1CAN111204, Response to Request for Additional Information Request for Extension of Enforcement Discretion
| ML123210137 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/15/2012 |
| From: | Schwarz C Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 1CAN111204 | |
| Download: ML123210137 (38) | |
Text
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 1CAN111204 November 15, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Response to Request for Additional Information Request for Extension of Enforcement Discretion Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51
References:
- 1. Entergy letter dated August 23, 2012, Request for Extension of Enforcement Discretion, Arkansas Nuclear One - Unit 1 (1CAN081202)
- 2. NRC email dated November 5, 2012, RAI Regarding the Revision of the Regulatory Commitment Relating to the Submittal of 10 CFR 50.48(c) LAR (TAC No. ME9429) (ML12310A462)
- 3. Staff Requirements Memorandum SECY-12-0031, Enforcement Alternatives for Sites that Indicate Additional Time Required to Submit Their License Amendment Requests to Transition to 10 CFR 50.48(c) National Fire Protection Association Standard 805, dated February 24, 2012 (ML12025A349)
Dear Sir or Madam:
By letter dated August 23, 2012 (Reference 1), Entergy Operations, Inc. (Entergy) requested an extension to enforcement discretion related to fire protection issues associated with Renewed Facility Operating License No. DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The original enforcement discretion was based, in part, on submittal of an ANO-1 request to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide 1.205, Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, no later than August 31, 2012. Due to circumstances described in the Reference 1 letter, Entergy has requested an extension of enforcement discretion related to fire protection issues for ANO-1 based, in part, on submitting the aforementioned ANO-1 License Amendment Request (LAR) implementing 10 CFR 50.48(c) prior to August 31, 2013. Per the enforcement discretion policy, once the request is submitted and accepted, the enforcement discretion would then continue until the NRC dispositions the LAR.
1CAN111204 Page 2 of 2 The NRC notified Entergy on November 5, 2012 (Reference 2), of a request for additional information (RAI) necessary to support approval of Entergys request for an extension of enforcement discretion. Enclosure 1 contains Entergys response to the RAI.
Entergy requests the NRC issue a Confirmatory Order approving the requested enforcement discretion extension for ANO-1 as permitted by Reference 3.
This letter contains no new commitments. Should you have any questions concerning this letter, or require additional information, please contact Stephenie Pyle at 479-858-4704.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November 15, 2012.
Sincerely, ORIGINAL SIGNED BY CHRISTOPHER J. SCHWARZ CJS/dbb
Enclosure:
- 1. Response to RAI Regarding the Revision of the Regulatory Commitment Relating to the Submittal of 10 CFR 50.48(c) LAR cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Enclosure 1 to 1CAN111204 Response to RAI Regarding the Revision of the Regulatory Commitment Relating to the Submittal of 10 CFR 50.48(c) LAR to 1CAN111204 Page 1 of 7 Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c)
By email dated November 5, 2012, the NRC notified Entergy Operations, Inc. (Entergy) of a request for additional information (RAI) related to Entergys August 23, 2012, request for an extension of enforcement discretion for fire protection issues for Arkansas Nuclear One, Unit 1 (ANO-1). The questions associated with the RAI are listed below and include the Entergy responses.
- 1) General/Plant Configuration and Modifications
- a. Provide a list of modifications that have been installed that may improve fire safety since starting transition in 2005.
The following is a list of ANO-1 modifications completed. Similar modifications have been completed for ANO, Unit 2 (ANO-2), but are not included below.
Zone 97-R Eliminate makeup tank outlet valve CV-1275 spurious operation Zone 98-J: Eliminate action to manually re-close B512 load center breaker Zone 98-J: Eliminate action to de-energize and close pressurizer electromagnetic relief valve (ERV) isolation Zone 98-J: Eliminate actions to establish emergency diesel generator (EDG) power Zone 99-M: Eliminate action to manually re-close B512 load center breaker Zone 99-M: Eliminate actions to establish EDG power Zone 99-M Eliminate makeup tank outlet valve CV-1275 spurious operation Zone 100-N: Eliminate actions to establish EDG power Zone 112-I: Eliminate action to de-energize and close pressurizer ERV isolation Zone 129-F Eliminate makeup tank outlet valve CV-1275 spurious operation Zone 197-X Eliminate makeup tank outlet valve CV-1275 spurious operation
- b. Provide a list of known modifications that will be committed to in the LAR.
