ML12167A021
| ML12167A021 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/12/2012 |
| From: | Clark R Entergy Operations |
| To: | Kalyanam N Plant Licensing Branch IV |
| Kalyanam N | |
| Shared Package | |
| ML12166A553 | List: |
| References | |
| TAC ME8282 | |
| Download: ML12167A021 (8) | |
Text
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-1 Med 2 In Fire Area HH, a separation ANO will ANO plans to relocate interposing Yes Yes This modification is issue was identified on the EFW modify the relays and affected cables associated specifically credited valves 2CV-1026-2 and control wiring with 2CV-1026-2 and 2CV-1076-2 from a PRA 2CV-1076-2. During a fire for the EFW from Fire Area HH, Fire Zone 2096- perspective.
induced circuit failure the valves by re- M, to the adjacent room in Fire Area Modification reduces feedwater valves may be routing the G, Fire Zone 2098-C. Circuits for the risk in Fire Area HH impacted by a fire in Fire Zone affected cable 2CV-1026-2 and 2CV-1076-2 are of a fire induced circuit 2096-M. or other currently routed through Fire Area G failure for EFW valves LAR Source: modification. and no new impacts will be generated 2CV-1026-2 and 2CV-The final by this modification. 1076-2 in Fire Zone Attachment C (NEI-04-02 method Table B-3) Section for EFW 2096-M.
selected will Valves 2CV-1026-2 and be determined In accordance with 2CV-1076-2 in Fire Area HH during the station directives, Risk Summary project compensatory scoping measures per OP-phase. 1003.014 have been established as appropriate.
S1-2 High 2 In Fire Area JJ, a separation ANO will ANO plans to modify the circuits as Yes Yes This modification is issue was identified that impacts modify the DC described to eliminate impacts in Fire specifically credited the DC power cables control power cables Area JJ associated with these from a PRA wiring on both trains. If a fire by re-routing components. perspective and affects event occurred, this could result and/or 2A-3, 2A-308, 2A-309, and 2A-310 multiple fire areas.
in the loss of equipment that wrapping the The red train 125V DC panel 2D-23 The modification limits would otherwise be available. affected that supplies control power for 2A-3 the risk of a potential Additional considerations are cables or and 2B-5 is planned for relocation to spurious operation and potential spurious operations at other Fire Area MM from Fire Area JJ. a loss of DC power to switchgear 2A-3 that may result modification. Control power cables are planned to safety bus for in a loss of power to the safety The final be routed using embedded conduits switchgear 2A-3 due to bus. method from Fire Area MM to Fire Area II to a fire induced circuit LAR selected will avoid Fire Areas JJ and SS. This failure.
Source: be determined allows post-fire control of 2A-3 bus during the In accordance with Attachment from the control room. station directives, C project scoping 2CV-1036 Auxiliary relays compensatory Switchgear/ (NEI-04-02 2CR1036A, B, C, and D are currently measures per OP-Table B-3) phase.
installed in MCC 2B-61 and are 1003.014 have been EFW Valves VFDR(s) planned to be relocated to MCC 2B- established as 2A-3 JJ-04 63. This would eliminate cables that appropriate.
2A-308 JJ-04 are routed through Fire Area JJ 2A-309 JJ-04 associated with this valve. This eliminates a loss of 2CV-1036-2 due 2A-1 JJ-04 to a fire in Fire Area JJ.
2CV-1036-2 JJ-01 2CV-1075 The reroute of DC 2CV-1075-1 JJ-01 control power to bus 2A-3 and load-2H-1 JJ-03 center 2B-5 listed above assures 2H-2 JJ-03 MCC 2B-53 remains available to Attachment C (NEI 04-02 Table power this valve. An embedded B-3) Fire Area JJ Risk Summary conduit between Fire Area G and II is components: 2A-3, 2A-308, 2A- planned to be used to avoid Fire 309, 2A-310, 2B-6, 2CV-1036-2, Areas JJ, SS, and TT. New 2CV-1075-1, 2CV-4816, and dedicated fuses are planned to be 2CV-4817. installed in 2C-17 for 2CV-1075-1 control relays so that failure of cables in scheme 2S113 will not impact 2CV-1075-1.
