ML040360409
| ML040360409 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/14/2003 |
| From: | Merschoff E NRC Region 4 |
| To: | Anderson C Entergy Nuclear Operations |
| References | |
| FOIA/PA-2003-0358, IR-01-006 | |
| Download: ML040360409 (27) | |
See also: IR 05000313/2001006
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON, TEXAS 76011.8064
Craig G. Anderson, Vice President,
Operations
Arkansas Nuclear One
Entergy Operations, Inc.
1448 S.R. 333
Russellville, Arkansas 72801-0967
SUBJECT:
RESPONSE TO BACKFIT CLAIM REGARDING NRC INSPECTION
REPORT 50-313/01-06; 50-368/01-06
Dear Mr. Anderson:
This letter is written in response to your letter of September 28, 2001, in which you claimed
that our position that manual actions cannot be used to comply with 10 CFR Part 50, Appendix
R,Section III.G.2. was a backfit. At issue is your use of manual actions for achieving and
maintaining hot shutdown conditions in the event of a fire In the Unit I emergency diesel
generator corridor and north switchgear room. In your letter of September 28, 2001, you
asserted that the NRC has accepted such manual actions in the past, and stated that our
position with respect to disallowing the use of manual actions for complying
of Appendix R should be considered a backfit that is generic to all plants.
On October 26, 2001, and again on _
_
, we convened a backfit panel in accordance
with NRC Management Directive 8.4, "NRC Program for Management of Plant-Specific
Backfitting of Nuclear Power Plants," to review your backfit claim as stated in your letter of
September 28, 2001. After careful consideration of your appeal, we have determined that (1)
the NRC did not Impose a regulatory staff position that is new or different from a previously
applicable staff position relative to the requirements of 10 CFR Part 50, Appendix R,
Section Ill.G.2; (2) the NRC did not approve the use of manual actions for complying with
10 CFR Part 50, Appendix R, Section III.G.2 in the Unit 1 diesel generator corridor and north
switchgear room; and (3) your methodology for using manual actions (in the event of a fire in
the Unit 1 diesel generator corridor and north switchgear room), in lieu of ensuring that one
train of redundant equipment needed for achieving and maintaining hot shutdown conditions
was free of fire damage, does not comply with the requirements of 10 CFR Part 50,
Appendix R, Section IlI.G.2.XThe bases for these conclusions are described in Enclosures 1,
2, and 3. Enclosure 4 lists the licensing basis documents we reviewed in reaching these
conclusions
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In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at
httD:/lwww.nrc.aov/NRC/ADAMSfindex.html (the Public Electronic Reading Room).
fShould you have any questions concerning this matter, please contact me at (817) 860-8225
or Mr. A. T. Howell at (817) 860-8180. ;
-'A.1
Sincerely,
IRA/
Ellis W. Merschoff
Regional Administrator
Enclosures: As stated
Dockets: 50-313; 50-368
cc: w/Enclosure
Executive Vice President
& Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Manager, Washington Nuclear Operations
ABB Combustion Engineering Nuclear
Power
12300 Twinbrook Parkway, Suite 330
Rockville, Maryland 20852
County Judge of Pope County
iKana Zrnitrt - MIUMI~t IMMtf -LU ^d'IJ
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Pope County Courthouse
100 West Main Street
Russeliville, Arkansas 72801
Winston & Strawn
1400 L Street, N.W.
Washington, DC 20005-3502
David D. Snellings, Jr., Director
Division of Radiation Control and
Emergency Management
4815 West Markham Street, Mail Slot 30
Little Rock, Arkansas 72205-3867
Mike Schoppman
Framatome ANP, Inc.
Suite 705
1911 North Fort Myer Drive
Rossylin, Virginia 22209
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Electronic distribution from ADAMS by RIV:
W. F. Kane, DEDO
S. J. Collins, D:NRR
Regional Administrator (EWM)
Deputy Regional Administrator (TPG)
DRS Director (ATH)
DRP Director (KEB)
DNMS, Director (DDC)
K. D. Smith, RC (KDSI)
G. F. Sanbom, D:ACES (GFS)
ACES, Enforcement Staff (GMV)
Branch Chief, DRS/EMB (CSM)
Branch Chief, DRPID (LJS)
Senior ProJect Engineer, DRP/D (JFMI)
Senior Resident Inspector (RLB3)
ANO Site Secretary (VLH)
Chief, DRPITSS (PHH)
RITS Coordinator (NBH)
G. M. Holahan, NRR
S. C. Black, NRR
S. A. Richards, NRR
R. J. Barrett, NRR
J. N. Hannon, NRR
- lat'COGC (GSM)
Scott Morris (SAMI)
M. R. Johnson, NRR
BGramm (RAG)
TAlexion (TWA)
NRR Event Tracking System (IPAS)
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ENCLOSURE 1
BACKFIT ANALYSIS
In a letter dated September 28, 2001, Entergy Operations, Inc., claimed that Region tVs
position that manual actions cannot be used to comply with 10 CFR Part 50, Appendix R,
Section III.G.2. was a backfit, generic to all plants.