A list of the known modifications that are expected to be committed to in the ANO-1 license amendment request (LAR) is provided in Attachment 1 of this enclosure.
- c. Provide a schedule for inclusion of the known modifications into the PRA models.
The known modifications identified in Attachment 1 of this enclosure are currently included in the ANO-1 Fire probabilistic risk analysis (PRA) model. Updates to the ANO-1 Fire PRA model for any changes associated with modifications will be addressed upon identification. However, additional modifications are not expected to be required.
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- d. Provide a schedule for installation of the known modifications.
Attachment 4 of Entergys August 23, 2012, request for an extension of enforcement discretion provided a scoping schedule for known modifications associated with the ANO-1 transition to NFPA 805. The previous attachment has been modified to include projected design and installation schedules for each modification and is included in Attachment 2 of this enclosure. The schedule, as presented, represents the current assessment of available resources over the expected transition/implementation period and also considers plant operating modes for those modifications that require shutdown conditions for installation. While this schedule is subject to change, the ANO-1 NFPA 805 transition plan is based on completing implementation items as soon as reasonably practical.
- e. Provide an explanation as to how the proposed schedule supports the submission of a complete and acceptable LAR by an additional 12 months.
The ANO-1 LAR is based on the Nuclear Energy Institute (NEI) 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c) template which includes a large main body, 23 attachments, and at least three enclosures. Seven of the attachments, and their related main body sections, lack finalization. As discussed in the aforementioned August 23, 2012, request for enforcement discretion extension, most activities associated with the ANO-1 LAR have been temporarily suspended in order to support resolution of NRC concerns associated with the ANO-2 NFPA 805 LAR. Upon completion of the ANO-2 LAR (currently scheduled to complete by the end of 2012), lessons learned will be incorporated into the ANO-1 LAR and the remaining sections/attachments completed.
This is currently scheduled to complete in the 2nd quarter 2013. Entergy has requested an extension of enforcement discretion to permit the ANO-1 LAR to be submitted no later than August 31, 2013, in order to accommodate potential unforeseen circumstances that could delay completing the ANO-1 LAR in the 2nd quarter 2013.
These circumstances may include:
- Spring 2013 ANO-1 refueling outage
- Delay of the ANO-2 NFPA 805 LAR submittal
- New NRC concerns or industry issues associated with NFPA 805 submittals
- Preparation for NFPA 805 audit of ANO-2, which is expected to occur in the 2nd quarter 2013 following the ANO-1 refueling outage
- Resources needed to support potential ANO-2 NFPA 805 related NRC RAI
- Other significant emergent site issues that could require support from the ANO NFPA 805 resource team Following submittal of the ANO-2 LAR, the focus will shift to completing the ANO-1 LAR. The response to RAI 2 below presents additional detailed information regarding the schedule for completing the ANO-1 LAR, absent unforeseen circumstances described above. Based on this assessment, Entergy believes the requested ANO-1 LAR submittal date of August 31, 2013, will provide sufficient margin to accommodate LAR completion considering the potential unforeseen circumstances described above.
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- 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.
The auxiliary feedwater (AFW) pump scoping activities were originally scheduled in series since the same design engineering team would be required to support both unit modifications. The design engineering team is also responsible for supporting other NFPA 805 modifications. Significant progress has been made with respect to the ANO-2 AFW pump scoping effort. During this effort, efficiencies have been realized that partially support upcoming ANO-1 AFW pump scoping efforts. Based on this overlap, the ANO-1 AFW pump scoping effort is currently scheduled to complete near the end of the 1st quarter 2013 (see Attachment 2 of this enclosure).
- 2) 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 Code compliance reviews are complete.
o Existing Engineering Equivalency Evaluations (EEEEs)
EEEEs have been compiled and are complete.
o Fire Area Licensing Action Reviews Licensing Actions reviews are complete.
