ML033580456

SERP Worksheet for SDP-Related Findings

ML033580456
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/30/2002
From:	NRC/OE
To:
References
FOIA/PA-2003-0358, IR-01-006
Download: ML033580456 (14)

Text

I iWy r!u.tV r,-r-P vvOrKSneet.wpd Pac Issue Date: 04/30/02 E4-1 0609.01, Exhibit 4 SERP Worksheet for SdP-Related Findings SERP Date: December 10, 2002 Cornerstone Affected and Proposed Preliminary Results:

Licensee: Entergy Operations, Inc.

Facility/Location: Arkansas Nuclear One Docket No(s): 50-313 and 50-368 License No: DPR-51, NPF-6 Inspection Report No: 2001-06 Date of Exit Meeting: August 21, 2001 Issue Sponsor: Dwight Chamberlain Meeting Members:

Issue Sponsor: Dwight Chamberlain Technical Spokesperson(s):

Program Spokesperson:

OE Representative:

A.

Brief Description of Issue ANO Unit 1 fire zones for the diesel generator corridor (Fire Zone 98J) and the north electrical switchgear {Fire Zone 99M) room did not meet separation ts for electrical cables an reudant trains of safe shutdown eau mnt B.

Statement of the Performance Deficiency As a method for complying with 10 CFR Part 50, Appendix R, Section III.G.2, the licensee credited the use of manual actions to remotely operate equipment necessary for achieving and maintaining hot shutdown, in lieu of providing protection (from fire %

damage) to the cables associated with that equipment. The licensee credited a symptom-based approach which relied on the operators ability to detect each failure or mis-operation as it occurred and then perform manual actions as nece a

t iti ate thef C.

Significance Determnination Basis

1.

Reactor Inspection for IE, MS, B cornerstones

a.

Phase 1 screening logic, results and assumptions

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SEPWrsee-p a

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b.

Phase 2 Risk Evaluation (when applicable)

List dominant affected accident sequences by initiator, in order of contribution, and each sequence's numerical contribution.

5 List any pertinent assumptions under each initiator group (A risk analyst should review and verify that Phase 2 process was followed correctly and that the results are reasonable.)

Attach applicable Phase 2 Worksheets See Reference 2.

List any confirmatory checks made using licensee risk information, SPAR

I Troy Pruett - SERP Worksheet.wpd Pag model results, or other source of risk insights.

1.i

2.

A uain9--060,Revision 2, 'ANO-2 IPE 22 Va7lue-s"

3.

ANO Calculation 95-E-0066-02, Revision 2, ANO-1 IPEEE P2 Values"

4.

ANO Unit 1 and Unit 2 IPEEE

5.

ANO Fire Hazards Analysis

6.

ANO White Paper regarding ignition source frequencies

7.

ANO Calculation 02-E-0004-01, "Zone 99-M PSA Analysis for Operator Action SDP"

8.

ANO Calculation 02-E-0004-02, Zone 98-J PSA Analysis for Operator Action SDP"

9.

NRC Memorandum from E. W. Weiss to M. Reinhart, "Fire Hazard Analysis for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. M82872)," dated May 28, 2002

10.

NRC Memorandum from E. W. Weiss to M. Reinhart, "Supplemental Fire Modeling for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. MB2872)," dated July 18, 2002

11.

ANO Unit 1 and Unit 2 Updated Safety Analysis Reports Note any differences and an evaluation of their effect on this determination.

_~~~~~~~

C.

I

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Pqn, Troy Pruett

- SERP Worksheet-wpd pas' I

Concisely address each of the analysis aspects that follow.

PRA tools used:

'3 Affected sequences:

Influential assumptions:

5 Sensitivity of results to each influential assumption:

3

I of greatest uncertainty factors and impact on assumptions: IVf Previous similar analyses (It applicable): NA1 Proposed preliminary or final color: Yellow.

6

2.

All Other Inspection Findings (not IE, MS, B cornerstones)

Flowchart logic and full justification of assumptions used Proposed preliminary/final color D.

Proposed Enforcement.

a.

Regulatory requirement not met.

10 CFR 50.48, Section (b) and 10 CFR Part 50, Appendix R, Section Ill.G.2

b.

Proposed citation.

During an NRC triennial fire protection inspection conducted on June 11 - 15, 2001, at Arkansas Nuclear One, Unit 1, the following violation of NRC requirements was identified. Note that ANO-1 was licensed prior to January 1, 1979; therefore, was required to meet 10 CFR Part 50, Appendix R, Section Ill.G.