Backfitting is defined in 10 CFR 50.109 "as the modification of or addition to systems,
structures, components, or design of a facility, or the design approval or manufacturing license
for a facility; or the procedures or organization required to design, construct or operate a
facility; any of which may result from a new or amended provision in the Commission rules or
the imposition of a regulatory staff position interpreting the Commission rules that is either new
or different from a previously applicable staff position..."
FIRE PROTECTION REGULATIONS
In 1981, the NRC issued 10 CFR 50.48, "Fire protection," and Appendix R to 1 0 CFR Part 50,
"Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."
Arkansas Nuclear One (ANO) Unit I was licensed in 1974, and Unit 2 was licensed in 1978;
therefore, for both units, the licensee was required to meet the provisions of 10 CFR Part 50,
Appendix R, Sections IllI.G, lll.J, and 111.0.
10 CFR 50.48, Fire protection.
(b)
'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.
(2)
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 l/l. G, III.J, and 111. ."
10 CFR Part 50, Appendix R. Paragraph Il.G. Fire protection of safe shutdown capability
2.
'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
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72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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3.
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 hot
shutdown does not satisfy the requirement of paragraph G.2 of this
section; or
b.
Where redundant trains of systems required for hot shutdown located in
the same fire area may be subject to damage from fire suppression
activities or from the rupture or inadvertent operation of fire suppression
systems.
In addition, fire detection and a fixed fire suppression system
shall be installed in the area, room, or zone under consideration.'
STATEMENTS OF CONSIDERATION for IOCFR50.48 and 10 CFR PART 50, APPENDIX R
1.
As shown below, in the statements of consideration for 10 CFR 50.48 and 10 CFR Part 50, Appendix R (FR 76606, Vol. 45 No. 225, November 19, 1980), the Commission
explained that there were three ways to ensure that one means of achieving safe
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shutdown is available (Appendix R.l1l.G.2), and that if none of these three methods is
feasible, then alternative or dedicated safe shutdown capability is required (Appendix
R. III.G.3).
'G. Protection of Safe Shutdown Capability Technical Basis.
The objective for the protection of safe shutdown capability is to
ensure that at least one means of achieving and maintaining safe
shutdown conditions will remain available during and after any
postulated fire in the plant. Because it is not possible to predict
the specific conditions under which fires may occur and
propagate, the design basis protective features are specified
rather than the design basis fire. Three different means for
protecting the safe shutdown capability outside of containment
-are acceptable. The first means is separation of redundant safe
shutdown trains and associated circuits by means of 3-hour fire
rated barriers. The second means is a combination of separation
of redundant safe shutdown trains and associated circuits by a
1-hour fire rated barrier and automatic fire suppression and
detection capability for both redundant trains. The third means,
which may be used only when redundant trains and associated
circuits are separated by 20 feet or more of clear space, requires
automatic fire suppression and detection systems in the area. An
alternative or dedicated safe shutdown capability independent of
the fire area is required if fire protection for safe shutdown
capability cannot be provided as outlined above.. .
GENERIC NRC GUIDANCE
Generic Letter (GL)81-124 shown below, in the first paragraph of GL 81-12 and again in
Enclosure 2 to GL 81-12, the NRC explained that cables for or associated with redundant safe
shutdown systems must be protected from the effects of fire by the methods described in
Section III.G.2 of Appendix R to 10 CFR Part 50 (Appendix R), or provided witlyaltemative or
dedicated shutdown capability as described in Section III.G.3 of Appendix R_
'Paragraph 50.48(b) of 10 CFR Part 50, which became effective on February
17, 1981, requires all nuclear plants licensed to operate prior to January 1, 1979
to meet the requirements of Section lIl. G, ll.J and 111.0 of Appendix R to 10 CFR Part 50 regardless of any previous approvals by the Nuclear Regulatory
Commission (NRC) for altemative design features for those items. This would
require each licensee to reassess all those areas of the plant ". . . 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 or (sic) redundant trains of systems necessary to achieve and maintain
hot shutdown conditions are located within the same fire area outside of primary
containment. . ."* to determine whether the requirements of Section I/I. G.2 of
Appendix R are satisfied. If not, the licensee must provide alternative shutdown
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capability in conformance with Section III.G.3 or request an exemption if there is
some justifiable basis...
Quoted from Section Ill.G.2 of Appendix R to
10 CFR Part 50. . .'
Section lil. G of Appendix R to 10 CFR Part 50 required cabling for or
associated with redundant safe shutdown systems necessary to achieve and
maintain hot shutdown conditions be separated by fire barriers having a
three-hour rating or equivalent protection (see Section III.G.2 of Appendix R) ...
Safety related and non-safety related cables that are associated with the
equipment and cables of the alternative, or dedicated method of shutdown are
those that have a separation from the fire area less than that required by
Section 111.G.2 of Appendix R to 10 CFR 50..