- b. Nuclear Safety Capability Assessment o Safe Shutdown Equipment List (SSEL)
The SSEL was established by CALC-85-E-0087-23, Safe Shutdown Equipment List (SSEL) Methodology, in 2005 and loaded into the Plant Data Management System in support of deterministic compliance for Appendix R. Additional equipment has been added on an as needed basis to support the Fire PRA. This activity is complete.
to 1CAN111204 Page 4 of 7 o Safe Shutdown Circuit Analysis Safe shutdown cable analysis was established by CALC-85-E-0087-24, Safe Shutdown Cable Analysis, in 2005 and loaded into the Plant Data Management System in support of deterministic compliance for Appendix R. Additional analysis has been performed on an as needed basis to support the Fire PRA. This activity is complete.
o Fire Area Assessment Fire Area assessments are complete pending final data from the Fire PRA affecting fire area risk.
o Known Transition Modifications Thirty-five (35) modifications have been identified as provided in Attachment 1 of this enclosure. Modifications that support the deterministic and Fire PRA issues have been identified and design scoping is underway on many. Future ANO-1 NFPA 805 outage related modifications have been segregated into a red train or green train outage based on the train most impacted.
- c. Probabilistic Risk Assessment (PRA) o Fire PRA Peer Review The Fire PRA Peer Review has been completed and results incorporated into draft version of LAR Attachment V.
o Scoping Fire Modeling A draft of LAR Attachment J has been prepared and will be revised, if necessary, following completion of the overall Fire PRA activity.
o Self-Ignited Cable Fire Scenarios This concern does not apply at ANO-1 because the electrical cable insulation is IEEE 383 equivalent such that this scenario is not credible.
o Circuit Failure Mode/Likelihood Analysis This portion of the project has been completed, which permits development of the Fire PRA model with respect to failures.
o Main Control Room Analysis A revision to the Control Room Analysis is pending completion of the ANO-2 Control Room Analysis. The ANO-1 analysis will be revised to reflect the issues and concerns discussed during the October 9, 2012, public meeting relating to the status of the ANO-2 non-acceptance items. This activity is scheduled to complete in the 1st quarter 2013.
o Detailed Fire Modeling Most of the detailed fire modeling effort for ANO-1 has been completed. This activity is scheduled to complete in the 1st quarter 2013.
to 1CAN111204 Page 5 of 7 o Focus Scope Peer Review (if needed)
A focused scope peer review has been performed and documentation is near completion. Any findings from the peer review will be documented in LAR Attachment V along with the disposition of any findings. This activity is scheduled to complete in the 1st quarter 2013.
o Human Reliability Analysis The Human Reliability Analysis (HRA) for ANO-1 operator actions has been completed for all new operator actions. This effort is considered complete, pending no new operator actions are identified as the Control Room Analysis is completed.
o Fire Risk Quantification The Fire Risk Quantification for all fire scenarios is in progress and nearing completion, with the exception of the Control Room Analysis. The Control Room scenarios will be completed following submittal of the ANO-2 LAR and will incorporate the insights gained from the ANO-2 analysis. The overall results will be quantified upon completion of the Control Room Analysis and incorporated into the Summary Report. This activity is scheduled to complete in the 1st quarter 2013.
o Revised Fire PRA Multiple Spurious Operations (MSOs), proposed modifications, and operator actions have been incorporated into the Fire PRA model and the model has been used for quantification of the delta risk for most Fire Areas. Additional changes to the Fire PRA model may be required to address changes to proposed modifications or new recovery actions, however, it is expected that any additional changes would be minor. This activity is scheduled to complete in the 1st quarter 2013.
o Fire Risk Evaluations (FREs)
All FREs, with the exception of the Control Room Analysis, have been drafted.
Final revisions to the FREs are in progress and are expected to be completed soon after submittal of the ANO-2 LAR. The FRE for the Control Room Analysis will require significant effort and is currently scheduled to complete near the end of the 1st quarter 2013.
o Pinch-Point Analysis Pinch-Point analysis was the method used for determining impacts on NPO key safety functions. This activity is complete.
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- e. Resolution of the three ANO-2 LAR Deficiencies o Deficiency No. 1 Steps to resolution The insights gained from the ANO-2 LAR deficiencies and the October 9, 2012, public meeting are being evaluated to ensure that the ANO-1 transition risk analysis is completed in accordance with the lessons learned. This activity is scheduled to complete in the 1st quarter 2013.
