D at breaker 2H-12, local panel 2H-1, in B-4 2P-32D REACTOR COOLANT PUMP B4-01 RA Fire Area B-2, Fire Zone 2200-MM.

Locally open EFW discharge valve following power failure.

EE-L 2CV-1075-1 2P-7B DISCHARGE TO SG-B EE-L-01 RA 2CV-1075-1 located in Fire Area GG, Fire Zone 2081-HH.

2CV-1036-2 Locally open EFW discharge valve following power failure.

EE-L 2P-7B DISCHARGE TO SG-B N/A RA 2CV-1036-2 located in Fire Area GG, Fire Zone 2081-HH.

2CV-1026-2 Locally open EFW discharge valve following power failure.

EE-U EFW VALVE 2CV-1026-2 located in Fire Area EE-L, Fire Zone 2084-DD. N/A RA 2CV-1076-2 2CV-1076-2 located in Fire Area GG, Fire Zone 2081-HH.

Open Manual Valves 2EFW-5A&B to Divert 2P-7A Flow to 2EFW-5A B Discharge Line Following Fire Damage to 2P-7A motor EE-U EFW VALVE operated valves (MOVs). 2EFW-5A located in Fire Area FF, N/A RA 2EFW-5B Fire Zone 2025-JJ. 2EFW-5B located in Fire Area CC, Fire Zone 2024-JJ.

, Attachment 2 2CAN081202 Page 2 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area Manually trip 2CV-1016-1 at breaker 2D-2301 and 2D-2401, SG-A TO BLOWDOWN G 2CV-1016-1 local panel 2D-23 and 2D-24 in Fire Area JJ Fire Zone 2109-U, G-01 RA TANK 2T-67 MOV to isolate blowdown.

Manually trip 2CV-1066-1 at breaker 2D-2301 and 2D-2401, SG-B TO BLOWDOWN G 2CV-1066-1 local panel 2D-23 and 2D-24 in Fire Area JJ Fire Zone 2109-U, G-01 RA TANK 2T-67 MOV to isolate blowdown.

Locally vent air from the actuator for 2CV-4816 to fail the valve G 2CV-4816 LETDOWN THROTTLE CV G-01 RA closed in Fire Area EE, Fire Zone 2084-DD.

Locally vent air from the actuator for 2CV-4817 to fail the valve G 2CV-4817 LETDOWN THROTTLE CV G-01 RA closed in Fire Area EE, Fire Zone 2084-DD.

De-energize DC Control Power to 2P-32A at 2H-11 located in G 2P-32A REACTOR COOLANT PUMP Fire Area B-2, Fire Zone 2200-MM. Then verify tripped/ G-01 RA manually trip 2H-11 in Fire Area B-2, Fire Zone 2200-MM.

De-energize DC Control Power to 2P-32B at 2H-21 located in G 2P-32B REACTOR COOLANT PUMP Fire Area B-2, Fire Zone 2200-MM. Then verify tripped/ G-01 RA manually trip 2H-21 in Fire Area B-2, Fire Zone 2200-MM.

De-energize DC Control Power to 2P-32C at 2H-22 located in G 2P-32C REACTOR COOLANT PUMP Fire Area B-2, Fire Zone 2200-MM. Then verify tripped/ G-01 RA manually trip 2H-22 in Fire Area B-2, Fire Zone 2200-MM.

De-energize DC Control Power to 2P-32D at 2H-12 located in G 2P-32D REACTOR COOLANT PUMP Fire Area B-2, Fire Zone 2200-MM. Then verify tripped/ G-01 RA manually trip 2H-12 in Fire Area B-2, Fire Zone 2200-MM.

HIGH PRESSURE SAFETY G 2P-89B* Locally operate breaker 2A-406 to prevent start of HPSI pump G-01 RA INJECTION (HPSI) PUMP LOW PRESSURE SAFETY G 2P-60B* Locally operate breaker 2A-405 to prevent start of LPSI pump G-01 RA INJECTION (LPSI) PUMP CONTAINMENT SPRAY Locally operate breaker 2A-404 to prevent start of Containment G 2P-35B* G-01 RA PUMP Spray Pump

, Attachment 2 2CAN081202 Page 3 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area 2CV-5630-1 G RWT OUTLET VALVES Close both RWT outlet valves locally G-01 RA 2CV-5631-2*