2B Cables are planned to be re-routed to control room panel 2C33-2 from 2B-6 using an embedded conduit between Fire Zone 2100-Z to the cable spreading room Fire Area G. This eliminates an impact in Fire Area JJ.
2CV-4816 & 2CV-4817 - A re-route of cable 2I016N is planned by using embedded conduit C4080 that is located between Fire Area G (cable spreading room) to Fire Area EE-L.
Cable 2I016N is also planned to be separately fused in panel C-09 to prevent failure due to a loss of cable 2I016P. This eliminates circuit impacts in Fire Areas TT, JJ, and EE-U.
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-3 High 2 Fire induced circuit failure could ANO will ANO plans to install backup DC Yes Yes This modification is impact DC power cables feeding provide an control power to switchgear 2A-1, 2A- specifically credited circuit breakers at switchgear alternate DC 2, 2H-1 and 2H-2 with automatic from a PRA 2A-1, 2A-2, 2H-1, and 2H-2. power source transfer capability in the event the perspective and affects The failure of 2A-1 and 2A-2 or other normal DC control power source is multiple fire areas.
could prevent alignment to an modification. lost. Modification to install offsite power source. The failure The final The new backup DC power source an alternate DC power of 2H-1 and 2H-2 could prevent method will be located completely within Fire source reduces the risk tripping the reactor coolant selected will Area B-2 in proximity to the of a fire induced circuit pumps (RCPs) from the control be determined switchgear either on elevation 372 or failure to the DC power room. during the below at elevation 354. This cables feeding RCP LAR Source: project eliminates impacts to switchgear DC circuit breakers 2H-1 scoping control power due to a fire in any and 2H-2 which could Attachment phase.
C other ANO-2 fire area and allows prevent tripping the Switchgear (NEI-04-02 tripping of the RCPs in those areas. RCPs from the control Table B-3) Inclusive in this modification will be room.
VFDR(s) changes to the control power circuits In accordance with 2A-1 JJ-04 for switchgear 2H-1 and 2H-2 to allow station directives, tripping the RCPs in a scenario where compensatory 2H-1 JJ-03, MM-04, SS-03 a fire originates internally to a measures per OP-2H-2 JJ-03, MM -04, SS-03 switchgear cubicle. This design will 1003.014 have been Attachment C (NEI-04-02 Table prevent fire damage to a load cubicle established as B-3) Globally credited in the from disabling the ability to trip the appropriate.
performance based Risk line breakers and remove power to Summary for all fire areas. the RCPs. The opposite scenario where fire damages the line breakers would not prevent the RCP load breakers from being tripped. This modification will require the line and load breakers be separately fused and fed as described:
2H-1: Internal DC control wiring jumpers will be removed to isolate the line and load cubicles. The DC control power for line breakers 2H-13, 2H-14, and 2H-15 will be isolated from the DC control power for the load breakers 2H-10, 2H-11, and 2H-12.
2H-2: Internal DC control wiring jumpers will be removed to isolate the line and load cubicles. The DC control power for line breakers 2H-23, 2H-24, and 2H-25 will be isolated from the DC control power for the load breakers 2H-20, 2H-21, and 2H-22.