Steps to inclusion into the PRA It is unlikely the Fire PRA model will require revision to address the issues identified in this deficiency. However, in order to address the deficiency identified, the scenarios for the compliant transition case will be reviewed and revised as necessary. This activity is scheduled to complete in the 1st quarter 2013.
Steps to inclusion into the FREs The FRE for the transition risk will be developed in a manner to document the process used and the results obtained from the quantifications. This activity is scheduled to complete near the end of the 1st quarter 2013.
o Deficiency No. 2 Steps to resolution The unapproved methods identified in the ANO-2 LAR submittal have been removed and the ANO-1 analysis performed in a manner that is in accordance with approved methods. This activity is complete.
Steps to inclusion into the PRA ANO-1 has revised the analysis to remove all unapproved methods and has included the Multi-Compartment Analysis / Hot Gas Layer (MCA/HGL) analysis in the core damage frequency / large early release frequency (CDF/LERF) results. The CDF/LERF results remain acceptable in relation to the risk acceptance criteria. This activity is complete.
Steps to inclusion into the FREs The process utilized, along with the results, will be documented in the FREs.
This activity is scheduled to complete near the end of the 1st quarter 2013.
o Deficiency No. 3 Steps to resolution The methods used in finalizing the ANO-1 analysis will identify any additional modifications or operator actions required to ensure acceptable risk results.
This activity is scheduled to complete in the 1st quarter 2013.
to 1CAN111204 Page 7 of 7 Steps to inclusion into the PRA The process used will be similar to that previously used in ensuring that any plant changes required to minimize risk are documented, properly included in the PRA model, and incorporated into the results. This activity is scheduled to complete in the 1st quarter 2013.
Steps to inclusion into the FREs All modifications and operator actions that are required for acceptable delta risk results will be documented in the appropriate FRE. This activity is scheduled to complete near the end of the 1st quarter 2013.
- f. Programmatic o Finalize the ANO-1 LAR As noted above, all preparation activities are scheduled to complete by the end of the 1st quarter 2013. Final reviews and verifications are scheduled to complete in the 2nd quarter 2013 with submittal of the LAR to follow immediately thereafter.
o LAR Peer Review Because both ANO units are unique with regard to plant configuration, there are no industry experts available to support a peer review. This was identified during ANO public meetings held with the NRC staff following submittal of the enforcement extension request; therefore, Entergy believes this item is no longer applicable. In addition, Entergy maintains contract staff to perform LAR reviews against the NEI template and other NFPA 805 LARs submitted by the industry.
Based on the numerous public meetings and reviews already ongoing, Entergy is confident a quality LAR will be submitted without need for additional peer review.
o Management Approval The plant management approval is an on-going process that is systematically performed throughout the ANO-1 LAR development process. Final signature and approval will be obtained immediately following the aforementioned verifications. of this enclosure provides a table of the above LAR preparation activities.
Note that Entergys August 23, 2012, request for an extension of enforcement discretion also included a list of NFPA 805 operator recovery actions and the associated recovery action risk (Attachments 2 and 3 of the August 23, 2012, letter, respectively). Enclosure 2 of Entergys August 23, 2012, letter contains the commitment for submittal of the ANO-1 NFPA 805 LAR by August 31, 2013.
Attachments
- 1. ANO-1 NFPA 805 Modifications
- 2. ANO-1 NFPA 805 Modifications Design and Installation Schedule
Attachment 1 ANO-1 NFPA 805 Modifications
, Attachment 1 1CAN111204 Page 1 of 21 S. Plant Modifications to be Completed During Implementation Table S-1, Plant Modifications, provided below includes a description of the modifications along with the following information:
A problem statement, Risk ranking of the modification, An indication if the modification is currently included in the FPRA, Compensatory measure in place, and A risk-informed characterization of the modification and compensatory measure.
The following ranking legend should be used when reviewing the table:
High = Modification which would have an impact on FPRA and affect multiple Fire Areas.
Med = Modification which would have an impact on FPRA and affect individual Fire Areas, or include IN 92-18 modifications.
Low = Modification which would have no or insignificant impact on risk.