2CV-4920-1 BORIC ACID MAKEUP G TANK (BAMT) GRAVITY Open both BAMT Gravity Feed valves locally G-01 RA 2CV-4921-1* FEED VALVES VOLUME CONTROL TANK G 2CV-4873-1* Close VCT outlet valve locally G-01 RA (VCT) OUTLET VALVE G 2T-1* PRESSURIZER HEATERS Turn OFF and operate pressurizer heaters as necessary G-01 RA G 2P-36A/B/C* CHARGING PUMPS Stop and operate Charging pumps locally G-01 RA EMERGENCY DIESEL G 2K-4B* Place EDG #2 in LOCKOUT locally G-01 RA GENERATOR #2 (EDG #2) 4160V VITAL POWER De-energize 2A-4 locally to prevent spurious G 2A-4* G-01 RA SWITCHGEAR operation/energize 2A-4 to restore power to vital equipment 480V VITAL POWER LOAD De-energize 2B-6 locally to prevent spurious operation /

G 2B-6* G-01 RA CENTER energize 2B-6 to restore power to vital equipment 125V DC VITAL POWER (2C-108 / EDG #2 ENGINE De-energize DC control power (2D-24 breakers 2, 4, 6, 8, 9, 10)

START SOLENOIDS &

to support EDG #2 (2SV-2829-2, 2SV-2830-2, 2SV-2831, and EXCITATION CABINET, G 2D-24* 2E-21), 2A-4, and 2B-6 local control, and de-energize DC G-01 RA 4160V VITAL POWER control power to fail close RCS high point vent valves SWITCHGEAR, 480V VITAL (2SV-4636-2, 2SV-4668-2, 2SV-4670-2)

POWER, AND RCS HIGH POINT VENT VALVES)

CHARGING HEADER G 2CV-4840-2* Locally verify open Charging header isolation G-01 RA ISOLATION EDG #2 SERVICE WATER G 2CV-1504-2* Locally verify open EDG #2 Service Water outlet G-01 RA OUTLET Verify RWT suction valve open for Charging capability if G 2CV-4950-2* RWT SUCTION VALVE G-01 RA necessary

, Attachment 2 2CAN081202 Page 4 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area G 2P-4C* SERVICE WATER PUMP Align Loop 2 Service Water header locally G-01 RA EFW PUMP 2P-7A G 2CV-0795-2* Verify open 2P-7A Condensate suction MOV locally G-01 RA SUCTION MOV NEW AUXILIARY G TBD Start and align AFW pump G-01 RA FEEDWATER (AFW) PUMP De-energize 2CV-0789-1 at panel 2B-53, breaker 2B-53D2, EFW PUMP 2P-7B GG 2CV-0789-1 located in Fire Area B-3, Fire Zone 2091-BB. Verify open/ N/A RA CONDENSATE SUCTION manually open 2CV-0789-1 in Fire Area FF, Fire Zone 2025-JJ.

De-energize DC Control Power to 2A-113 at 2A-1 located in JJ 2A-113 2A-1 SUPPLY BREAKER Fire Area B-2, Fire Zone 2200-MM. Verify closed/manually JJ-04 RA close 2A-113 in Fire Area B-2, Fire Zone 2200-MM.

De-energize DC Control Power to 2A-309 at 2A-3 located in JJ 2A-309 2A-3 SUPPLY BREAKER Fire Area II, Fire Zone 2101-AA. Verify closed/manually close JJ-04 RA 2A-309 in Fire Area II, Fire Zone 2101-AA.

2CV-1036-2 Locally open EFW discharge valve following power failure.

JJ 2P-7B DISCHARGE TO SG-B 2CV-1075-1 and 2CV-1036-2 located in Fire Area GG, Fire JJ-01 RA 2CV-1075-1 Zone 2081-HH.

De-energize 2CV-5649-1 at panel 2B-52, breaker 2B-52G3, CONTAINMENT SUMP located in Fire Area DD, Fire Zone 2040-JJ. Verify open/

JJ 2CV-5649-1 N/A RA SUCTION ISOLATION manually open 2CV-5649-1 in Fire Area AA, Fire Zone 2007-LL (action performed in conjunction with 2CV-5650-2).

De-energize 2CV-5650-2 at panel 2B-62, breaker 2B-62G3, CONTAINMENT SUMP located in Fire Area HH, Fire Zone 2073-DD. Verify open/

JJ 2CV-5650-2 N/A RA SUCTION ISOLATION manually open 2CV-5650-2 in Fire Area AA, Fire Zone 2007-LL (action performed in conjunction with 2CV-5649-1).