S1-4 High 2 In Fire Area TT, a separation ANO will ANO plans to modify the circuits as Yes Yes This modification is issue was identified that impacts modify the described to eliminate impacts in Fire specifically credited the power cables for EFW, components Area TT associated with these from a PRA chemical and volume control by either cable components. perspective and affects system (CVCS), and service re-route or 2CV-1036 Auxiliary relays multiple fire areas.
water (SW) components 2B-5, circuit 2CR1036A, B, C, and D are currently The modification 2CV-0789-1, 2CV-1036-2, 2CV- modification. installed in MCC 2B-61 and are reduces the risk of a 1075-1, 2CV-4816, 2CV-4817, The final planned to be relocated to MCC 2B- fire induced circuit and 2P-7B in the fire PRA method 63. This would also eliminate cables failure for model. selected will that are routed through Fire Area TT EFW/CVCS/SW LAR be determined associated with this valve. This components and power Source: during the eliminates a loss of 2CV-1036-2 due cables (2B-5, 2CV-EFW/ Attachment project to a fire in Fire Area TT. 0789-1, 2CV-1036-2, C scoping 2CV-1075-1, phase. 2CV-1075 Cables for this valve CVCS/SW (NEI-04-02 between panels 2C-39 to 2C-17 that 2CV-4816, 2CV-4817, Table B-3) are currently routed through Fire Area and 2P-7B) in Fire Components VFDR(s) TT are planned to be re-routed to Area TT.
2CV-1036-2 TT-01 remain exclusively in the cable In accordance with 2CV-1075-1 TT-01 spreading room. An embedded station directives, conduit between Fire Area G and II is compensatory 2P-7B TT-01 planned to be used to avoid Fire measures per OP-2CV-0789-1 TT-01 Areas JJ, SS, and TT. New 1003.014 have been 2CV-4816 TT-02 dedicated fuses are planned for established as installation in 2C-17 for 2CV-1075-1 appropriate.
2CV-4817 TT-02 control relays so that failure of cables 2B-5 TT-03 in scheme 2S113 will not impact 2CV-Note: This modification is also 1075-1.
discussed in Item S1-2 for Fire 2P-7B - Cables for this pump Area JJ. Modification resolves between panels 2C-39 to 2C-17 that impacts in both fire areas. are currently routed through Fire Area TT are planned to be re-routed to remain exclusively in the cable spreading room. New conduits are also planned to be installed.
2CV-0789 Cables for this valve between panels 2C-39 to 2C-17 that are currently routed through Fire Area TT are planned to be re-routed to remain exclusively in the cable spreading room. An embedded conduit between Fire Area G and II is planned for use to avoid Fire Areas JJ and SS.
2CV-4816 & 2CV-4817 - A re-route of cable 2I016N is planned by using
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization embedded conduit C4080 that goes between Fire Area G (cable spreading room) to Fire Area EE-L.
Cable 2I016N is also planned to be separately fused in panel C-09 to prevent failure due to a loss of cable 2I016P of cable. This eliminates circuit impacts in Fire Areas TT, JJ, and EE-U.
2B Cables for this loadcenter between panels 2C-39 to 2C-33-1 that are currently routed through Fire Area TT are planned to be re-routed to remain exclusively in the cable spreading room.
S1-5 High 2 In Fire Area SS, a fire induced ANO will ANO plans to modify the circuits as Yes Yes This modification is circuit failure could impact the modify the described to eliminate impacts in Fire specifically credited DC power on both trains components Area SS associated with these from a PRA resulting in the loss of the by either cable components. perspective and affects following components. re-route or 2A-3 and 2A-310 The red train 125V multiple fire areas.
LAR tray wrap. DC panel 2D-23 that supplies control The modification Source: The final power for 2A-3 and 2B-5 is planned to reduces the risk of a Attachment method be relocated from Fire Area JJ to Fire fire induced circuit C selected will Area MM. Control power cables are failure that could result Switchgear (NEI-04-02 be determined planned to be routed using embedded in the loss of DC power Table B-3) during the conduits from Fire Area MM to Fire for both trains.
VFDR(s) project Area II to avoid Fire Areas JJ and SS.
scoping In accordance with 2A-3 SS-01 This allows post-fire control of 2A-3 station directives, phase. bus from the control room.