, Attachment 1 1CAN111204 Page 2 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-1 High 1 New Auxiliary Feedwater (AFW) pump: ANO plans to install a new Yes Yes This AFW modification is credited (PRA) AFW pump with controls globally from a PRA perspective to Due to multiple impacts to the independent of the existing provide a reliable additional source Emergency Feedwater (EFW) system, EFW pumps. The AFW will be of feedwater.
the need for an additional source of capable of feeding one of the feedwater to the Steam Generators ANO-1 SGs. The new AFW The local control panel modification (SGs) was identified. pump would be designed to is also specifically credited from a meet or exceed the flow PRA perspective to provide an The availability of feedwater to SGs alternate means to perform was identified as an issue by PRA. requirements of the ANO-1 EFW pump P-7B (nominally required actions outside the ANO-1 Also identified by PRA was ANOs Control Room.
inability to perform high risk and time 500 gpm @ 1050 psig).
sensitive actions, such as control of The new AFW pump would be Manual actions are credited in fire AFW, outside of the Control Room. designed with the capability to areas that contain redundant safe be operated from the ANO-1 shutdown equipment. The LAR Source: modification process will ensure Control Room and locally at Attachment C (NEI-04-02 Table B-3) the pump. The design will these actions are feasible.
ensure electrical isolation from Control Room functions to prevent a fire in the Control Room from affecting local control of AFW components.
The new AFW pump and associated motor operated valves would be designed to be powered by diverse power sources to prevent a single exposure fire from disabling equipment operation. The new AFW pump would be designed to include local controls and monitoring instrumentation to ensure proper operation and water flow to the SG.
, Attachment 1 1CAN111204 Page 3 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-2 High 1 Switchgear A-1: ANO plans a modification to Yes Yes This modification is credited (PRA) install a redundant DC control globally from a PRA perspective In multiple Fire Areas, PRA determined power supply to switchgear and affects multiple fire areas.
that backup DC control power supply to A-1 to eliminate loss of switchgear A-1 will be installed to switchgear due to loss of Modification to install an alternate eliminate loss of switchgear A-1 due to normal DC control power. DC power source reduces the risk loss of normal DC control power. of a fire induced circuit failure to In the event the normal DC the DC power cables feeding A-1 LAR Source: control power source is lost, a which could preclude loss of offsite transfer to this alternate DC power.
Attachment C (NEI-04-02 Table B-3) power source can be performed. In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-3 High 1 Switchgear A-2: ANO plans a modification to Yes Yes This modification is credited (PRA) install a redundant DC control globally from a PRA perspective In multiple Fire Areas, PRA determined power supply to switchgear and affects multiple fire areas.
that backup DC control power supply to A-2 to eliminate loss of switchgear A-2 will be installed to switchgear due to loss of Modification to install an alternate eliminate loss of switchgear A-2 due to normal DC control power. DC power source reduces the risk loss of normal DC control power. of a fire induced circuit failure to In the event the normal DC the DC power cables feeding A-2 LAR Source: control power source is lost, a which could preclude loss of offsite Attachment C (NEI-04-02 Table B-3) transfer to this alternate DC power.
power source can be performed. In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 4 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 Med 1 Switchgear A-3: ANO plans a modification to Yes Yes This modification is specifically (PRA) reroute the DC control power credited for Fire Area I-2.
In Fire Area I-2, PRA determined that to eliminate Fire Area I-2 rerouting the DC control power to A-3 impact. Modification to reroute the DC was necessary to maintain control power source for A-3 reduces the functions for P-36A, P-7B, P-4A and risk of a fire induced circuit failure P-4B(R). of the switchgear and the possible loss of control functions to pumps LAR Source: P-36A, P-7B, P-4A and P-4B(R).
Attachment C (NEI-04-02 Table B-3) In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-5 High 1 Switchgear H-1: ANO plans a modification to Yes Yes The modification to install a (PRA) install a redundant DC control redundant DC control power supply In multiple Fire Areas, PRA determined power supply to switchgear is credited globally from a PRA that existing DC control power supply to H-1 to eliminate loss of perspective and affects multiple fire switchgear H-1 should be modified to switchgear due to loss of areas.
eliminate loss of switchgear H-1 due to normal DC control power.
loss of normal DC control power. The modification to separate line In the event the normal DC and load breaker control power is This failure could preclude the Reactor control power source is lost, a only credited in B-1@BOFZ.