EFW PUMP 2P-7B De-energize and manually open 2CV-0789-1 prior to starting an JJ 2PIS-0789 N/A RA CONDENSATE SUCTION EFW pump.

Manually start 2P-7B at switchgear, breaker 2A-311 located in JJ 2P-7B EFW PUMP JJ-01 RA Fire Area II, Fire Zone 2101-AA.

, Attachment 2 2CAN081202 Page 5 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area Locally close minimum flow recirculation valve for the HPSI JJ 2P-89 HPSI PUMP JJ-02 RA pumps 2CV-5628-2 in Fire Area DD, Fire Zone 2040-JJ.

2A-113 MM 4.16KV SWITCHGEAR Align offsite power to bus 2A-1 and 2A-2. N/A RA 2A-213 2CV-1025-1 Locally open EFW discharge valves following fire induced 2CV-1036-2 control and power failure. 2CV-1025-1 and 2CV-1038-2 located MM EFW VALVE N/A RA 2CV-1075-1 in Fire Area EE-L, Fire Zone 2084-DD. 2CV-1075-1 and 2CV-1036-2 located in Fire Area GG, Fire Zone 2081-HH.

2CV-1038-2 De-energize 2CV-1470-1 at panel 2B-54, breaker 2B-54E4, located in Fire Area II, Fire Zone 2101-AA. Verify open/

SERVICE WATER (SW) TO manually open 2CV-1470-1 in Fire Area OO, Fire Zone INTAKE.

OO 2CV-1470-1 OO-1 RA 2P-4A Note: Valve operator is installed external to the intake structure and not in the impacted area.

De-energize 2CV-1474-2 at panel 2B-62, breaker 2B-62H3, located in Fire Area HH, Fire Zone 2073-DD. Verify open/

OO 2CV-1474-2 SW TO 2P-4C manually open 2CV-1474-2 in Fire Area OO, Fire Zone INTAKE. OO-1 RA Note: Valve operator is installed external to the intake structure and not in the impacted area.

De-energize 2CV-1038-2 at panel 2B-63, breaker 2B-63H3, EFW FROM 2P-7B TO SG-A SS 2CV-1038-2 located in Fire Area HH, Fire Zone 2096-M. Verify open/ SS-01 RA ISOLATION manually open 2CV-1038-2 in Fire Area EE, Fire Zone 2084-DD.

De-energize 2CV-1425-1 at panel 2B-54, breaker 2B-54D5, AUXILIARY COOLING SS 2CV-1425-1 located in Fire Area II, Fire Zone 2101-AA. Verify closed/ SS-05 RA WATER (ACW) ISOLATION manually close 2CV-1425-1 in Fire Area OO, Fire Zone INTAKE.

De-energize 2CV-1470-1 at panel 2B-54, breaker 2B-54E4, SS 2CV-1470-1 SW TO 2P-4A located in Fire Area II, Fire Zone 2101-AA. Verify open/ SS-05 RA manually open 2CV-1470-1 in Fire Area OO, Fire Zone INTAKE.

2P-7A/B SUCTION FROM Align EFW/AFW suction to QCST T-41B on low-low level in SS 2EFW-802 N/A RA 2T-41A/B CST aligned to EFW/AFW (2T-41A or 2T-41B).

, Attachment 2 2CAN081202 Page 6 of 6 Table G Recovery Actions and Activities Fire Component Component Description Actions VFDR RA/PCS Area 2CV-1026-2 Align DC operated valves prior to battery discharge.

2CV-1037-1 2CV-1037-1 and 2CV-1026-2 located in Fire Area EE-L, Fire SS EFW VALVE N/A RA 2CV-1039-1 Zone 2084-DD. 2CV-1039-1 and 2CV-1076-2 located in Fire Area GG, Fire Zone 2081-HH.

2CV-1076-2 De-energize DC Control Power to 2A-309 at 2A-3 located in TT 2A-309 2A-3 SUPPLY BREAKER Fire Area II, Fire Zone 2101-AA. Verify closed/manually close N/A RA 2A-309 in Fire Area II, Fire Zone 2101-AA.