2H-1 SS-03 compensatory 2A-4, 2A-409, & 2B Cables are measures per OP-2H-2 SS-03 planned to be re-routed to control 1003.014 have been Attachment C (NEI-04-02 Table room panel 2C33-2 from 2A-4 and established as B-3) Fire Area SS Risk 2B-6 using an embedded conduit appropriate.
Summary components 2A-4, 2A- between Fire Zone 2100-Z to the 409, 2B-6, 2A-310, 2CV-0789-1, cable spreading room Fire Area G.
2CV-1040-1, 2D-27, 2K-4A, 2P- This eliminates an impact in Fire 16A, 2P-36A, 2PIS-0789-1, Zone 2097-X and Fire Area JJ. The 2SV-0724-1, 2SV-2809-1, 2SV- 125V DC control power from 2D-24 to 2810-1, and 2SV-2811. 2A-4 is planned to be re-routed using a new conduit to avoid an impact against cables G2D2404A and B in Fire Zone 2097-X.
2CV-0789-1 & 2PIS-0789 The power cable for 2PIS-0789-1 (for 2CV-0789-1) is planned to be re-routed using an embedded conduit from Fire Area G to Fire Area II to avoid Fire Area SS.
2CV-1040 This valve is not directly impacted but is failed due to a loss of AC. The red train 125V DC panel 2D-23 that supplies control power for 2A-3 and 2B-5 is planned to be relocated from Fire Area JJ to Fire Area MM. Control power cables are planned to be routed using embedded conduits from Fire Area MM to Fire Area II to avoid Fire Areas JJ and SS.
This assures 2CV-1040-1 will have a source of power and eliminates an impact in Fire Area SS.
2D-27, 2K-4A, 2P-16A, 2P-36A, 2SV-0724-1, 2SV-2809-1, 2SV-2810-1, and 2SV-2811 - The cables associated with these components are planned to be re-routed to avoid Fire Area SS by installing a new raceway in Fire Area B-2 directly under Fire Area SS on elevation 372.
Circuits are planned to be re-routed using the new raceway in Fire Area B-2. The new raceway is planned to be installed above the vertical zone of influence for any postulated fire source. This eliminates impacts for 2D-27, 2K-4A, 2P-16A, 2P-36A, 2SV-0724-1, 2SV-2809-1, 2SV-2810-1, and 2SV-2811 in Fire Area SS.
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-6 Med 2 Motor Operated Valves (MOVs) ANO will ANO plans to modify the control No Yes The NPO modification listed below will be modified to modify the circuit for 2CV-5038-1 to prevent reduces the risk of fire meet requirements per IN 92-18. affected spurious closure. This is planned to induced MOV circuit The NPO assessment valve(s) by be similar to the inhibit circuit failures (hot shorts, determined that any one of the circuit modification on CV-1275 for ANO-1. open circuits and short RCS drop line valves can fail in modification to Procedural controls to secure power to ground). This MOV a closed and unrecoverable prevent failure by opening breakers are planned to modification can position resulting in a loss of in a non- be implemented for 2CV-5084-1 and prevent a non-SDC. recoverable 2CV-5086-2. recoverable position LAR position. The failure resulting in the Source: final method loss of shutdown Attachment selected will cooling.
D be determined In accordance with MOVs (NEI-04-02 during the station directives, Table F-1) project compensatory (IN 92-18) VFDR(s) scoping measures per OP-phase. 1003.014 have been 2CV-5038-1 NPO-RCS-SDC established as 2CV-5084-1 NPO-RCS-SDC appropriate.
