ML040050082

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Summary of Meeting with ANO
ML040050082
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 10/03/2002
From: Hannon J
Plant Systems Branch
To:
References
FOIA/PA-2003-0358, GL-83-033, RG-1.189
Download: ML040050082 (4)


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SUMMARY

OF MEETING WITH ANO I L !, I., % -, ,If

t. *'Relied on defih's from RG 1.189 associated circuits Lk F I

-i .. emergency control station I.I free of fre dan a e v Lcx r 1

V-1ul 21982 Mattson iif < shuto081 c" cc-i--

allowable rpii~ civ aesud ~ Il' i/July, 1, 1982 Appendix R compliance reviewx-.,V%' x (U' I '

.~~~f ~ ~Fa_ ctions to comply with IIGI . C-Ct '

N143 fire zones I LA 1~~I00 comply with Appendix R

~i4 of the 100 rlied on manual actions to meet IIIGI alternate shutdown zones (111G3) were identified in Appendices A & B C L,/A ecting ~~on alternate safe shiutdown c.\m. .--

,qustinedthe14 zones -that relied on manual actions

~,'eetig summyissued Septdmbcf 1982.

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/ saffaskd fr wvritten discussion of the mebodology being employed

  • Ocobe 5, 982response

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/ methodology discussion provided -c-> cev;-(P j~C Y\:L

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,/treated safe shutdown for IIIGI and altermae II1G3 compliance -

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the component to be operated is not in affected fire zone.-

sufficient time to performn the required action is available - .

personnel beyond fire brigade are available '-I L

examples of the various fire zones wer8 provided one that required an exemption (43) one that met Appendix R (100) one that relied on manual actions (110)

Nuclear Utility Fire Protection Group Meeting March 16, 1983 summary dated March 28, 1983 mm J .. Taylor's answers on the inspection process

~Leon Whtnej~' vas also i attendance accepted the ASB position on mianual actions for associated circuits -

I&E Manual 25 15/62, Rev I Inspection bf SSD equirements section HIG looked at both alternative and redundant safe tdw ars.. _

  • SECY 83-269 dated July5,l1983-PnA t ~kk -L allowable repairs to achieve safe suldowvn referenced Mattson memo

( allowed manuial actions to comply with IIIGI

  • discussion of fire zones and fire areas pursuant to GL 83-33
  • regional workshops held in spring of 1984
  • CEB guidance (free of fire damage) for llIGI compliance
  • AprIl 27, 1984 meeting with ANO sunimary dated June 5, 18 ~~~

methodology appeared to be consistent wvith staff position

  • reaqalyis agaiist IG, J, &OCi's(Y( I credit taken for manual operation of valves not invicinitoffr

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Total CDF 1. -UH (a)Severity Factors. S. ,f,r.e,seyeqityfactor is a fractional value (between 0 and 1)that is used to adjust fire frequency estimates to reflect some specific mitigating pattern of.Y behaviorof the fire event. ..The severity factor is applied to reflect a split in large versus small fires. " neAge.ic ,of.plant-specific information,.theseverityfactors forjlei,_v,.

'7 electrical cabinets, ventilation syster~p and fire ,proitioq panels were b ased. or;heag.E Fjg6.e,?PAmplementatiQn Guide (FP P e),oDecember.1 995 (Section D.3). .The FP.RAIG.,

spyprItyJactors ranged from.8OM taland engine ing ju*Jgrent. wasused tQdetermine. ai In the case of the electrical cabinets attery c gers in fire zone 98-J, the EPRI FPRAIG did not Drovide specific erity facto alues for electrical cabinets and battery t

d~pi chargersAnite li'a,# building t ofg  ; v-o.a.sth t~~~~yi __an~l~si_ pa a , i Probability of automatic suppression system being unavailable, P1 - As discussed in Section 3(b), the probability of pre-action sprinkler system in fire zone 98-J being unavailable is assumed to be 0.05 for the normal operating state based on the EPRI database (EPRI FIVE report, page 10.3-7). This unavailability value include the consideration for failure of the system to operate on demand and the system being out of service at the time of a fire (due to shut control valve, etc.). Infire zone 99-M, no automatic fire suppression system is provided. Therefore, the P1 value was assumed to be 1.0.

(c)Manual Suppression by Fire Brigade, P2 - Recent fire drills performed on fire zone 100-N,which is adjacent to fire zone 99-M, indicated that the response times of the entire fire brigade arriving at the fire zone averaged less than 10 minutes. wlhere are two access ala ypoints-to.the fire zones -which are easily-accessible by-the fire-brigade respons.ej.geams" Based on these considerations, it was assumed that any fire scenario requiring greater

  • than 20 minutes to sustain cable damage may be suppressed by the fire brigade.

Hawever,..the SPLB fire modeling analyses indicate that severe, fires with. HRR greaterp than 400 kW in fire.zones.90-Jand.9 M could cause.damage to the overhead cables in;I

-approximately 19 minutes and 10 minutes, respectively. -Thvrefore, the failure prob&bilit of manual suppression by the fire brigade associated with severe fires was estimated to be b.5in this risk analysis.

(d)Conditional Core Damage Probability, P3 - For the fire scenarios in fire zone 98-J involving ignition of the electrical cabinets, battery chargers, ventilation systems, and fire protection panels, it is assumed that one equipment train would be available to perform mitigating functions because a one-hour rated barrier surrounds the Red train AC instrumentation power supply cables. Although other Red train power cables in fire zone 98-J are unprotected, the estimated time of 19 minutes to cable damage allows the arrival of the fire brigade in 10 minutes to control the fire. It is not likely that a fire from these sources would damage both equipment trains at the same time. Therefore, the CCDP

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associated circuits defined consistent with GL 81-12 clarification -

  • inspection 87-14 report dated Sep 30, 1987 (D. Kubicki, et. al.)

found manual component operation for fire induced maloperation acceptable manual operation of redundant components evaluated to be satisfactor J

-- references made to SOC for IIIJ and inspectionguidance_

  • FPFI report dated T 98orusqueanna q u e-protection for fire-iduced spurious failures found acceptabl.e recognized the use of symptom-based procedures for post-fire safe shutdown URI identified regarding adequacy of symptom-based procedures
  • Susquehanna response dated July 20, 1998 pre-fire plans describe symptoms that lead to required manual actions
  • NRC Special Inspection Report dated September 4, 1998 closed FPFI URI based on procedural clarifications and improvements J
  • ANO interprets the usqueln inspection resiltis`si-6ffri~nliiTlheir use of symptom-based procedures for post-fire safe shutdown
  • ANO recommends that symptom-based procedures be used to guide manual actions in any future rulemak-ing by NRC
  • ANO firmly believes that their use of manual actions for IIIG2 redundant safe shutdown areas is consistent with NRC regulations and guidance
  • ANO believes that the b/f panel finding was flaved because we did not adequately consider the licensing basis for their facility
  • they attempted to lay out their understandingfjtheir licensing basis at this information exchange meeting
  • they asserted that their survey ofother re-74jan Idicated they wre.not outliers; there are at leas thefacilities who have similar manual action methodology without prior NRC approval
  • the meeting was adjourned - NRC will consider the licensee's perspective as we determine how to process the finding in the ROP John Hannon October 3, 2002

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