10 CFR 50.48, Section (b) states,

'Appendix R to this part establishes fire protection features required to satisfy Criterion 3 of Appendix A to this part with respect to certain generic issues for nuclear power plants licensed to operate before January 1, 1979.... With respect I

... a cavc_

to all other fire protection features covered by Appendix R, all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, lll.J, and /1.O.0 10 CFR Part 50, Appendix R, Paragraph III.G. states,

1.

'Fire protection features shall be provided for structures, systems, and components important to safe shutdown. These features shall be capable of limiting fire damage so that:

a.

One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and

b.

Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2.

Except as provided for in paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

a.

Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier;

b.

Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or

c.

Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area;...

3.

Alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room or zone under consideration, shall be provided:

a.

Where the protection of systems whose function is required for

r hot shutdown does not satisfy the requirement of paragraph G.2 of this section;...

Contrary to the above, in two fire zones in Unit 1, the licensee failed to ensure that cables of redundant trains of systems necessary to achieve and maintain hot shutdown conditions were free of fire damage by one of the means specified in 10 CFR Part 50, Appendix R, Paragraph III.G.2.

c.

Historical precedent. None E.

Determination of Follow-up Review (as needed)

For White findings propose whether HQs (NRR and/or OE) should review final determination letter before issuance. (For greater than White findings review and concurrence by NRR and OE is required as discussed in Section 4b.)

F.

References

1.

NRC Inspection Report 50-313; 368/01-06 dated August 20, 2001 (ML012330501)

2.

Task Interface Agreement - Request for Risk Determination of Fire Protection Findings at Arkansas Nuclear One, Unit 1 (01TIA 1), dated September 10, 2001 (ML012530361)

3.

ANO Calculation 95-E-0066-01, Revision 2, 'ANO-2 IPEEE P2 Values'

4.

ANO Calculation 95-E-0066-02, Revision 2, ANO-1 IPEEE P2 Values

radgU

5.

ANO Unit 1 and Unit 2 IPEEE

6.

ANO FIRE Hazards Analysis

7.

ANO White Paper regarding Ignition Source Frequencies

8.

ANO Calculation 02-E-0004-01, "Zone 99-M PSA Analysis for Operator Action SDP"

9.

ANO Calculation 02-E-0004-02, Zone 98-J PSA Analysis for Operator Action SDP"

10.

NRC Memorandum from E. W. Weiss to M. Reinhart, "Fire Hazard Analysis for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No.

MB2872)," dated May 28, 2002 (ML012330501)

11.

NRC Memorandum from E. W. Weiss to M. Reinhart, 'Supplemental Fire Modeling for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. MB2872)," dated July 18, 2002 (ML021990405)

12.

ANO Unit 1 and Unit 2 Updated Safety Analysis Reports

13.

NRC analyst human reliability screening analysis (RIV SA\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\FIRE HRA.WPD)

14.

NRC analyst qualitative assessment of remaining fire zones in Unit 1 and Unit 2 (RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\ANO MATRIX.WPD)

15.

NRC analyst sensitivity analysis for Fire Zone 99-M (RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\SENSITIVITY ANALYSIS.WPD and RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\ANO SDP CALC DATA.XLS)

I

Issue Date: 04/30/02 E4-1 0609.01, Exhibit 4 SERP Worksheet for SDP-Related Findings SERP Date:

Cornerstone Affected and Proposed Preliminary Results:

Licensee: Entergy Operations, Inc.

Facility/Location: Arkansas Nuclear One Docket No(s): 50-313 and 50-368 License No: DPR-51, NPF-6 Inspection Report No: 2001-06 Date of Exit Meeting: August 21, 2001 Issue Sponsor: Elmo Collins Meeting Members:

Issue Sponsor:

Technical Spokesperson(s):

Program Spokesperson:

OE Representative:

A.

Brief Description of Issue ANO Unit 1 fire zones for the diesel generator corridor and the north electrical switchgear room did not meet separation requirements for electrical cables and redundant trains of safe shutdown equipment. In addition, the licensee did not have adequate procedures for the manual actions necessary to achieve safe shutdown (Section 1 R05.3 of Reference 1).

B.

Statement of the Performance Deficiency The licensee used manual actions to remotely operate equipment necessary for achieving and maintaining hot shutdown, in lieu of providing protection to the cables associated with that equipment, as a method of complying with 10 CFR Part 50, Appendix R, Section III.G.2. The licensee credited a symptom-based approach which relied on the operator's ability to detect each failure or mis-operation as it occurred and then erform C.