Clarification of GL 81-1 2{Lhe NRC further clarified the requirements of Appendix R, Section
III.G In a memorandum from Darrell G. Elsenhut, Director, Division of Licensing, NRR, to Roget
J. Mattson, Director, D'vision of system Integration, NRR, dated March 22, 1982, which was
sent to all licensees.
mUsing the requirements of Sections Il.G and IILL of Appendix R, the capability
to achieve hot shutdown must exist given a fire in any area of the plant in
conjunction with a loss of offsite power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Section ill.G of Appendix
R provides four methods for ensuring that the hot shutdown capability is
protected from fires. The first three options as defined in Section III.G.2
provides methods forprotection from fires of equipment needed for hot
shutdown:
1.
Redundant systems including cables, equipment, and associated circuits may
be separated by a three-hour fire rated barrier; or,
2.
Redundant systems including cables, equipment and associated circuits may be
separated by a horizontal distance of more than 20 feet with no intervening
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combutibles. inaddition, fire detection and an automatic fire suppression
system are required; or
3.
Redundant systems including cables, equipment and associated circuits may be
enclosed by a one-hour fire rated barrier. In addition, fire detectors and an
automatic fire spression sysptehitie required.
The last option as defined by Section III. G.3 provides an alteinative shutdown
capability to the redundant trains damaged by a fire.
4.
Alternative shutdown must be independent of the cables, equipment and
associated circuits of the redundant systems damaged by the fred
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"Protection of Equipment Necessary To Achieve Hot Shutdown," of IN 84-09 states,
"Appendix R, Section Ill.G. 1, requires that 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 one train of
systems necessary to achieve and maintain a hot shutdown condition from
either the control room or emergency control station(s) is free of fire damage.
Sections lll.G.2 and lll.G.3 specify four alternatives that may be implemented
outside of primary containment to assure that one redundant train of equipment,
cabling and associated circuits necessary to achieve and maintain hot shutdown
remains free of fire damage. The alternatives are:
1.
Separation of redundant trains of equipment, cabling, and associated circuits by
a three-hour fire barrier.
2.
Enclosure of redundant trains of equipment, cabling, and associated circuits by
a one-hour fire barrier with fire detection and automatic fire suppression systems
installed in the area.
3.
Separation of redundant trains of equipment, cabling, and associated circuits by
a horizontal distance of 20 feet with no intervening combustibles and with fire
detection and automatic fire suppression systems installed in the area.
4.
Installation of alternative or dedicated shutdown capability independent of the
equipment, cabling, and associated circuits under consideration, and installation
of fire detection and fixed fire suppression systems in the area containing this
alternative or dedicated shutdown capability."
NUREG 0800, STANDARD REVIEW PLAN 9.5.1, "FIRE PROTECTION PROGRAM"
In 1981, the NRC issued Revision 3 of NUREG 0800, Standard Review Plan Section 9.5.1,
"Fire Protection Program" as guidance to NRC staff in performing fire protection program
reviews. NUREG 0800 included Revision 2 to Branch Technical Position CMEB 9.5-1,
"Guidelines for Fire Protection for Nuclear Power Plants," which provided guidance acceptable
for implementing .10 CFR 50.48 and Appendix R. Section C.5.b, "Safe Shutdown Capability,"
of Branch Technical Position CMEB 9.5-1 states,
M(1)
Fire protection features should be provided for structures, systems, and
components important to safe shutdown. These features should 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 stations(s)
is free of fire damage; and
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(b)
Systems necessary to achieve and maintain cold shutdown from either
the control room or emergency control stations(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)
To meet the guidelines of Position C5.b. 1, one of the following means of
ensuring that one of the redundant trains is free of fire damage should be
provided:
(a)
Separation of cables and equipment and associated circuits of
redundant trains by a fire barrier having a 3-hour rating. Structural steel
forming part of or supporting such fire barriers should be protected to
provide fire resistance equivalent to that required of the barrier;
(b)
Separation of cables and equipment and associated circuits of
redundant trains by a horizontal distance of more than 20 feet with no
intervening combustible or fare hazards. In addition, fire detectors and an
automatic fire suppression system should be installed in the fire area; or
(c)
Enclosure of cable and equipment and associated circuits of one
redundant train in a fire barrier having a 1-hour rating. In addition, fire
detectors and an automatic fire suppression system should be installed
in the fire area.
(3)
If the guidelines of Positions C5.b. 1 and C5.b.2 cannot be met, then alternative
or dedicated.shutdown capability and its associated circuits, independent of
cables, systems or components in the area, room, or zone under consideration
should be provided.'
ANO EXEMPTIONS AND SAFETY EVALUATION REPORTS
In the following safety evaluation reports (SERs) and exemptions, the NRC restated the
requirements of Appendix R, Section IlI.G, and clarified how to ensure that one train of
equipment and cables necessary for achieving and maintaining hot shutdown conditions was
free of fire damage. These documents explain that there are three methods specified in
Section IlI.G.2 of Appendix R of ensuring one train free of fire damage, and that if these
methods cannot be met, then an alternative fire protection configuration must be provided in
accordance with Section III.G.3 of Appendix R.
