ML033580394
| ML033580394 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/21/2003 |
| From: | NRC Region 4 |
| To: | |
| References | |
| FOIA/PA-2003-0358, IR-01-006 | |
| Download: ML033580394 (3) | |
Text
ANO Fire Protection Finding Summary Inspection:
Triennial Fire Protection; June 2001 Report:
50-313;368/2001-06; August 2 Finding:
In Fire Zone 98J nd 99M of ANO, Unit 1, the licensee failed to ensure that one train of cables uipment, and components was free of fire damage by one of the three means specified in 10 CFR Part 50, Appendix R, Section III.G.2. In lieu of providing this protection, the licensee credited numerous manual actions for restoring fire-affected safe shutdown functions.
Backfit:
ANO claimed the violation was a generic backfit. RIV held 2 backfit panels upholding the violation. NRR addressed the generic aspect of this finding, agreeing with RIV.-
At issue:
The requirements of 10 CFR Part 50, Appendix R, Section III.G.
Ill.G.1: fire protection features shall be provided for SSCs important to safe shutdown (SSD), and must be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown from either the control room or emergency control station(s) is free of fire damage.
lIl.G.2: where redundant SSD systems are located in the same fire area, one train of SSD systems (including associated circuits) must be free of fire damage by one of three methods:
(a) separation by a 3-hr fire barrier; (b) separation by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, automatic fire detection and suppression system shall be installed; or (c) enclosure of one train in a 1-hr fire barrier. In addition, automatic fire detection and suppression system shall be installed.
IllI.G.3: where protection of SSD functions cannot meet III.G.2, alternative or dedicated shutdown capability must be provided.
ANO:
ANO claimed that they are only required to meet Section III.G.1
-Vwhich permits action at emergency control stations.
Generic:
NRC has always permitted the use of manual actions as a method for meeting III.G.2.
Other licensees use manual actions for meeting III.G.2 without prior NRC approval'
-s fl.\\2
Summary (cont)
Risk:
Phase 2-Phase 3 gfib[e m
I
-5 b=FN~~~~~
.~~~~~~~~~~~~~fLt i
If IIIIIIIIIIIIIIk!IIIIinE 5
ILJJL&.A1&A
ear
I
_l rr
__v_
- 1.
U'F7<
4-,
Differences:
EQ-if~mr Mr 1-~
Iiiq..1
,Wlli!;
R Anft S
-_Iu-
- i.
Ai IWI
-Mmi r
ANO FP ISSUE TIME LINE June 11 - 22, 2001 August 3, 2001 August 20, 2001 August 31, 2001 September 7, 2001 September 10, 2001 September 28, 2001 October 26, 2001 January 11, 2002 January 17, 2002 April 15, 2002 May 16, 2002 Inspection Exit - issue was characterized as a URI for compliance review and risk significance Report - issue was a URI for compliance review and risk significance Re-Exit - compliance review determined that the use of manual actions for achieving and maintaining hot shutdown conditions was a non-compliance with III.G.2 Phase 2__um Backfit - ANO claimed the violation was a backfit generic to all plants BackfIt Panel NEI letter to NRR - generic aspect of using manual actions for complying with Appendix R, III.G.2 Backfit Panel - panel denied the backfit, and upheld the violation Backfit Res nse to 0~. bckfit was deni ed NRR letter to NEI - addressing the generic position concerning the use of manual actions for complying with Appendix R, III.G.2.
Age~~~il
__.~~~~"KW August 20, 2002 September 25, 2002 December10, 2002 January 24, 2003 March 21, 2003 March 25, 2003 April 2, 2003 Re-SERP IMC 0609.01 issued - as requested bv RIV this revision permittd the choice letter to characterize the riskk Choice letter to ANO informing them the finding was GREATER-THAN-GREEN Additional Information requested-by ANO to be provided by April 11, 2003 Additional information provided - to ANO via overnight mail
-5 April 11, 2003