2CV-5086-2 NPO-RCS-SDC S1-7 Med 2 MOVs listed below will be ANO will ANO plans to modify 2CV-1075-1 to Yes Yes This modification is modified to meet requirements modify the prevent spurious closing from a fire in specifically credited per IN 92-18. The four EFW affected Fire Area G by installing flexible from a PRA discharge valves and two EFW valve(s) by metallic conduit on conductors 1R perspective.
pump steam supply valves can circuit and 22R of cable scheme 2B53-J2 in The modification fail in a closed and modification to control room cabinets 2C-17 and 2C- reduces the risk of fire unrecoverable position. prevent failure 39. induced MOV circuit LAR Source: in a non- ANO plans to modify 2CV-1076-2 to failures (hot shorts, recoverable prevent spurious closing from a fire in open circuits and short Attachment C (NEI-04-02 Table position. The B-3) Section for EFW MOVs Fire Area G by installing flexible to ground). This MOV final method metallic conduit on conductors 1R, modification can 2CV-1075-1, 2CV-1076-2, 2CV- selected will 1036-2, 2CV-1039-1, 2CV-0340- 22R, 23R of cable scheme 2D-26C1 prevent a non-be determined in control room cabinets 2C-16 and recoverable position 2, and 2CV-0205-2 in Fire Area during the G Risk Summary 2C-40. failure.
project scoping ANO plans to modify 2CV-1036-2 to In accordance with phase. prevent spurious closing from a fire in station directives, Fire Area G by installing flexible compensatory metallic conduit on conductors 22R measures per OP-and 23R of cable scheme 2B-63H1 in 1003.014 have been control room cabinet 2C-40. established as ANO plans to modify 2CV-1039-1 to appropriate.
prevent spurious closing from a fire in Fire Area G by installing flexible metallic conduit on conductors 1R, 22R, 23R of cable scheme 2D-27B2 in control room cabinets 2C-16 and 2C-39.
ANO plans to modify 2CV-0340-2 to prevent spurious closing from a fire in Fire Area G by installing flexible metallic conduit on conductor 1R of cable scheme 2D-26B1 in control room cabinet 2C-16.
ANO plans to modify 2CV-0205-2 to prevent spurious closing from a fire in Fire Area G by installing flexible metallic conduit on conductors 1R and 2R of cable scheme 2D-26C2 in control room cabinets 2C-16 and 2C-18 S1-8 Med 2 In Fire Area B-3, spurious ANO will ANO plans to modify 2CV-4698-1 to Yes Yes This modification is opening of MOV 2CV-4698-1 modify the prevent spurious opening from a fire specifically credited pressurizer low temperature - affected valve in Fire Area B-3 by installing flexible from a PRA overpressure (LTOP) relief can cable by metallic conduit on conductor 1F of perspective.
result from a fire in motor control installing cable R2D27A3J to panel 2D-27.
Cable R2D27A3J enters panel 2D-27 The modification in Fire center (MCC) 2B-53. flexible Area B-3 to install metallic via a floor penetration from cable tray LAR Source: EC152 in Fire Zone 2076-HH. flexible metallic conduit conduit in protects the valve Attachment C (NEI-04-02 Table MCC 2B-53.
B-3) Section for Fire Area B-3 Note: CR-ANO-2-2012-1005 was control cable in MCC The final 2B-53 which reduces Risk Summary method prepared to document the incorrect reference to MCC 2B-53 versus the the risk of fire induced selected will circuit failures (such as be determined correct panel 2D-27.
spurious opening).
during the This modification can project prevent a non-scoping recoverable position phase. failure.
In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-9 Med 2 In Fire Area G, spurious opening ANO will ANO plans to modify 2CV-1002 to Yes Yes This modification is of valves 2CV-1002 (in cabinet modify the prevent spurious opening from a fire specifically credited 2C02), 2CV-1052 (in cabinet affected in the control room by installing from a PRA 2C02), 2CV-0714-1 (in cabinet valves cable flexible metallic conduit on conductor perspective.