Exemption and SER Dated March 22. 1983: Section II of the Exemption states,
Section III. G of Appendix R requires fire protection for equipment important to
safe shutdown. Such fire protection is achieved by various combinations of fire
barriers, fire suppression systems, fire detectors, and separation of safety trains
(II.G.2) or alternative safe shutdown equipment free of the fire area (lIl.G.3).
The objective of this protection is to assure that one train of equipment needed
for hot shutdown would be undamaged by fire, and that systems needed for
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cold shutdown could be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.'
Section 1.0 of the SER issued with the Exemption states,
'Section III. G.2 requires that one train of cables and equipment necessary to
achieve and maintain safe shutdown be maintained free of fire damage by one
of the following means:
a.
Separation of cables and equipment and associated non-safety circuits of
redundant trains by a fire barrier having a 3-hour rating. Stnrctural 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.
If these conditions are not met,Section III.G.3 requires alternative shutdown
capability independent of the fire area of concem. It also requires a fixed
suppression system installed in the fire area of concern if it contains a large
concentration of cables or other combustibles.
These alternative requirements are not deemed to be equivalent for all
configurations; however, they provide equivalent protection for those
configurations in which they are accepted.
Because it is not possible to predict the specific conditions under which fires
may occur and propagate, the design basis protective features are specified in
the rule rather than the design basis fire. Plant specific features may require
protection different than the measures specified in Section Il. G. In such a case,
the licensee must demonstrate, by means of a detailed fire hazards analysis,
that existing protection or existing protection in conjunction with proposed
modifications will provide a level of safety equivalent to the technical
requirements of Section II. G of Appendix R.
In summary, Section IlI.G is related to fire protection features for ensuring that
systems and associated circuits used to achieve and maintain safe shutdown
are free of fire damage. Fire protection configurations must either meet the
specific requirements of Section III.G or an alternative fire protection
configuration must bejustified by a fire hazards analysis. a
Exemption and SER Dated October 26. 1988: The Exemption states,
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"Section 111. G of Appendix R requires fire protection for equipment important to
post-fire shutdown. Such fire protection is achieved by various combinations of
fire barriers, fire suppression systems, fire detectors, and separation of safety
trains (lII.G.2) or alternate post-fire shutdown equipment free of the fire area
(III.G.3). The objective of this protection is to assure that one train of equipment
needed for hot shutdown would'be undamaged by fire, and that systems
needed for cold shutdown could be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (111. G. 1).'
Section 1.0 of the SER issued with the Exemption states,
wSection ll/.G.2 requires that one train of cables and equipment necessaryto
achieve and maintain safe shutdown be maintained free of fire damage by one
of the following means:
a.
Separation of cables and equipment and associated non-safety circuits of
redundant trains by a fire barrierhaving 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.
If these conditions are not met, Section Ill. G.3 requires an alternative shutdown
capability independent of the fire area of concem. It also requires a fixed fire
suppression system be installed in the fire area of concern if it contains a large
concentration of cables or other combustibles. These alternative requirements
are not deemed to be equivalent; however, they provide equivalent protection
for those configurations in which they are accepted.
Because it is not possible to predict the specific conditions under which fires
may occur and propagate, the design basis protective features are specified in
the rule rather than a design basis fire. Plant specific features may require
protection different than the measures specified in Section I//.G. In such a case,
the licensee must demonstrate, by fire hazards analysis, that existing protection
or existing protection in conjunction with proposed modifications will provide a
level of safety equivalent to the technical requirements of Section /11. G of
Appendix R.
In summary, Section IlI.G is related to fire protection features for ensuring that
systems and associated circuits used to achieve and maintain safe shutdown
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are free of fire damage. Fire protection configurations must either meet the
specific requirements of Section III.G or another fire protection configuration
must be justified by a fire hazards analysis.
BACKFIT ANALYSIS CONCLUSION
In reviewing the above documents, the panel found that the regulations, statements of
consideration, generic correspondence, as well as ANO-specific safety evaluation reports are
in agreement concerning the use of manual actions for achieving and maintaining hot
shutdown conditions as required in Section Ill.G of Appendix R to 10 CFR Part 50.. As these
documents show, the NRC did not consider manual actions to be acceptable for complying
with 10 CFR Part 50, Appendix R, Section III.G.2; however, if the requirements of Section
III.G.2 could not be met, manual actions were permitted under Section III.G.3. The panel
concluded that the position to disallow the use of manual actions for meeting i 0 CFR Part 50,
Appendix R,Section III.G.2 is not an imposition of a regulatory staff position interpreting the
Commission rules that are either new or different from a previously applicable staff position.
Therefore, this position is not a backfit generic to all plants, nor is It a backfit specific to ANO.