Coolant Pumps (RCPs) from being transfer to this alternate DC tripped in the control room. power source can be Both modifications reduce the risk performed. of a fire induced circuit failure to LAR Source: the DC power cables feeding Attachment C (NEI-04-02 Table B-3) Additionally, ANO plans a switchgear H-1 which could modification to remove internal preclude tripping the RCPs from DC jumpers and separately the control room.
protect H-1 switchgear line and load breaker control In accordance with station power. This will prevent a fire directives, compensatory originating in a cubicle from measures per OP-1003.014 have disabling the ability to trip the been established as appropriate.
RCPs due to loss of shared control power.
, Attachment 1 1CAN111204 Page 5 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-6 High 1 Switchgear H-2: ANO plans a modification to Yes Yes The modification to install a (PRA) install a redundant DC control redundant DC control power supply In multiple Fire Areas, PRA determined power supply to switchgear is credited globally from a PRA that existing DC control power supply to H-2 to eliminate loss of perspective and affects multiple fire switchgear H-2 should be modified to switchgear due to loss of areas.
eliminate loss of switchgear H-2 due to normal DC control power.
loss of normal DC control power. The modification to separate line In the event the normal DC and load breaker control power is This failure could preclude the RCPs control power source is lost, a only credited in B-1@BOFZ.
from being tripped in the control room. transfer to this alternate DC power source can be Both modifications reduce the risk LAR Source: of a fire induced circuit failure to performed.
Attachment C (NEI-04-02 Table B-3) the DC power cables feeding Additionally, ANO plans a switchgear H-2 which could modification to remove internal preclude tripping the RCPs from DC jumpers and separately the control room.
protect H-2 switchgear line and load breaker control In accordance with station power. This will prevent a fire directives, compensatory originating in a cubicle from measures per OP-1003.014 have disabling the ability to trip the been established as appropriate.
RCPs due to loss of shared control power.
, Attachment 1 1CAN111204 Page 6 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-7 Med 1 A-309, 4160V AC Breaker: ANO plans to install a circuit Yes Yes This modification is specifically (PRA) modification to protect the credited from a PRA perspective.
In Fire Area B-1@BOFZ, PRA identified circuits associated with that a fire induced fault in the turbine breaker A-309 such that, a fire Modification to the circuits building could result in spurious closing in the turbine building will not associated with breaker A-309 is or preclude automatic trip functions at result in spurious closing, or planned such that a fire in the A-309 (vital switchgear A-3 supply preclude automatic trip turbine building will not result in breaker from switchgear A-1), when functions challenging the spurious closing or preclude loading the credited Emergency Diesel supply when loading the EDG automatic trip functions when Generator (EDG). (A-308). loading the credited EDG (A-308) in Fire Area B-1@BOFZ.
LAR Source: This modification will re-route cables, wrap cables or modify In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory circuits for breaker A-309 to assure the protective features measures per OP-1000.120 have remain intact; breakers remain been established as appropriate.
tripped, and do not impede automatic start of the associated EDG and closure of EDG breaker A-308.
, Attachment 1 1CAN111204 Page 7 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-8 Med 1 A-409, 4160V AC Breaker: ANO plans to install a circuit Yes Yes This modification is specifically (PRA) modification to protect the credited from a PRA perspective.
In Fire Area B-1@BOFZ, PRA identified circuits associated with that a fire induced fault in the turbine breaker A-409 such that a fire Modification to the circuits building could result in spurious closing in the turbine building will not associated with breaker A-409 is or preclude automatic trip functions at result in spurious closing or planned such that a fire in the A-409 (vital switchgear A-4 supply preclude automatic trip turbine building will not result in breaker from switchgear A-2), when functions challenging the spurious closing or preclude loading the credited EDG. supply when loading the EDG automatic trip functions when (A-408). loading the credited EDG (A-408)
LAR Source: in Fire Area B-1@BOFZ.