2C17), and 2CV-4698-1 (in by installing 1F of cable G2B63A3D in cabinet 2C- The modification in Fire cabinet 2C09) can result from a flexible 02 to 2HS-1002. Cable G2B63A3D Area G to install fire in the control room. metallic enters cabinet 2C-02 via conduit flexible metallic conduit LAR Source: conduit in EC2414 from Fire Zone 2098-L. protects the valves each valves
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization Attachment C (NEI-04-02 Table control panel. ANO plans to modify 2CV-1052 to control cable which B-3) Section for MOVs 2CV- The final prevent spurious opening from a fire reduces the risk of fire 1002, 2CV-1052, 2CV-0714-1, method in the control room by installing induced circuit failures and 2CV-4698-1 in Fire Area G selected will flexible metallic conduit on conductor (such as spurious Risk Summary be determined 1F of cable R2B53D3D in cabinet 2C- opening). This during the 02 to 2HS-1052. Cable R2B53D3D modification can project enters cabinet 2C-02 via conduit prevent a non-scoping EC1389 from Fire Zone 2098-L. recoverable position phase. ANO plans to modify 2CV-0714-1 failure.
(2SV-0714-1) to prevent spurious In accordance with opening from a fire in the control station directives, room by installing flexible metallic compensatory conduit on conductor 14 of cable measures per OP-R2S066E in cabinet 2C-17 to 2HS- 1003.014 have been 0714-1. Cable R2S066E enters established as cabinet 2C-17 via a penetration from appropriate.
cable tray EC169 in Fire Zone 2098-L.
ANO plans to modify 2CV-4698-1 to prevent spurious opening from a fire in the control room by installing flexible metallic conduit on conductor 1F of cable R2D27A3J in cabinet 2C-09 to 2HS-4698-1. Cable R2D27A3J enters cabinet 2C-09-1 via conduit EC1052 from Fire Zone 2098-L.
S1-10 Med 2 In Fire Area B-4 an incipient fire ANO will ANO plans to provide a modification Yes Yes This modification is detection system is not installed provide a for CEDM room cabinets 2C-70, 2C- specifically credited in control element drive modification to 71, 2C-72, 2C-73, 2C-80 and 2C-409 from a PRA mechanism (CEDM) room install incipient that will require an air sampling tubing perspective.
panels 2C70, 2C71, 2C72, detection in entry hole drilled in each cabinet to The early warning fire 2C73, and 2C80. CEDM room gain access to the air sampling port detection system However an early warning fire panels 2C70, connection location inside each modification in Fire detection system in accordance 2C71, 2C72, cabinet. Air sample tubing is planned Area B-4 reduces the with NFPA 72, Fire Alarm 2C73, and to be routed, with supports/hangers, risk of a fire induced Detection Code, is required by 2C80. to meet design requirements. circuit and equipment the PRA in accordance with FRE Sampling ports are planned to be failures that could CALC-09-E-0008-05. monitored by UL listed incipient air result in the loss of sampling detector panels. Within CEDM room panels LAR Source: each detector panel, a UL listed 2C70, 2C71, 2C72, Attachment C (NEI-04-02 Table power supply with battery backup is 2C73, and 2C80.
B-3) Section for CEDM Room planned to be installed.
Panels 2C70, 2C71, 2C72, In accordance with Fire detection signal cable is planned station directives, 2C73, and 2C80 in Fire Area B-4 to be routed from each air sampling Risk Summary compensatory detector panel to the control room fire measures per OP-panel 2C-343-3. 1003.014 have been established as appropriate.
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-11 High 2 At ANO the availability of ANO will ANO plans to install a new Auxiliary Yes Yes The AFW modification feedwater to ANO-2 SGs was provide a Feedwater Pump (AFW) in ANO-1 is specifically credited identified as an issue by PRA. modification to capable of feeding the ANO-2 steam from a PRA assure a generators. perspective to provide Also identified by PRA was ANOs inability to perform high source of a reliable additional AFW to one of The AFW would be designed to meet source of feedwater.