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Enclosure 2- Section III.G.2 LiErtsirEmsa~ioaW'siac.
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ENCLOSURE 2
APPENDIX R, SECTION III.G.2 LICENSING BASIS ANALYSIS
In a letter dated September 28, 2001, Entergy Operations, Inc. (Entergy), claimed that
Region [V's position that manual actions cannot be used to comply with Section III.G.2 of
10 CFR Part 50, Appendix R (Appendix R) was a backfit. In addition to the backfit claim,
Entergy asserted that during the review of their fire protection program in the 1980's, the NRC
was aware that manual actions were sometimes credited for complying with Section III.G. of
Appendix R at ANO, and that the NRC's failure to'categorically deny the use of all manual
actions for complying with Section III.G.2 implied tacit approval. Because of this tacit approval,
the licensee stated that the use of manual actions became part of the licensing basis.
NRC EXEMPTIONS AND SAFETY EVALUATION REPORTS
ANO-1 was licensed prior to January 1, 1979; therefore, was required to meet 10 CFR Part 50,
Appendix R,Section III.G.
Safety Evaluation Report (SER) dated May 13, 1983: This SER contained the NRC's review of
the licensee's methodology for altemativ esafe shutdown in accordance with Appendix R,
Sections III.G. 3 and III.G.L.
SER, "Introduction,' reads
'By submittals dated July 1 and July 29, 1982, the licensee described the
means by which safe shutdown can be achieved in the event of fire and
proposed modifications to the Arkansas Nuclear One Units I and 2 to meet the
requirements of Appendix R to 10 CFR 50, Items III.G.3 and Ill.
SER, Section C. "Remaining Plant Areas'
(
'MAII other areas of the plant not required to have alternate safe shutdown will
comply with the requirements of Section III. G.2 of Appendix R, unless an
exemption request has been approved by the staff."
Exemption and (SER) dated March 22. 1983: In this SER, the NRC clearly described the
requirements of Appendix R,Section III.G.2, and added that if those requirements could not be
met, then the licensee was required to meet the provisions of Appendix R,Section III.G.3.
SER, Section 1.0 reads,
'Section III.G.2 requires that one train of cables and equipment necessary to
I
Enclosure 2 - Section Ill.G.2 LlmtsiREmpisativalysic.
-1 8-
capability independent of the fire area of concern. It also requires a fixed fire
suppression system be installed in the fire area of concern if it contains a large
concentration of cables or other combustibles. These alternative requirements
are not deemed to be equivalent; however, they provide equivalent protection
for those configurations in which they are accepted."
LICENSEE SUBMITTALS
Licensee letter dated July 1. 1982: Arkansas Power & Light submitted the results of their
Appendix R compliance review by letter dated July 1, 1982. This review evaluated fire areas in
ANO Units 1 and 2 for compliance.to 10 CFR 50.48 and Appendix R, incorporating
recommendations, clarifications, and evaluation crfe-tia of Generic Letter 81-12 (see
Enclosure I 'for relevant excerpts from GL 81-12). In the general description of their
Appendix R analysis methodology, the licensee'staTed that they: first, credit manual actions;
second, provide protection for the remaining vulnerable safe shutdown equipment using the
separation criteria of Section Ill.G of Appendix R; and third, provide 'altemative methods of
mitigating the effects of fire damage to any remaining equipment whose da'mage from fire
could adversely affect safe shutdown.
later statement
that this methodology would divert "piiyreliance from adminit-raveo-trols to preclude
fires or damage due to fires." The reliance on manual actions to operate equipment that is
damaged by a fire does not preclude damage. In addition, the licensee failed to specify that
_
manual actions were credited for complying with Section Ill.G.2 of Appendix R in Fire Zones (
98J and 9OM] ;X
Section I, 'Introduction,' of this submittal, the licensee stated,
-_
6.
In certain cases, credit for manual operation of equipment was taken if controls}
(and power for valves) could possiblfy] be damaged by a fire. Such credit was I
7
taken only if:
a.
the component to be operated is not located in the affected fire zone,
although the cable may be damaged by fire;
b.
sufficient time is available to perform the required manual actions; and
c.
personnel are available, beyond the fire brigade and minimum
operations shift crew limitations, to perform the manual actions.
7.
For redundancies that were still identified as potential safe shutdown concerns
following the above review, specific physical separation, barriers, intervening
combustibles, and suppression systems were evaluated to determine
compliance with Section lIl.G of Appendix R."
8.
For those redundancies remaining as a potential safe shutdown concern
following 7 above, alternative means for accomplishing the necessary function
was reviewed.
Enclosure 2 - Section III.G.2 I-I~-19E-satiaWysIsc.
_1 9_
'The evaluations described above were performed in accordance with the
criteria of appendix R, including: consideration of cable insulation as
combustible; taking no credit for cable coatings to act as a thermal or radiant
barrier to protect cables; and diverting primary reliance from administrative
controls to preclude fires or damage due to fires."