De-energize 2CV-1036-2 at panel 2B-63, breaker 2B-63H1, EFW FROM 2P-7B TO SG-B TT 2CV-1036-2 located in Fire Area HH, Fire Zone 2096-M. Verify open/ TT-01 RA ISOLATION manually open 2CV-1036-2 in Fire Area GG, Fire Zone 2081-HH.

De-energize 2CV-1075-1 at panel 2B-53, breaker 2B-53J2, EFW FROM 2P-7B TO SG-B TT 2CV-1075-1 located in Fire Area B-3, Fire Zone 2091-BB. Verify open/ TT-01 RA FLOW CONTROL VALVE manually open 2CV-1075-1 in Fire Area GG, Fire Zone 2081-HH.

RA - Recovery Action PCS - Primary Control Station * - Defense in Depth Measure

Attachment 3 to ANO-2 Recovery Action Risk

, Attachment 3 2CAN081202 Page 1 of 4 Table W-2 ANO-2 Fire Area Risk Summary Additional Fire NFPA 805 Fire Area Fire Area VFDR Fire Risk Fire Risk Area Description RAs Risk of RAs Area Basis CDF LERF (Yes/No) Eval. CDF Eval. LERF (CDF/LERF) 2MH01E concrete manhole east 4.2.4.2 4.89E-09 4.93E-11 yes no 4.89E-09 4.93E-11 n/a 2MH02E concrete manhole east 4.2.4.2 5.09E-09 5.13E-11 yes no 5.09E-09 5.13E-11 n/a 2MH03E concrete manhole east 4.2.4.2 9.99E-08 2.65E-09 yes no -5.66E-06 -1.89E-07 n/a 2MH01W concrete manhole west 4.2.3.2 8.10E-09 1.67E-10 no n/a n/a n/a n/a 2MH02W concrete manhole west 4.2.3.2 8.10E-09 1.67E-10 no n/a n/a n/a n/a 2MH03W concrete manhole west 4.2.3.2 9.23E-09 1.90E-10 no n/a n/a n/a n/a Fire Zone 2007-LL (B HPSI, AA LPSI, and Containment Spray 4.2.4.2 1.52E-06 1.67E-8 yes no -9.70E-07 -3.22E-08 n/a Pump room and gallery)

Fire Zones SBOD and 2MH12 AAC (alternate AC diesel and 4.2.3.2 5.12E-08 1.06E-9 no n/a n/a n/a n/a nearby manhole)

Admin administration building 4.2.3.2 n/a n/a no n/a n/a n/a n/a miscellaneous turbine building 1.22E-04/

B-2 4.2.4.2 5.41E-06 1.23E-07 yes yes -1.19E-04 -3.98E-06 fire compartments 1.56E-06 Fire Zones 2091-BB, 2112-BB 7.90E-09/

B-3 and 2183-J (electrical 4.2.4.2 4.13E-07 1.32E-08 yes yes -1.96E-06 -6.49E-08 1.90E-10 penetration rooms)

Fire Zone 2154-E (CEDM 4.86E-05/

B-4 4.2.4.2 3.26E-06 3.61E-08 yes yes 2.60E-07 -5.17E-08 equipment room) 5.26E-07

, Attachment 3 2CAN081202 Page 2 of 4 Table W-2 ANO-2 Fire Area Risk Summary Additional Fire NFPA 805 Fire Area Fire Area VFDR Fire Risk Fire Risk Area Description RAs Risk of RAs Area Basis CDF LERF (Yes/No) Eval. CDF Eval. LERF (CDF/LERF)

Fire Zones 2149-B and 2158-F B-5 4.2.3.2 4.06E-09 1.21E-10 no n/a n/a n/a n/a (stairwells 2001 and 2055)

Fire Zones 2006-LL, 2010-LL, 2011-LL, and 2014-LL (general access, C HPSI pump room, B-6 4.2.4.2 1.56E-06 1.70E-08 yes no 3.00E-08 3.00E-10 n/a tendon gallery access, and A HPSI, LPSI and Containment Spray Pump room)

Fire Zone 2024-JJ (turbine-CC driven emergency feedwater 4.2.3.2 1.49E-09 3.85E-11 no n/a n/a n/a n/a pump room)

Fire Zones 2019-JJ, 2032-JJ, 2040-JJ, and 2068-DD (boric DD acid condensate tank room, 4.2.4.2 2.45E-06 2.76E-08 yes no -2.85E-06 -9.64E-08 n/a spent resin storage tank room, corridor, and hot machine shop)

