ML121380395
| ML121380395 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/25/2012 |
| From: | Marilyn Evans Division of Operating Reactor Licensing |
| To: | Entergy Operations |
| Kalyanam N, NRR/DORL/LPL4, 415-1480 | |
| References | |
| TAC ME8282 | |
| Download: ML121380395 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 25, 2012 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT 2 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE:
LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME8282)
Dear Sir or Madam:
By letter dated March 27, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12087A113), Entergy Operations, Inc. (Entergy, the licensee),
submitted a license amendment request (LAR) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment would enable Entergy to adopt a new fire protection licensing basis for ANO-2, which complies with the requirements in paragraphs 50.48(a) and (c) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, Entergy would transition the fire protection program to one based on the National Fire Protection Association standard 805 (NFPA 805)
Performance-Based Standard for Fire Protection For Light Water Reactor Generating Plants (2001 Edition) (ADAMS Accession No. ML010800360). Entergy further requested changes to paragraph 3.D of Facility Operating License NPF-6 that describes how the licensee may make changes to its approved fire protection program without prior approval by the U.S. Nuclear Regulatory Commission (NRC).
The purpose of this letter is to provide the results of the NRC staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with 10 CFR 50.90, an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principai safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment.
- 2 In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested in the enclosure by July 11, 2012, to enable the NRC staff to complete its acceptance review. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence. If the supplemental information is not adequate, the application will not be accepted and ANO-2 will lose enforcement discretion.
The information requested and associated time frame in this letter were discussed with Ms. Stephanie Pyle of your staff on May 23,2012.
If Entergy is unable to provide the requested supplemental information by July 11, 2012, the licensee should be aware of the following:
- 1. Entergy may continue the development of the requested supplemental information and may submit the information at a future date. However, in accordance with Section 9.1 of the Enforcement Policy, ANO-2 will lose enforcement discretion on July 11, 2012. In addition, the NRC will conclude that the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the application. Enforcement discretion may be regained when an acceptable LAR is submitted.
- 2. Entergy may, at any time, cease its transition to NFPA 805 and comply with the regulations set forth in 10 CFR Part 50, Appendix R. As indicated in the Enforcement Policy, if Entergy decides not to complete the transition to 10 CFR 50.48(c), it must submit a letter stating its intent to retain its existing licensing basis and withdrawing its letter of intent to comply with 10 CFR 50.48(c).
- 3. Entergy may formally request an extension of enforcement discretion to a date when an acceptable application will be submitted. A request for additional enforcement discretion will be considered to be a withdrawal of the original LAR submittal for ANO-2. This option would require the following:
- a. As soon as possible and prior to July 11, 2012, Entergy would propose a new date, by which it could submit an acceptable application and must provide adequate justification for the delay.
- b. If the justification and proposed date are acceptable to the NRC, Entergy would be required to agree to an Order, which will be effective upon issuance, and to waive its rights to a hearing. The subsequent Confirmatory Order issued by the NRC would extend the submission date and enforcement discretion to the new date. If Entergy fails to meet the new submittal date and fails to comply with its existing licensing basis, the NRC will take appropriate enforcement action consistent with its Enforcement Policy.
- 3 If Entergy chooses to pursue an extension, as described above, the NRC expects that the request will include adequate justification including the following:
- 1.
Schedule of the key transition activities and major milestones for achieving the proposed new date including:
- a.
The preliminary design of specific plant modifications used to reduce site risk;
- b.
Identification of all required NFPA 805 operator recovery actions;
- c.
Identification of all the NFPA 805 recovery action risk; and
- d.
Completion of the subsequent fire risk evaluations, sensitivity analyses, and formulation of the LAR.
- 2.
Transition status should also identify and describe the additional progress that will be made in the following areas between the original ANO-2 LAR submittal date and the proposed new submittal date:
- a.
Classical fire protection transition;
- b.
Nuclear safety performance criteria transition; and
- c.
Defining and installing transition modifications.
Entergy is also requested to ensure the following transition-related information remains available, on-site, for NRC staff review:
- a.
Listing of all fire protection-related noncompliances and the related compensatory measures for those noncompliances;
- b.
Documentation ensuring each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements," dated April 19, 2005 (ADAMS Accession No. ML042360547); and
- c.
A description of the physical modifications performed, if any, to address existing fire protection issues and noncompliances.
- 4 If you have any questions, please contact the Project Manager for ANO-2 at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368
Enclosure:
As stated cc w/encl: Distribution via Listserv
LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 805 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368 By letter dated March 27.2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12087A113). Entergy Operations. Inc. (Entergy. the licensee).
submitted a license amendment request (LAR) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment would enable Entergy to adopt a new fire protection licensing basis for ANO-2, which complies with the requirements in paragraphs 50.48(a) and (c) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically. Entergy would transition the fire protection program to one based on the National Fire Protection Association 805 (NFPA-805)
Performance-Based Standard for Fire Protection For Light Water Reactor Generating Plants (2001 Edition) (ADAMS Accession No. ML010800360). Entergy further requested changes to paragraph 3.0 of Facility Operating License NPF-6 that describes how the licensee may make changes to its approved fire protection program without prior approval by the U.S. Nuclear Regulatory Commission (NRC).