Licensee letter dated October 5, 1982: In a meeting held on August 31, 1982, and in the
meeting summary dated September 3, 1982, the NRC requested additional information
Including a description of the manual actions in fire zones that the licensee had indicated were
in full compliance with Appendix R. In the letter of October 5, 1982, the licensee listed the
following fire zones as being in full compliance with Appendix R, but requiring some sort of
manual or non-routine operation: 149E, 67U,68P,128E,170Z, 38Y,79U,1121, 46Y, 47Y,
2084DD, 211 IT, 2097X, and 2155A. Fire Zones 98J and 99M were not listed.
Licensee letter dated August 15. 1984: In this submittal, the licensee forwarded their
re-evaluation of their compliance with Appendix R using additio~nal guidance provided in
Generic Letter 83-33, and Information Notice (IN) 84-09.'
s'shown below, the licensee stated
that credit for manual action may be taken; however did no specify whether these manual
actions w~ere- for meetin~g Section lIl G.2 o
as an acceptable method for complying with Appendix R, Section IlI.G.2
,
Section II.B 'Initial Conditions)aYd Assumptions," of this reanalysis reads,
"The reanalysis of ANO-1 and 2 was performed under the initial conditions
defined by Appendix R to 10CFR50. Those conditions are consistent with those
utilized in AP&L's original Appendix R compliance submittal dated July 1, 1982
(OCAN078202). and subsequent correspondence dated November 11, 1982
(OCANI18210). ... Where adequate time is available, and the valve is not
physically located in the vicinity of the postulated fire, credit is taken for manual
operation of manually operable valves.'
Section III.D, 'Activities Required for Achieving Hot Shutdown" of this reanalysis reads,
"The activities required for achieving hot shutdown are those credited in our
previous Appendix R submittals referenced earlier in this report."
Section lll.F, "Separation Criteria," of this reanalysis reads,
"...
The method of operability of any component in a given system is to
determine whether it is sufficiently protected or separated from the postulated
fire. The separation criteria to be used are specified in Appendix R to 10CFR50,
Section 1ll.G and in clarification of that regulation presented in Generic Letter 83-33 and IE Information Notice 84-09."
APPENDIX R, SECTION III.G.2 LICENSING BASIS ANALYSIS CONCLUSION
In reviewing the above documents, the panel found that the regulations and the ANO-specific
safety evaluation reports are in agreement concerning the use of manual actions for achieving-
and maintaining hot shutdown conditions as required in Section III.G of Appendix R.
APPENDIX R, SECTION III.G.2 COMPLIANCE ANALYSIS
for FIRE ZONES 98J AND 99M
In a letter dated September 28, 2001, Entergy Operations, Inc. (Entergy), claimed that
Region IV's position that manual actions cannot be used to comply with Section III.G.2 of
10 CFR Part 50, Appendix R (Appendix R) was a backfit. In addition to the backfit claim,
Entergy asserted that during the review of their fire protection program, the NRC was aware
that manual actions were sometimes credited for complying with Section III.G. of Appendix R
at ANO, and that the NRC's failure to challenge the use of all manual actions implied tacit
approval. The issue of whether manual actions were part of the ANO licensing basis is
addressed in Enclosure 2. Entergy further asserted that the unprotected circuits in Fire Zones
98J and 99M interface with systems and equipment necessary for achieving and maintaining
hot shutdown conditions, but are not part of the safe shutdown systems. Therefore, because
these cables are not "necessary," for achieving and maintaining hot shutdown conditions, in
Fire Zones 98J and 99M, Entergy is in compliance with Appendix R,Section III.G.2.
FINDING
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.
Enclosure 2 - Section III.G.2 LiGiEisalinaIVbc.
-21-
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 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, III.J, and III.O."
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:
Enclosure 2 - Section III.G.2 Li&rtsfrE4AsaWtaabslac.
-22-
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; ...'
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.
1"
/
NRC DOCUMENTS
F-Yemntinn ;;nd S;afetv Fvnhiiatinn Rennrt (SFRI dated
22. 1983: The following excerpts
ensee provided concerning their
from the SER are in response to additional Information the
r-n.b-eG fnr
I-
m
rnm
AnriiY
l in
-ra
ir
7 nna 02a
Section IV of the Exemption reads,
-
.
raqwai Ia
Enclosure 2 - Section III.G.2 LIEt
W satioaa4c.
-23-
'The licensee has indicated that enclosure of the corridor A-train conduits in a
one-hour rated fire barrier and separation of the DC equipment room from the
corridor by three-hour rated fire barriers will be provided. With these
modifications, the area will comply with Section III. G of Appendix R, and no
exemption is needed."
Section 8.0 of the SER reads,
.. .The corridor contains primarily E-train cables, however there is one A-train
conduit in the corridor. ... By letter dated November 11, 1982, the licensee
proposed to enclose the single A-train conduit in the corridor in a one-hour rated
barrier."
The level of protection provided for the corridor area and D.C. equipment room
meetsSection III. G; therefore, and exemption is not needed."
