ML12310A462

E-mail, Request for Additional Information, Request for Extension of Enforcement Discretion Submittal of License Amendment Request to Transition to National Fire Protection Association (NFPA) 805

ML12310A462
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/05/2012
From:	Kalyanam N Plant Licensing Branch IV
To:	David Bice Entergy Operations
Kalyanam N
References
TAC ME9429
Download: ML12310A462 (4)

Text

From: Kalyanam, Kaly To: BICE, DAVID B

Subject:

RAI regarding the Revision of the Regulatory Commitment relating to the submittal of 10 CFR 50.48(c) LAR (TAC No. ME9429)

Date: Monday, November 05, 2012 3:08:00 PM David Bice:

On November 2, 2005, Entergy (the licensee) notified the U.S. Nuclear Regulatory Commission (NRC) of its intent to transition the Arkansas Nuclear One, Unit 1 (ANO-1) to a risk-informed, performance-based fire protection program in accordance with Section 50.48(c) to Title 10 of the Code of Federal Regulations (10 CFR) (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML053140128).

Under this initiative, the NRC exercised enforcement discretion for most fire protection noncompliances that are identified during the licensee's transition and for certain existing identified noncompliances that would reasonably be resolved at the completion of transition. On June 28, 2011, the licensee committed to submit the ANO-1 LAR by August 31, 2012 (ADAMs Accession No. ML111790756) and the staff approved this new commitment by letter dated July 28, 2011 (ADAMS Accession No. ML112030193). On August 23, 2012, the NRC received a letter from Entergy requesting another extension of enforcement discretion with a new commitment date of August 31, 2013.

Entergy is requesting the staff utilize the regulatory alternative of issuing a Confirmatory Order for the requested extension per SECY-12-0031. Entergy explains the need for the additional time is to correct the deficiencies identified during the nonacceptance of the ANO-2 NFPA 805 LAR (ADAMs Accession No. ML12208A196). Entergy reasoned the lack of resources needed to correct both the Unit 1 and 2 LARs will add to the delay. The ANO-1 LAR has scheduled this effort to incorporate the identified ANO-2 deficiencies by March 1, 2013. The licensee plans to submit the LAR by August 31, 2013.

Consistent with Section 9.1 of the Interim Enforcement Policy, the NRC is requesting Entergy provide additional information, within 30 days of the receipt of this Request for Additional Information (see below), to justify the revised submittal date:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVISION OF THE REGULATORY COMMITMENT RELATING TO THE SUBMITTAL OF 10 CFR 50.48(c) LICENSE AMENDMENT REQUEST FROM ENTERGY OPERATIONS, INC., FOR ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NOS. 50-313 On November 2, 2005, Entergy (the licensee) notified the U.S. Nuclear Regulatory Commission (NRC) of its intent to transition the Arkansas Nuclear One, Unit 1 & 2 (ANO-1,

ANO-2) to a risk-informed, performance-based fire protection program in accordance with Section 50.48(c) to Title 10 of the Code of Federal Regulations (10 CFR) (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML053140128.)

Under this initiative, the NRC exercised enforcement discretion for most fire protection noncompliances that are identified during the licensee's transition and for certain existing identified noncompliances that would reasonably be resolved at the completion of transition. The original 24 month discretion period was extended to 36 months and again until 6 months past the final pilot plant transition, which occurred in December 2010.

Approximately twenty license amendment requests (LARs) were scheduled to be submitted at the end of June of 2011 and due to the complexity of these licensing actions, the Commission approved additional enforcement discretion to stagger the submittals to even out the resources needed for the reviews (SECY-11-0033 & SECY-11-0051).

On June 28, 2011, the licensee committed to submit the ANO-1 LAR by August 31, 2012 (ADAMs Accession No. ML111790756) and the staff approved this new commitment by letter dated July 28, 2011 (ADAMS Accession No. ML112030193.) On August 23, 2012, the NRC received a letter from Entergy requesting an extension of enforcement discretion for ANO-1, with a new commitment date of August 31, 2013. Entergy is requesting the staff utilize the regulatory alternative of issuing a Confirmatory Order per SECY-12-0031.

Entergy explains the need for additional time is to correct deficiencies identified during the nonacceptance of the ANO-2 NFPA 805 LAR (ADAMs Accession No. ML12208A196).

Entergy reasoned the lack of resources needed to correct both LARs will add to the delay.

The request has scheduled to incorporate the identified ANO-2 deficiencies in to the ANO-1 LAR by March 1, 2013 and submit their LAR by August 31, 2013.