The purpose of this report is to provide the final results of the NRC staffs acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed license change. The acceptance review is intended to identify any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
The NRC staff performed the LAR acceptance review in accordance with Revision 1 of the Office of Nuclear Reactor Regulation (NRR) Office Instruction LlC-109. "Acceptance Review Procedures" Agencywide Document Management System (ADAMS Accession No. ML091810088). The staff subsequently has determined that the licensee has not provided adequate information necessary to complete the comprehensive LAR review to transition ANO-2 to NFPA 805.
The NRC staff's review identified issues where: (1) significant analysis and evaluations are missing, (2) there was significant and obvious problems with the information and analyses provided, and (3) appropriate regulatory guidance was not followed. This informational need was conveyed to Entergy. during phone call on May 1. 2012, followed by this letter. The staff has identified the following information needed to start its technical review.
Technical Acceptance Issues
- 1.
Significant analyses and evaluations are missing from the LAR because the plant modifications described in Appendix S are not developed beyond vague Enclosure
- 2 conceptualizations. Many of the modifications list two or more general modification options and make statements to the effect that "the final [modification)" to achieve compliance "will be determined during the scoping phase". Other modifications are described simply as general complex goals (e.g., "will resolve multiple issues"). Thus, it is apparent that the final plant configuration has not been determined.
The plant modifications need to be developed to the level of detail that can support an independent review of the efficacy of the proposed plant changes (e.g., re-route cables from specific fire areas; controls to be located on, and location of, local control panels; what equipment will be installed; etc.). Furthermore, almost every modification is credited in the probabilistic risk analysis (PRA) and these modifications are relied upon to yield an acceptable change in risk.
Therefore, the modifications for transition need to be described and, as appropriate, modeled in the PRA to properly estimate the change in risk associated with transition.
The LAR needs to be supplemented with the descriptions of these modifications and provide adequate information to review the evaluations supporting these modifications.
- 2.
For a number of fire areas, the LAR lacks the identity of all the required NFPA 805 operator recovery actions (RAs), along with analysis of the associated RA risk. For a number of risk-significant fire areas, risk-informed, performance based alternatives to the deterministic requirements are proposed. NFPA 805, Section 4.2.4, Performance Based Approach, states, in part, that "the additional risk presented by [the use of recovery action] shall be evaluated." In Table W-2 of the LAR, a column for the "Additional Risk of RAs (CDF/LERF [core damage frequencyllarge early release frequency))" is provided.
For some fire areas, a quantitative risk result was provided. However, for about one third of the fire areas, it is reported that "the risk of the recoveries is dominated by the modifications and does not impact the overall delta risk for the area." In addition, Appendix G in the LAR confirms that; "[t]he performance-based evaluations resulted in the need for recovery actions to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth."
Therefore, the LAR needs to be supplemented with all of the quantitative RA risk estimates to demonstrate that the evaluations supporting the transition have been satisfactorily completed.
- 3.
The LAR contains insufficient information to support an unexpected risk estimate in Table W-2. Fire Area G, which includes the main control room (MCR) and other alternative shutdown areas has a relatively high fire-risk contribution. Table W-2 indicates that some Fire Area G variances from deterministic requirements (VFDRs) will remain in place and that RAs are credited for reducing the fire risk in this area. These entries indicate that the total change in risk in Fire Area G is "0.0" and the additional risk from RAs estimate is bounded by "0.0." Attachment G of the LAR states that ANO-2 has no primary control station, besides the MCR, yet only eight RAs are identified for Fire Area G. It is unclear how these few RAs can achieve and maintain a safe and stable state after abandonment of the MCR, and how both the total change in risk and the additional risk from RAs is bounded by a risk estimate of "0.0."
- 3 Therefore, the LAR needs to be supplemented with additional discussion about the planned modifications and RAs, and how these are modeled in the PRA in sufficient detail to explain the unexpected results. This information is needed to demonstrate that the evaluations supporting the requested transition have been satisfactorily completed.
- 4.
Appropriate regulatory guidance was not followed because two sensitivity studies compare the results based on one "unaccepted method" to results based on another "unaccepted method," instead of comparing an "unaccepted method" with an "accepted method." NFPA 805, Section 2.4.3.3, Fire Risk Evaluations, requires, in part, that PRA methods "shall be acceptable to the [NRC]."Section V.2 of the LAR identifies two deviations from the compilation of acceptable methods in NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities" (NUREG-6850),
and provides the results of sensitivity analyses for (1) non-suppression probability for long-term fires and (2) adjustment factor for electrical cabinet ignition frequency. The sensitivity analyses did not use NUREG/CR-6850 methods or methods accepted by the staff in the Frequently Asked Question process.
Therefore, the LAR needs to be supplemented with the risk results calculated using an acceptable analysis method. This information is needed to demonstrate the affect of using the unaccepted method instead of one on the accepted methods.
For the LAR to be acceptable for detailed review, it needs to be supplemented with the technical information identified above.
-4 If you have any questions, please contact the Project Managerfor ANO-2 at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, IRA by Louise Lund forI Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368
Enclosure:
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