Fire Zones 2055-JJ and 2084-DD 9.56E-07/

EE-L 4.2.4.2 3.81E-07 7.53E-09 yes yes -7.89E-07 -2.64E-08 (piping penetration rooms) 3.12E-08 Fire Zone 2111-T (lower south 1.54E-05/

EE-U 4.2.4.2 2.03E-06 4.81E-08 yes yes -5.77E-06 -1.94E-07 electrical penetration room) 4.59E-07 Fire Zone 2025-JJ (motor-FF driven emergency feedwater 4.2.3.2 1.15E-08 3.66E-10 no n/a n/a n/a n/a pump room)

Fire Zones 2199-G, 2119-H, 2136-I, 2137-I, 2150-C, 2098-C, 7.42E-05/

G 4.2.4.2 2.64E-06 3.52-08 yes yes -2.65E-06 -9.78E-08 and 2098-L (control room and 1.64E-06 other alternate shutdown areas)

, Attachment 3 2CAN081202 Page 3 of 4 Table W-2 ANO-2 Fire Area Risk Summary Additional Fire NFPA 805 Fire Area Fire Area VFDR Fire Risk Fire Risk Area Description RAs Risk of RAs Area Basis CDF LERF (Yes/No) Eval. CDF Eval. LERF (CDF/LERF)

Fire Zones 2076-HH and 2081-HH (electrical equipment 2.93E-05/

GG 4.2.4.2 1.03E-06 2.17E-08 yes yes -1.12E-05 -3.82E-07 room and upper north and lower 9.51E-07 north piping penetration room)

Fire Zones 2063-DD, 2072-R, 2073-DD, 2096-M, 2106-R, and 2107-N (sample room, HH 4.2.4.2 3.11E-06 4.65E-08 yes no -5.80E-07 -2.18E-08 n/a VCT room, 2B-62 room, 2B-63 room, degasifier vacuum pump room, and corridor)

Fire Zone 2101-AA (north II 4.2.4.2 2.90E-06 9.31E-08 yes no -1.33E-04 -4.52E-06 n/a switchgear 2A-3 room) 2.82E-04/

JJ Fire Zone 2109-U (corridor) 4.2.4.2 2.70E-06 7.97E-08 yes yes -3.78E-06 -1.21E-07 3.27E-06 Fire Zones 16-Y and 2020-JJ K (clean waste receiver tank room 4.2.3.2 6.47E-10 1.44E-11 no n/a n/a n/a n/a and boron holdup tank vault)

Fire Zones 2093-P, 2114-I and 2115-I (south EDG room, EDG KK 4.2.4.2 1.72E-07 5.22E-09 yes no n/a air intake room, and boric acid makeup tank room)

Fire Zone TKVLT (diesel fuel L 4.2.3.2 1.86E-08 4.32E-10 no n/a n/a n/a n/a storage vault)

Fire Zones 2099-W and 2103-V 6.36E-05/

MM (west DC equipment room and 4.2.4.2 3.28E-06 7.85E-08 yes yes -2.06E-05 -7.94E-07 1.81E-06 west battery room)

, Attachment 3 2CAN081202 Page 4 of 4 Table W-2 ANO-2 Fire Area Risk Summary Additional Fire NFPA 805 Fire Area Fire Area VFDR Fire Risk Fire Risk Area Description RAs Risk of RAs Area Basis CDF LERF (Yes/No) Eval. CDF Eval. LERF (CDF/LERF)

Fire Zones 2032-K and 2033-K (containment building south NN 4.2.4.2 3.04E-06 7.76E-08 yes no n/a side and containment building north side) 1.72E-06/

OO Intake Structure 4.2.4.2 1.62E-07 1.84E-09 yes yes 1.62E-07 1.84E-09 1.60E-08 Fire Zones 2094-Q and 2114-I QQ (north EDG room and EDG air 4.2.3.2 3.98E-07 1.26E-08 no n/a n/a n/a n/a intake room)

Fire Zones 2097-X, 2100-Z and 2102-Y (east DC equipment 2.48E-05/

SS 4.2.4.2 2.81E-06 7.43E-08 yes yes -3.75E-05 -1.28E-06 room, south switchgear room 6.95E-07 and east battery room)

Fire Zone 2108-S (electrical 1.16E-05/

TT 4.2.4.2 2.86E-06 4.47E-08 yes yes -2.37E-05 -7.95E-07 equipment room) 3.83E-07 YD YARD 4.2.3.2 6.73E-07 1.28E-08 no n/a n/a n/a n/a 6.74E-04/

TOTAL 4.30E-05 8.34E-07 -3.70E-04 -1.26E-05 1.13E-05 Indicative of an immeasurable change in risk from the impact of the VFDR on Fire PRA model.