SER dated May 13. -1983: This SER contained the NRC's review of the licensee's
methodolog-yfoir alternative safe shutdown in accordance with Appendix R, Sections III.G. 3
and III.G.L.fAs the following excerpts of the SER show, all other fire areas not identified as
altemative-sa7itdown areas were understood by the NRC to reieit the requiremen'ts of III.G.2 of
Appendix R, unless the licensee was granted exemrptions. FIire
idejntified as'altemative shutdown area
"Introduction," of the SER reads,
($9
'By submittals dated July 1 and July 29, 1982, the licensee described the
means by which safe shutdown can be achieved in the event of fire and
proposed modifications to the Arkansas Nuclear One Units 1 and 2 to meet the
requirements of Appendix R to 1O CFR 50, Items III.G.3 and lll.L.
j
Section C. "Remaining Plant Areas," of the SER reads,
"All other areas of the plant not required to have alternate safe shutdown will
comply with the requirements of Section III. G.2 of Appendix R, unless an
exemption request has been approved by the staff"
LICENSEE SUBMITTALS
Licensee letter dated July 1. 1982: As requested by the NRC, Arkansas Power & Light
submitted the results of their Appendix R compliance review by letter dated July 1, 1982.
In Table 1.0 of Section 1 of this submittal, the licensee indicated that an exemption was
needed for Fire Zone 98J, and that modifications were necessary for Fire Zone 99M in order
for these fire zones to comply with Appendix RA.
6.-
In Section 3 of this submittal, describing modifications in Fire Zones 99M, the licensee stated,
1.
For the service water pumps, install breakers outside of zones 100-M and 99-M
so the B service water pump may be powered from either the red or the green
bus. This pump can therefore be assured of power from the unaffected
switchgear room, and be able to isolate from faults in the switchgearroom
l
where the fire bccurs. ... Outside of zones 99M and 100-N, the new service
water pump B circuit breakers will be located in different zones from the pump A I
and pump C cabling.
2.
For the makeup pumps, similarmodifications as those described above for the
service water pumps will be made to assure that a fire in either switchgear room
will not cause loss of all makeup pump capability.
With these modifications this zone will comply with Appendix R.'
In Section 4 of this submittal, regarding exemption details for Fire Zone 98J, the licensee
stated,
-,
'This zone is predominantly of the "greens or EB" safety division, although
certain cables associated with the 'red" or CA" division are also located in the
corridor portion of the zone. The 'A' cables in this zone are routed in conduit
and are predominately associated with the "red' D.C. equipment room."
'The "red' division cabling located in the corridor that is required for safe shutdown will
be wrapped in a 1-hour fire barrier. The circuits involved are the power supplies
to the RS panels [120V ac to vital instrumentation] which are located in the
control room. With the suppression system in this area and the addition of the
1-hour fire barrier, the corridor portion of this zone will comply with Appendix R.
Following modifications described above, this zone sill substantially comply with
Appendix R; however, two exemptions are requested for this zone:
1.
Omission of a complete 3-hour fire barrier separating "redo D. C. equipment room
from the corridor; and
2.
Omission of sprinkler coverage over trays and equipment in the "red D. C.
equipment room."
Licensee letter dated November 11. 1982: As requested by the NRC, Arkansas Power & Light
reviewed other alternatives or modifications which might facilitate appval of certain fire zones
for which the exemution reauests, wer
. ..Z;- __
Enclosure 2 - Section III.G.2 Lfi-t25-lpsaMoab/*c.
-25-
information regarding Fire Zone 98J,
"Modifications to this zone will be made as stated in our July submittal except for
those designed to "separate" the corridor area from the "red" D.C. equipment
room. This separation will be'accomplished by the addition of a 3-hour rated fire
door and fire dampers in the ventilation ducts. . .
With this modification, no
exemptions are required for zone 98J."
Licensee letter dated August 15. 1984: The licensee re-evaluated the configurations in ANO
Units I and 2 for compliance with Appendix R using additional guidance provided in Generic Letter 83-33, and Information Notice (IN) 84-09. With this letter, the licensee submitted their
"Reanalysis Against 1 OCFR50 Appendix R, Sections III.G, J, and O," and clarified the
proposed modifications and exemption requests.is shown below, the licensee stated that
there would be no redundant circuits in Fire Zones 99M after completion of proposed
modifications. The licensee did not identify the use of manual actions for complying with
Appendix R,Section III.G.2 in Fire Zones 98J and 99M.
Regarding Fire Zone 99M, Section 111.1, "Fire Area Analysis," of this reanalysis reads,
....
Zone 99M, after completion of the IR6 modifications mentioned below, will
contain no redundant circuits.