Entergy also identified 35 proposed plant modifications (Enclosure 1, Attachment 1) that they are considering to install as part of their NFPA 805 transition. The schedule for completing the scoping for these modification ranges from November of this year to December of next year, (Enclosure 1, Attachment 4). Entergy did not provide any indication that they have installed any modifications to improve fire safety since starting their transition in 2005 and didnt provide a schedule for when these new proposed modifications would be started and completed.

Entergy provided a list of 36 required operator manual actions or Recovery Actions (RAs) associated with initiating fires by fire area (Enclosure 1, Attachment 2.) Thirty-two of these 36 actions are associated with Fire Area G. Actions required from the multi-compartment analysis were considered a low failure probability and not included. The licensees letter notes that even though the ANO-1 LAR is not complete at this time, additional operator actions are not expected to be identified.

Recovery action risk totals (delta CDF & delta LERF), by Fire Area, are provided for 13 areas (Enclosure 1, Attachment 3.) The delta risk for Fire Area G drives the total risk of recovery with over half of the total recovery risk of the site. Recovery action risk was not broken down by RA.

Entergy addressed the completion of subsequent fire risk evaluations (FREs) and sensitivities analyses. These evaluations/analyses are completed and currently under review. The licensee identified that they may have to reevaluate the impacts from the ANO-2 PRA deficiencies on the ANO-1 fire PRA, FREs, and sensitivity analyses.

Consistent with Section 9.1 of the Interim Enforcement Policy, the NRC is requesting that Entergy provide the following additional information to justify the revised submittal date.

Entergy is requested to submit the following:

I). General/Plant Configuration and Modifications For the NRC to evaluate the feasibility of receiving an acceptable LAR, the staff needs assurance that the LAR, as supported by the PRA, will contain the details necessary to evaluate the request fully. Accordingly, the LAR and PRA should include the particular design features of the completed NFPA 805 plant (already incorporated within the models). The staff request that following information:

a. Provide a list of modifications that have been installed that may improve fire safety since starting transition in 2005.

b. Provide a list of known modifications that will be committed to in the LAR.

c. Provide a schedule for inclusion of the known modification into the PRA models.

d. Provide a schedule for installation of the known modifications.

e. Provide an explanation as to how the proposed schedule supports the submission of a complete and acceptable LAR by an additional 12 months.

f. During the October 9, 2012 ANO-2 public meeting, it was discussed that the AFW pump scoping would be completed this year. However, Attachment 4 in the ANO-1 request has the AFW pump scoping completing in September, 2013. Reconcile the difference between the two dates to complete AFW scoping.

II). Key Transition Activities Matrix Entergy provided an NFPA 805 transition project schedule matrix which showed minimal LAR preparation activities and milestone dates, except for some modification scoping and implementation activities. It may be that the licensees LAR preparation is mostly complete; however, the staff needs more detailed breakdown of the LAR preparation activities to justify the additional 12 months of enforcement discretion. Therefore, the staff requests a more detailed matrix of key transition activities which include the current status of these key activities and their scheduled completion dates. At minimum, include the following key transition activities:

a. Classical Fire Protection o NFPA Code Compliance Reviews o Existing Engineering Equivalency Evaluations o Fire Area Licensing Action Reviews

a. Nuclear Safety Capability Assessment o Safe Shutdown Equipment List (SSEL) o Safe Shutdown Circuit Analysis o Fire Area Assessment o Known Transition Modifications

b. Probabilistic Risk Assessment (PRA) o Fire PRA Peer Review o Scoping Fire Modeling o Self-Ignited Cable Fire Scenarios o Circuit Failure Mode/Likelihood Analysis o Main Control Room Analysis o Detailed Fire Modeling

o Focus Scope Peer Review (if needed) o Human Reliability Analysis o Fire Risk Quantification o Revised Fire PRA o Fire Risk Evaluations (FREs)

c. Non-Power Operations o Circuit Analysis o Pinch-Point Analysis

d. Resolution of the three ANO-2 LAR Deficiencies o Deficiency No.1

§ Steps to resolution

§ Steps to inclusion into the PRA

§ Steps to inclusion into the FREs o Deficiency No.2

§ Steps to resolution

§ Steps to inclusion into the PRA

§ Steps to inclusion into the FREs o Deficiency No.3

§ Steps to resolution

§ Steps to inclusion into the PRA

§ Steps to inclusion into the FREs

e. Programmatic o Finalize the ANO-1 LAR o LAR Peer Review o Management Approval If any of these activities are complete, indicate the completion on the matrix.