Attachment 4 ANO-2 Transition Status

, Attachment 4 2CAN081202 Page 1 of 2 ANO-2 NFPA 805 Transition Project Post-LAR Submittal Schedule Overview NFPA 805 Project Activity Name Start Finish th Clarification of and Resolve Three (3) NRC Identified LAR Deficiencies from August 9 Conference Call On-going 11/2/2012 Finalize NFPA 805 LAR Update incorporating LAR deficiency corrections 11/5/2012 12/07/2012 Outside Expertise Review of ANO-2 Revised NFPA 805 LAR for Confirmation Prior to NRC Submittal 12/10/2012 02/15/2013 Procedure Development Corporate Procedures (Design Engineering, Work Management, Outage Management, Training, On-going 05/16/2013 Maintenance, Licensing, Operations, and Fire Protection) [~40 identified]

Site Fire Protection Procedures (Engineering, Operations, Maintenance, and Fire Protection) 08/29/2013 03/24/2014

[~80 identified]

Training Program Corporate Procedures Training On-going 10/07/2013 Site Procedures Training 10/25/2012 05/09/2014 Software Development (ARC-PLUS) 01/07/2013 04/02/2013 Attachment S Implementation Items S2-1 Monitoring Program 01/07/2013 07/12/2013 S2-2 Flushing Procedure in Accordance with NFPA 15 01/14/2013 04/12/2013 S2-3 Evaluation for NFPA 14 on Standpipe Hose Station Hanger(s) 01/21/2013 04/19/2013 S2-4 Revise Procedure EN-DC-161 Control of Combustibles Completed 01/27/2012 S2-5 Revise Procedure(s) for NPO Transition 01/28/2013 07/26/2013 S2-6 Revise OMA Procedures/Documents to include feasibility criteria for FAQ 07-0030 02/11/2013 08/16/2013 S2-7 Develop/Revise Technical Documents/Procedures for NFPA 805 Licensing Basis 03/18/2013 11/22/2013 S2-8 Revise NFPA 13 Documentation on Partial Suppression to Replace NRC Approved Exemption 01/14/2013 04/12/2013

, Attachment 4 2CAN081202 Page 2 of 2 NFPA 805 Project Activity Name Start Finish Attachment S Modification Scoping S1-1 on EFW Valves in FA HH 03/06/2013 06/21/2013 S1-2 on DC Power Cables in FA JJ 06/10/2013 09/27/2013 S1-3 on Alternate AC Power Source for 2H-1 & 2H-2 in FA MM 07/25/2013 10/25/2013 S1-4 on Cable Reroute in FA TT 04/23/2013 07/26/2013 S1-5 on DC Power for Swgr in FA SS 09/11/2013 12/20/2013 S1-6 on MOVs modification for IEN 92-18 issues (NPO) 09/06/2012 02/22/2013 S1-7 on MOVs modification for IEN 92-18 (PRA Evaluation) 10/17/2012 03/15/2013 S1-8 on Installing Flex Metal Conduit in FA B-3 11/28/2012 04/19/2013 S1-9 on Mod Cable for MOVs in Various MCCs in FA G 01/24/2013 05/24/2013 S1-10 on Incipient Fire Detection in FA B-4 On-going 03/01/2013 S1-11 on Additional AFW Source to SGs On-going 09/27/2013 S1-12 on Mod Control Wiring for Fans in FA HH On-going 02/22/2013 S1-13 on Mod to Hold Open Fire Door DR265 09/03/2012 01/25/2013 S1-14 on NFPA 50A Non-Compliance Corrections On-going 11/23/2012 S1-15 on Fire Barrier Upgrades 09/25/2012 09/20/2013 S1-16 on NFPA 10 Non-Compliance Corrections On-going 01/25/2013

Enclosure 2 to 2CAN081202 List of Regulatory Commitments to 2CAN081202 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy Operations, Inc. (Entergy) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check one)

COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy will submit the License Amendment Request implementing July 15, 2013 10 CFR 50.48(c) for Arkansas Nuclear One, Unit 2