"NECESSARY" FOR SAFE SHUTDOWN
As discussed in Enclosure 2,Section III.G of Appendix R to Part 50 provides three ways of
ensuring that cables or equipment (in the same fire area) of redundant trains of systems
necessary for achieving and maintaining hot shutdown conditions are free of fire damage' If
these conditions cannot be met, then the fire area must meet the alternative or dedicated
shutdown requirements of Section III.G.3 of Appendix R. These requirements are explained in
NRC generic guidance documents, as well as in safety evaluation reports concerning the ANO
Appendix R analysis. During the triennial fire protection inspection atSNO, the inspection
team found numerous cables of redundant trains of systemstnecessarylfor achieving and
maintaining hot shutdown conditons located in the Fire Zones 8J an99M that were not
protected from fire damage in accordance with Section III.G.2 of Appendix R. In addition, the
team found that Fire Zones 98J and 99M did not meet the alternative or dedicated shutdown
requirements of Section III.G.3 of Appendix R. This finding was documented in NRC
Inspection Report 50-313101-06; 50-368101-06 as an unresolved issue pending further NRC
review and determination of safety significance. On August 30, 2001, the NRC informed
Entergy that this finding was a violation of Section III.G.2 of Appendix R to 10 CFR Part 50.
In their letter of September 28, 2001, Entergy asserted that the unprotected circuits in Fire
Zones 98J and 99M interface with systems and equipment necessary for achieving and
maintaining hot shutdown conditions, but are not part of the safe shutdown systems, therefore
are not 'necessary," for achieving and maintaining hot shutdown conditions, in Fire Zones 98J
and 99M. Entergy concluded that, because these cables in and of themselves are not
necessary for achieving and maintaining hot shutdown conditions, then Fire Zones 98J and
99M are in compliance with Appendix R,Section III.G.2, even though manual actions are
I
Enclosure 2 - Section III.G.2 Li~nt-26-s4isalyssc.
-26-
required to overcome the effects of fire d
FIRE ZONES 98J AND 99M COMPLIANCE ANALYSIS CONCLUSION
ouhteNRC was aware that the licensee intended to
use manual actions for meeting Appendix R,Section III.G for 14 fire zones, neither Fire Zone
98J nor 99M were identified on this list.
Regarding the licensee's claim that the cables contained in Fire Zones 98J and 99M are not
"required" for safe shutdown, the panel found that fire damage to certain cables in Fire Zones
98J and 99M could cause maloperation of equipment necessaryfor achieving and maintaining
hot shutdown conditions. Therefore; one train of these cables must be protected from fire
damage by one of the methods specified in Appendix R,Section III.G.2, III.G.3, or an
exemption must be obtained.
T7he panel concluded that the NRC staff
id
not approve of, the
licensee's use of manual actions in the event o
s n ire Zones 98J and 99M. In addition,
the panel concluded that, in Fire Zones 98J and 99M, the licensee does not meet the
requirements of Appendix R, Section 1Il.G;]2i
Entergy Operabons, Inc.
-27-
Enclosure 2 - Section III.G.2 LiEffstawE4BizaWas1sc.
-28-
ENCLOSURE 4
LICENSING BASIS DOCUMENTS REVIEWED
DATE
TYPE
DESCRIPTION
July 1, 1982
Letter to NRC
Results of ANO's Appendix R compliance review
July 29, 1982
Letter to NRC
Results of Appendix R compliance review -
clarifying information
September 3, 1982
Meeting summary
Summary of meeting with ANO on August 31,
1982 concerning alternate shutdown capability
with questions and requests for additional
.________
_
_Information (RAI) attached
September 3,1982
Letter to ANO
RAI concerning alternate shutdown capability
resulting from NRC review of July 1982
Appendix R compliance submittal
October 5, 1982
Letter to NRC
Response to RAI dated September 8, 1982
resulting from NRC review of July 1982
Appendix R compliance submittal
November 11, 1982
Letter to NRC
Response to RAI of September 3, 1982 and
meeting of October 6, 1982, and clarifying
information concerning exemption requests.
March 22, 1983
Letter to ANO
Exemptions from Appendix R and safety
evaluation report (SER) included in the
Exemption by reference
May 13, 1983
Letter to ANO
SER regarding ANO's safe shutdown capability
evaluated against Appendix R, III.G.3 and llI.L
August 15, 1984
Letter to NRC
Reanalysis of Appendix R Compliance and
requests for exemptions from Appendix R, III.G
August 30, 1985
Letter to NRC
Current status of Appendix R modifications and
September 3, 1986
Letter to ANO
RAls on Appendix R exemption requests
October 20, 1986
Letter to NRC
Response to RAI of September 3, 1986. RAI
280.15 and 208116 responses failed to identify
that make-up pump and emergency feedwater
pump cables were located in Fire Zones 98J
April 22,1987
Letter to NRC
Information on exemption for Fire Zone 38Y only
June 24, 1987
Letter to NRC
Information on exemption for Fire Zones 38Y,
34Y and 20Y
September 13,
Inspection Report
Inspection of ANO's implementation of and
1987
compliance to the safe shutdown requirements
of Appendix R
October 26, 1988
Letter to ANO
Exemptions from Appendix R and SER