Attachment C (NEI-04-02 Table B-3) This modification will re-route cables, wrap cables or modify In accordance with station circuits for breaker A-409 to directives, compensatory assure the protective features measures per OP-1000.120 have remain intact; breakers remain been established as appropriate.
tripped, and do not impede automatic start of the associated EDG and closure of EDG breaker A-408.
, Attachment 1 1CAN111204 Page 8 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-9 Med 1 Control Room Panel C20: ANO plans to provide a Yes Yes This modification is specifically (PRA) modification to install an credited from a PRA perspective.
In Fire Area G, Fire Zone 129F, PRA incipient very early warning determined that in order to reduce risk ASD detector in ANO-1 The modification to install an of a fire induced circuit and equipment Control Room Panel C20. incipient very early warning ASD failure in Control Room Panel C20, an detector in ANO-1 Control Room incipient very early warning aspirating The modification to install an Panel C20 in Fire Area G, Fire smoke detector (ASD) is required to be incipient early warning fire Zone 129F, reduces the risk of a installed in Panel C20. detection system is planned to fire induced circuit and equipment be in accordance with the failure that could result in the loss LAR Source: latest edition of NFPA 72, Fire of Control Room Panel C20.
Attachment C (NEI-04-02 Table B-3) Alarm Detection Code and NFPA 76, Standard for the In accordance with station Fire Protection of directives, compensatory Telecommunications Facilities. measures per OP-1003.014 have The incipient fire detection been established as appropriate.
system is required to meet FAQ 08-0046, Incipient Fire Detection System requirements.
S1-10 Med 1 Air Operated Valve (AOV) CV-1052: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-1052 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Quench Tank Drain valve CV-1052 should be modified to preclude spurious This modification adds an This modification reduces the risk operation. CV-1052 does not have inhibit circuit which will of fire induced AOV circuit failures automatic features via interlocks to preclude spurious opening of (hot shorts, open circuits and short preclude spurious operation to reduce the AOV due to intercable or to ground). This AOV modification overall plant risk as a result of a fire intracable hot shorts. can preclude spurious operation to induced circuit failure. reduce plant risk in Fire Area G as a result of a fire induced circuit LAR Source: failure.
Attachment C (NEI-04-02 Table B-3) In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 9 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-11 Med 1 Motor Operated Valve (MOV) CV-1053: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-1053 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Quench Tank Drain valve CV-1053 should be modified to preclude spurious This modification adds an This modification reduces the risk operation. CV-1053 does not have inhibit circuit which will of fire induced MOV hot short automatic features via interlocks to preclude spurious opening of circuit failure. This MOV preclude spurious operation to reduce the MOV due to intercable or modification will preclude spurious overall plant risk as a result of a fire intracable hot shorts. operation to reduce plant risk in induced circuit failure. Fire Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-12 High 1 MOV CV-1221: ANO plans a modification for Yes Yes The modification reduces the risk (PRA) CV-1221 to meet requirements of fire induced MOV hot short PRA determined that Letdown isolation per IN 92-18. circuit failure in accordance with valve CV-1221 should be modified to IN 92-18. This MOV modification meet requirements per IN 92-18. This modification adds an will preclude spurious operation to CV-1221 does not have automatic inhibit circuit which will reduce plant risk as a result of a features via interlocks to preclude preclude spurious opening of fire induced hot short circuit failure.
spurious operation to reduce overall the MOV due to intercable or In accordance with station plant risk as a result of a fire induced intracable hot shorts. directives, compensatory circuit failure. measures per OP-1003.014 have LAR Source: been established as appropriate.
Attachment C (NEI-04-02 Table B-3)
, Attachment 1 1CAN111204 Page 10 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-13 High 1 MOV CV-1405: ANO plans a modification for Yes Yes This modification is credited (PRA) CV-1405 to meet requirements globally from a PRA perspective In multiple Fire Areas, PRA determined per IN 92-18. and affects multiple fire areas.
that Train A Emergency Core Cooling (ECCS) Reactor Building sump suction This modification adds an This modification reduces the risk valve CV-1405 should be modified to inhibit circuit which will of fire induced MOV hot short meet requirements per IN 92-18. preclude spurious opening of circuit failure in accordance with CV-1405 does not have automatic the MOV due to intercable or IN 92-18. This MOV modification features via interlocks to preclude intracable hot shorts. will preclude spurious operation to spurious operation to reduce overall reduce overall plant risk as a result plant risk as a result of a fire induced of a fire induced hot short circuit circuit failure. failure.
