ML040360551
| ML040360551 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/10/2002 |
| From: | NRC/OE |
| To: | |
| Shared Package | |
| Ml040360400 | List: |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML040360551 (8) | |
Text
SERP Worksheet for SDP-Related Findings IMC 0609 Exhibit 4 of Aft 1 SERP Date: December 10, 2002 Cornerstone Affected and Proposed Preliminary Results:
Initiating Events: OBJECTIVE: to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Attributes:
Design Control: Initial Design and Plant Modifications Protection Against External Factors: Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Switchyard Activities, Grid Stability Configuration Control: Shutdown Equipment Lineup, Operating Equipment lineup, Equipment Performance: Availability, Reliability, Maintenance; Barrier Integrity (SGTR, ISLOCA, LOCA (S,M,L), Refueling/fuel handling equipment Procedure Quality: Procedure Adequacy Human Performance: Human Error Mitigating Systems: OBJECTIVE: to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e.,
core damage).
Attributes:
Design Control: Initial Design and Plant Modifications Protection Against External Factors: Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Seismic Configuration Control: Shutdown Equipment Lineup, Operating Equipment Lineup, Equipment Performance: Availability, Reliability Procedure Quality: Operating (Post Event) Procedure (AOPs, SOPs, EOPs); Maintenance and Testing (Pre-event) Procedures Human Performance: Human Error (Post Event), Human Error (Pre-event)
Licensee: Entergy Operations, Inc.
FacilitvLocation: Arkansas Nuclear One Docket No(s): 50-313 and 50-368 License No: DPR-51, NPF-6 Inspection Report No: 2001-06
I %cao -I- ' *.
.. .* -s j I IL. V1 .A ao I Date of Exit Meeting: August 21, 2001 Issue Sponsor: Dwight Chamberlain Meeting Members:
Issue Sponsor Dwight Chamberlain Technical Spokesperson(s):
Program Spokesperson:
OE Representative: Jennifer Dixon-Herrity A. Brief Description of Issue ANO Unit I 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 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 1R05.3 of Reference 1).
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 necessary to mitigate the effects. Due to the number of components that may be affected as a result of fire and uncertairty regarding the liming and synergistic impact that potential faidures hay have on the operator's ability to accomplish required shutdown functions, the team determined that the strategy for implementing manual actions to mitigate a postulated fire were inadequate (Reference 1).
C. Significance Determination Basis
- 1. Reactor Inspection for IE, MS, B comerstores
- a. Phase 1 screening logic, results and assumptions
- b. Phase 2 Risk Evaluation (when applicable)
Z5 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.)
See Reference 2.
List any confirmatory checks made using licensee risk information, SPAR model results, or-other source of risk insights.
1..
- 2. -ANO Calculaibon95-E-0066-O1, evision 2, "ANO-2 IPEEE P2 Values"
.5 ANO Fire Hazards Analysis
- 6. ANO White Paper-regarding ignition source frequencies
- 9. NRC Memorandum from E. W. Weiss to M. Reinhart, Fire Hazard Analysis for Fire Zone 98J, Emergency Diesel Generator Corridor and Fire Zone 99-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit I (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 9-M, North Electrical Switchgear Room, Arkansas Nuclear One, Unit I (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.
'5
- c. Phase 3 Analysis (if necessary)
Concisely address each of the analysis aspects that follow.
PRA tools used:
I;
Affected sequences:
Influential assumptions:
Sensitivity of results to each influential assumption:
f Contributions of greatest uncertainty factors and impact on assumptions:
s-and
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Previous similar analyses (if applicable): NJA Proposed preliminary or final co )
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-1
- 2. A ion ningsi, comes e Flowchart logic and full justificatip'f atmmnfinne tavarf Proposed preliminary/fina2oLg D. Proposed Enforcement.
L.
- a. Regulatory requirement not net' 10 CFR 50.48, Section (b) and 10 CRPart 50, Appepdix R, Section lll.G.2..
- b. Proposed citation.
During an NRC triennial fire protection inspection conducted on June 11 - 1 S./
2001, at Arkansas Nuclear One, Unit 1, the following violation of NRC ,-
requirements was identified. Note that ANO-1 was licensed prior to January Ii.
1979; therefore, was required to meet 10 CFR Part 50, Appendix R, /
Section III.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 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 11. G, III.J, and /1.O.'
10 CFR Aj Part 50, Appendix R. ParaaraDhIll.G. statest
- 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 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
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conditions were free of fire damage by one of the means spedfed in 10 CFR
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C. Historical precedent. None E. Determination of Fottowup Review (as needed)
For Whte findings propose whether lQs (NRR andlor determination Setter before issuance. (For greater OE) should review final than White findings review and concurence by NRR and OE is required as discussed in Section 4b.)
F. References
- l. 1 NRC Inspection Report 50-313; 368101-06 dated August 20,2001 2 as(MLInteraceAgreement - Request for Risk Determtnation of Fire P rotection
- 2. TkIntergfaeArsa Nular One, Unit i (01TIM l1), ae September 10, 2001 3 (MLOI12530361) IEEP aus ANO Calculation 95-E-O066-01, Revision 2, "ANO-2 IPEEE