Significance Determination Basis

1.

Reactor Inspection for IE, MS, B cornerstones

a.

Phase 1 screening logic, results and assumptions

II 5

b.

List dominant affected accident sequences by initiator, in order of contribution, and each sequence's numerical contribution.

List any pertinent assumptions under each initiator group (A risk analyst should review and verify that Phase 2 process was followed correctly and that the results are reasonable.)

Attach applicable Phase 2 Worksheets See Reference 2.

List any confirmatory checks made using licensee risk information, SPAR model results, or other source of risk Insights.

5~~~~~~~~~~

c.

Phase 3 Analysis (if necessary)

Concisely address each of the analysis aspects that follow.

PRA tools used:

l l~~~~~

Affected sequences:

Sensitivity of results to each Influential assumption:

-Ar l

- - as @ e. - l 1.

-S -



drr.

5

2.

ANOCalculation NO-2 IPEEE P2 Values"

3.

ANO Calculation 95-E-0066-02, Revision 2, ANO-1 IPEEE P2 Values"

4.

ANO Unit 1 and Unit 2 IPEEE

5.

ANO Fire Hazards Analysis

6.

ANO White Paper regarding ignition source frequencies

7.

ANO Calculation 02-E-0004-01, "Zone 99-M PSA Analysis for Operator Action SDP"

8.

ANO Calculation 02-E-0004-02, Zone 98-J PSA Analysis for Operator Action SDP"

9.

NRC Memorandum from E. W. Weiss to M. Reinhart, "Fire Hazard Analysis for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. MB2872)," dated May 28, 2002

10.

NRC Memorandum from E. W. Weiss to M. Reinhart, "Supplemental Fire Modeling for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. MB2872)," dated July 18, 2002

11.

ANO Unit 1 and Unit 2 Updated Safety Analysis Reports Note any differences and an evaluation of their effect on this determination.

I.-..

5 Contributions of greatest uncertainty factors and impact on assumptions:

Previous similar analyses (if applicable): N/A Proposed preliminary or final color

2.

All Other Inspection Findings (not IE, MS, B cornerstones)

Flowchart logic and full justification of assumptions used

E.

Determination of Follow-up Review (as needed)

For White findings propose whether HQs (NRR and/or OE) should review final determination letter before issuance. (For greater than White findings review and concurrence by NRR and OE is required as discussed in Section 4b.)

F.

References

1.

NRC Inspection Report 50-313; 368/01-06 dated August 20, 2001 (ML012330501)

2.

Task Interface Agreement - Request for Risk Determination of Fire Protection Findings at Arkansas Nuclear One, Unit 1 (01TIA11), dated September 10, 2001 (ML012530361)

3.

ANO Calculation 95-E-0066-01, Revision 2, "ANO-2 IPEEE P2 Values"

4.

ANO Calculation 95-E-0066-02, Revision 2, ANO-1 IPEEE P2 Values"

5.

ANO Unit 1 and Unit 2 IPEEE

6.

ANO FIRE Hazards Analysis

7.

ANO White Paper regarding Ignition Source Frequencies

8.

ANO Calculation 02-E-0004-01, "Zone 99-M PSA Analysis for Operator Action SDP"

9.

ANO Calculation 02-E-0004-02, Zone 98-J PSA Analysis for Operator Action SDP"

<g0i NRC Memorandum from E. W. Weiss to M. Reinhart, 'Fire Hazard Analysis for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. MB2872),"

dated May 28, 2002 (ML012330501)

NRC Memorandum from E. W. Weiss to M. Reinhart, 'Supplemental Fire Modeling for Fire Zone 98-J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit 1 (TAC No. M82872),"

dated July 18, 2002 (ML021990405)

12.

ANO Unit 1 and Unit 2 Updated Safety Analysis Reports

13.

NRC analyst human reliability screening analysis (RIV S:\\DRS\\PRAVANO\\99M FIRE ANALYSIS\\FIRE HRA.WPD)

14.

NRC analyst qualitative assessment of remaining fire zones in Unit 1 and Unit 2 (RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\ANO MATRIX.WPD)

15.

NRC analyst sensitivity analysis for Fire Zone 99-M (RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\SENSITIVITY ANALYSIS.WPD and RIV S:\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\ANO SDP CALC DATA.XLS)