risk and time sensitive actions, or exceed the flow requirements of such as control of auxiliary the SGs. The The local control panel plant change Unit 2 Emergency Feedwater Pump feedwater (AFW), outside of the 2P-7B (380 gpm @ 1100 psig). modification is ANO-2 control room. will resolve specifically credited multiple issues from a PRA LAR Source: for existing The new pump, controls and motor operated valves would be designed to perspective to provide Attachment C (NEI-04-02 Table areas where an alternate means to B-3) Fire Area G Risk Summary EFW is be installed in ANO-1. The preferred source of suction for the new pump is perform required and VFDR G-01 impacted. actions outside the planned to be from Unit 1. The ANO will discharge piping is planned to be ANO-2 control room.
provide a routed through the Unit 1 and Unit 2 This modification modification Turbine Buildings to Unit 2 Auxiliary reduces the risk of not for a local Building Rooms 2081 and 2084 for being able to perform control panel the tie-ins to the EFW System piping. necessary operator to perform The AFW tie-ins are planned to actions to shutdown critical discharge into the Unit 2 Emergency the plant, if either operator Feedwater System (EFW) Control Room cant be actions downstream of all EFW injection manned.
outside the valves. There are no fire impacts to ANO-2 control Also the local control ANO-2. panel modification room. As a minimum, the reduces the risk of The AFW pump would be designed to availability issue with of panel will have the capability to be operated permit control feedwater supply to the from the Unit 2 Control Room and ANO-2 SGs.
of AFW. locally in ANO-1.
Manual actions are credited in fire areas The AFW pump and associated motor that contain redundant operated valves would be designed to safe shutdown be powered by diverse ANO-1 non-equipment. These safety related power sources to actions have been prevent a single failure from disabling demonstrated feasible equipment operation.
and are therefore considered adequate The AFW pump would be designed to compensatory include controls and monitoring measures until instrumentation to ensure proper compliance can be water flow to the steam generators.
achieved by The local controls and monitoring transitioning to a instrumentation are planned to be 10CFR50.48(c) located in ANO-1, powered from licensing basis.
ANO-1 sources and have backup DC power.
S1-12 Low 2 In Fire Area B-3, excessive ANO will ANO plans to modify the control No No This modification temperatures have been modify the wiring for fans 2VEF-63 and 2VEF-64 supports a basic identified in Fire Zone 2091-BB control wiring to isolate control from the control assumption from a following a loss of ventilation. for fans 2VEF- room and allow the local controls to PRA perspective.
LAR Source: 63 and 2VEF- override a stop signal generated 64 to reduce from within Fire Area G, either from Attachment C (NEI-04-02 Table excessive hand-switch positioning or fire-B-3) Fire Area B-3 temperatures induced circuit damage. This in Fire Zone eliminates fire impacts in Fire Area G 2091-BB. The and assures either 2VEF-63 or 2VEF-final method 64 will remain available except for a selected will fire in Fire Area B-3, Fire Zone 2091-be determined BB.
during the project scoping phase.
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-13 Low 2 In Fire Area MM, excessive ANO will ANO plans to provide a modification No No This modification temperatures have been modify fire to fire door DR 265 to allow normally supports a basic identified in Fire Zone 2099-W door DR 265 open positioning with automatic assumption from a following a loss of ventilation. to allow closure features in the event of a fire. PRA perspective.
LAR Source: normally open This allows natural circulation to positioning prevent long term room overheating Attachment C (NEI-04-02 Table with automatic impact on equipment located in Fire B-3) Fire Area MM closure Zone 2099-W, West DC Equipment features in the Room, by allowing an opening to Fire event of a fire. Zone 2109-U, Corridor, in Fire Area The JJ.
modification will open Fire Zone 2099-W to Fire Zone 2109-U in Fire Area JJ allowing natural circulation to reduce post fire temperatures.
The final method selected will be determined during the project scoping phase.
