ML040360411
| ML040360411 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/14/2004 |
| From: | NRC Region 4 |
| To: | |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML040360411 (2) | |
Text
RIV STATUS OF FIRE PROTECTION INSPECTIONS Completed first round of FP Triennial Inspections in 2002 Completed second round of FP Triennials at 3 sites to date (DC, CGS, PV)
Early Focus/Findings (January 2000 - June 2001)
Separation of redundant trains in the same fire area (App R, III.G.2)
Redundant SSD equipment was free of fire damage (App R, III.G.2)
Fire barriers, fire doors, and fire rated penetrations Fire protection features (detection, suppression)
Later Focus/Findings (June 200i to Present, Incorporated Lessons-learned)
Manual actions in lieu of ensuring SSD equipment is free of fire damage (III.G.2)
Alternative shutdown - timing of manual actions Emergency communications Emergency lighting Fire barriers, doors, penetrations Findings in Second Round of Triennials Select less risk significant areas - expect the issues to be of less risk significance URI for manual actions in III.G.2 areas (pending licensing basis review)
URI for ASD timing issues (pending licensee actions)
APV for associated circuits Manual Actions Findings (manual actions In lieu of meeting Il.G.2 requirements)
Early findings were processed as non-compliances using the SDP process.
Later findings were processed iaw IP 71111.05T guidance (Green NCV if manual actions are reasonable and feasible)
Alternative Shutdown Findings (III.G.3)
Findings associated with the ability of operators to perform actions outside the control room within analyzed time constraints.
Findirf~s associated with the timing of ASD
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Findings associated with the adequacy and quality of ASD procedures.
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Associated Circuits/Multiple Hot Shorts/Mechanistic Damage Issues
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EGM 98-006 put these issues on hold For these issues, we have opened 4 URIs and 2 APVs Guidance coming in early Sept for NRC and in Oct for industry and public mechanistic damage and multiple hot shorts issues?
definition of associated circuits vs. required circuits?
Begin inspections using the new guidance early next year?
Compensatory Measures RIV reviews comp measures in place at the time of the inspections.
RIV inspectors perform walkdowns to verify that comp measures are in place, if necessary.
To date no findings of significance have been identified.
The licensee's FPP defines comp measures. Licensee's may change their FPP as long as it doesn't affect their ability to achieve and maintain SSD..
Licensing Basis Difficult and time-consuming for both the licensee and NRC to assemble the licensing basis. SERs not always clear wrt what exactly was reviewed and approved.
Understanding of the LB is time-consuming and sometimes controversial, requiring the region to consult with OGC.
At least one other region saves/files the LB of each plant during the first round, so that this does not need to be performed from scratch during subsequent triennials.
Would like to see Resolution of Heymc issue Definition of adversely affect (re: license condition that states that licensee's may make changes to their FPP as long as they do not adversely affect their ability to achieve and maintain SSD.)
Guidance on licensing basis - particularly if licensee submittals can be considered in determining the LB. Usually they are not listed as part of the FPP in the license condition.