ML040280201

SERP Worksheet for SDP-Related Findings

ML040280201
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/23/2003
From:	Office of Nuclear Reactor Regulation, NRC/OE, NRC Region 4
To:
References
FOIA/PA-2003-0358, IR-01-006
Download: ML040280201 (9)

Text

SERP Worksheet for SDP-Related Findings IMC 0609 Exhibit 4 of Ant I SERP Date:

January 23, 2003 Cornerstone Affected and Proposed Preliminary Results:

This finding affects the Mitigating Systems Cornerstone, because It affects the objective

• fo; ensure the availability, reliability, and capability of systems that respond to an external event (fire) to prevent undesirable consequences. Specifically, the licensee's ability to achieve and maintain hot shutdown conditions In the event of a fire in Fire Areas 98J and 99M Is affected by the lack of separation of redundant trains of safe shutdown systems in accordance with 10 CFR Part 50, Appendix R, Section lIl.G.2.

Licensee:

Facility/Locatlon:

Docket No(s):

License Nops):

Inspection Report No:

Date of Exit Meeting:

Entergy Operations, Mic.

Arkansas Nuclear One 50-313 and 50-368 DPR-51, NPF-6 2001-06 August 21, 2001-final exit meeting pending Issue Sponsor:

Meeting Members:

Issue Sponsor:

Technical Spokesperson:

Program Spokesperson:

OE Representative:

Dwight Chamberlain Dwight Chamberlain NRR Probabilistic Safety Assessment Office Branch NRR Inspection Program Branch Jennifer Dixon-Herrity 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 requirements for electrical cables associated with 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).

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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 locally operate equipment necessary for achieving and maintaining hot shutdown, In lieu of ensuring cables associated with that equipment were free of fire damage as required by 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 mal-operation as it occurred and perform -

manual actions as necessary to mitigate the effects of the failure or mal-operation. fue to the number of components that may be affected as a result of fire and uncertainty regarding the timing and synergistic impact that potential failures may have on the operator's ability to accomplish required shutdown functions, the inspection team determined that the strategy for impl~nentlng manual actions to mitigate a postulated fire were Inadequate (Reference 1).'

C.

Significance Determination Basis

1.

Reactor Inspection for IE, MS, B cornerstones

a.

Phase 1 screening logic, results and assum tions

b.

Phase 2 Risk EvaluatIon

/

_\\

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

2 A

lLs-t 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.)

>o Attach applicable See Reference 2.

e Phase 2 Worksheets List any confirmatory checks made using licensee risk Information, SPAR model results, or other sourcerkInsights.

7 5

Note any differences and an evaluation of their effect on this determination.

3

C.

Phase 3 Analysis (if necessary)

Concisely address each of the analysis aspects that follow.

PRA tools used:

Affected sequences:

4

Sensitivity of results to each Influential assumption:

-5 7

Contributions of greatest uncertainty factors and Impact on assumptions:

Previous similar analyses: NIA Proposed preliminary or final c 5

2.

All Other Inspection Findings (not IE, MS, B cornerstones): NONE D.

Proposed Enforcement.

a.

Regulatory requirement not met.

10 CFR 50.48, Section (b) and 10 CFR Part 50, Appendix R, Sections 111.G.2, lII.G.3, and III.L.

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 III.G.

10 CFR 50.48, Fire protection," 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 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 lll.G, ll.J, and /11.0."

10 CFR Part 50, Appendix R, Paragraph III.G, uFire protection of safe shutdown capability,' 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 6

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 shag 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 barier,

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 hon-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.

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

Contrary to the above, In Fire Zones 98J and 99M 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, or by alternative means specified in III.G.3.

Specifically, In Unit 1, Fire Zone 98J, the licensee did not ensure that cables associated with redundant trains of the following equipment necessary to achieve and maintain hot shutdown were free of fire damage, and did not provide alternative shutdown capability:

control cables for emergency diesel generators; X control cables for emergency diesel generator lock-out relays and output breakers; control cables for emergency feedwater system pumps; 7

control cables for service water system valves to emergency diesel generator jacket water cooling; control cables for service water system pumps and valves; make-up system pumps and valves; control cables for steam generator atmospheric dump and block valves; and control cables for pressurizer emergency relief and block valves.

In addition, in Unit 1, Fire Zone 99M, the licensee failed to ensure that cables associated with redundant trains of the following equipment necessary to achieve and maintain hot shutdown were free of fire damage, and did not provide alternative shutdown capability:

power and control cables for service water system pumps; emergency diesel generator output breaker 4KA; control cables for emergency diesel generator output breaker 4KB; control and instrument cables for emergency feedwater system pumps; control cables for emergency feedwater system valves; power and control power cables for make-up system pumps.

c.

Historical precedent. None E.

Determination of Follow-up Review 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.)

HQ should review the final determination letter before Issuance.

F.

References

1.

NRC Inspe6tion 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 (01 TIA 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"

5.

ANO Unit 1 and Unit 2 IPEEE

6.

ANO FIRE Hazards Analysis

7.

ANO White Paper regarding Ignition Source Frequencies 8

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 Dlesel 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 S:\\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\\LANO\\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 SA\\DRS\\PRA\\_ANO\\99M FIRE ANALYSIS\\ANO SDP CALC DATA.XLS) 9