S1-14 Low C With regard to NFPA 50A, ANO will ANO plans to provide a modification No No The subject hydrogen Gaseous Hydrogen Systems, provide a to move the hydrogen bottles and gas system bottle code non-compliance issues modification to manifold outside of the Hydrogen Gas storage area is not were identified in the Hydrogen remove the Bottle Storage Room to a concrete credited by the PRA.
Gas Bottle Storage Room hydrogen slab located outside this room and This modification will related to inadequate vent piping bottles and open to atmosphere. The primary be completed to meet and room ventilation. The manifold advantage of this modification is that NFPA 805 code hydrogen storage room light outside the it removes the potential discharge of requirements.
switch was identified as not room. hydrogen into a confined space. The meeting Article 501 for Class I, new hydrogen pipe is planned to be Division II locations of the buried from manifold location on the National Electric Code (NEC). outside slab and routed to the existing LAR Source: hydrogen piping inside the Hydrogen Gas Bottle Storage Room. This Attachment A (NEI-04-02 Table modification would relocate the B-1) Section 3.3.7.1 manifold and bottles and would include adding a roof over the new outside slab location for weather protection.
S1-15 Med C NFPA 805 non-compliance ANO will ANO plans to provide an adequate- Yes Yes This modification will issues were encountered when provide a for-the-hazard evaluation or a be completed to meet smaller fire areas were defined modification to modification to upgrade fire barrier NFPA 805 code such that multiple walls, upgrade walls, dampers, penetration seals, requirements.
dampers, penetration seals, and multiple walls, and doors to rated barriers for those In accordance with doors were credited and used in dampers, barriers credited for deterministic station directives, the PRA model as rated fire penetration compliance and subsequently compensatory barriers in the NRC regulatory seals, and credited in the Fire PRA analysis. measures per OP-basis for NFPA 805. doors to rated These barriers have been previously 1003.014 have been Multiple walls and doors barriers barriers. identified as NRC regulatory basis to established as will require upgrading to comply These barriers ensure compliance with NFPA 805 appropriate.
with NFPA 805. will be and have compensatory measures identified as established. The barriers to be LAR Source: NRC addressed as identified by EC-1956 Attachment A (NEI-04-02 Table regulatory are 2005-2, 2005-3, 2067-4, 2082-3, B-1) Section 3.11.2 basis to 2091-1, 2091-2, 2091-3, 2091-4, ensure 2107-4, 2110-2, 2110-4, 2110-7, compliance 2112-2, 2112-8, 2112-10, 2133-5, with NFPA 2133-6, 2147-8, 2148-4, 2148-5, 805. These 2149-5, 2152-2, 2154-2, 2154-3, barriers will be 2154-5, 2158-10, 2224-2, 2224-3, upgraded as 2228-10, 2239-4, 2239-5, 2256-4, required. 2256-5, 2256-6, 2256-8, 2134-1 and 2155-1.
Table S-1 Plant Modifications Proposed Amended Proposed Modification In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization S1-16 Low C NFPA 10 non-compliance issues ANO will ANO plans to provide a modification No No The subject fire (such as incorrect number of fire provide a to resolve the NFPA 10 code extinguishers are not extinguishers for travel distance, modification to deficiencies identified in CALC- credited in the Fire incorrect type and size for the install proper ANOC-FP-09-00009. PRA.
hazard area) were identified with number of fire In general, this modification would This modification will ANO portable fire extinguishers. extinguishers involve portable fire extinguisher be completed to meet LAR Source: to meet travel physical relocation, substitution of NFPA 805 code distance existing extinguishers, and requirements.
Attachment A (NEI-04-02 Table requirement in B-1) Section 3.7 documentation updates to reflect coverage these plant changes. The results will areas. ensure the proper number of fire ANO will extinguishers to meet travel distance install requirements in coverage areas, adequately adequately sized fire extinguishers, sized fire and the correct type of extinguisher extinguishers that is rated for the fire hazard in each and correct area.
type that are rated for the fire hazard to meet NFPA 10 requirements.