LAR Source: In accordance with station directives, compensatory Attachment C (NEI-04-02 Table B-3) measures per OP-1003.014 have been established as appropriate.
S1-14 High 1 MOV CV-1406: ANO plans a modification for Yes Yes This modification is credited (PRA) CV-1406 to meet requirements globally from a PRA perspective In multiple Fire Areas, PRA determined per IN 92-18. and affects multiple fire areas.
that Train B Emergency Core Cooling (ECCS) Reactor Building sump suction This modification adds an This modification reduces the risk valve CV-1406 should be modified to inhibit circuit which will of fire induced MOV hot short meet requirements per IN 92-18. preclude spurious opening of circuit failure in accordance with CV-1406 does not have automatic the MOV due to intercable or IN 92-18. This MOV modification features via interlocks to preclude intracable hot shorts. will preclude spurious operation to spurious operation to reduce overall reduce overall plant risk as a result plant risk as a result of a fire induced of a fire induced hot short circuit circuit failure. failure.
LAR Source: In accordance with station directives, compensatory Attachment C (NEI-04-02 Table B-3) measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 11 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-15 High 1 MOV CV-3643: ANO plans a modification for Yes Yes This modification reduces the risk (PRA) CV-3643 to meet requirements of fire induced MOV hot short PRA determined that Service Water per IN 92-18. circuit failure in accordance with (SW) Auxiliary Cooling Water (ACW) IN 92-18. This MOV modification supply valve CV-3643 should be This modification adds an will preclude spurious operation to modified to meet requirements per inhibit circuit which will reduce overall plant risk as a result IN 92-18. CV-3643 does not have preclude spurious opening of of a fire induced hot short circuit automatic features via interlocks to the MOV due to intercable or failure.
preclude spurious operation to reduce intracable hot shorts.
overall plant risk as a result of a fire In accordance with station induced circuit failure. directives, compensatory measures per OP-1003.014 have LAR Source: been established as appropriate.
Attachment C (NEI-04-02 Table B-3)
S1-16 Med 1 AOV CV-4400: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-4400 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building sump drain valve CV-4400 should be modified to This modification adds an This modification reduces the risk preclude spurious operation. CV-4400 inhibit circuit which will of fire induced AOV hot short does not have automatic features via preclude spurious opening of circuit failure. This AOV interlocks to preclude spurious the AOV due to intercable or modification will preclude spurious operation to reduce overall plant risk as intracable hot shorts. operation to reduce plant risk in a result of a fire induced circuit failure. Fire Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 12 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-17 Med 1 MOV CV-4446: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-4446 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building sump drain valve CV-4446 should be modified to This modification adds an This modification reduces the risk preclude spurious operation. CV-4446 inhibit circuit which will of fire induced MOV circuit failures does not have automatic features via preclude spurious opening of (hot shorts, open circuits and short interlocks to preclude spurious the MOV due to intercable or to ground). This MOV modification operation to reduce overall plant risk as intracable hot shorts. can preclude spurious operation to a result of a fire induced circuit failure. reduce plant risk in Fire Area G as a result of a fire induced circuit LAR Source: failure.
Attachment C (NEI-04-02 Table B-3) In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-18 Med 1 MOV CV-5611: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-5611 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building firewater valve CV-5611 should be modified to This modification adds an This modification reduces the risk preclude spurious operation. CV-5611 inhibit circuit which will of fire induced MOV hot short does not have automatic features via preclude spurious opening of circuit failure. This MOV interlocks to preclude spurious the MOV due to intercable or modification will preclude spurious operation to reduce overall plant risk as intracable hot shorts. operation to reduce plant risk in a result of a fire induced circuit failure. Fire Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 13 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-19 Med 1 MOV CV-5612: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-5612 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building firewater valve CV-5612 should be modified to This modification adds an This modification reduces the risk preclude spurious operation. CV-5612 inhibit circuit which will of fire induced MOV hot short does not have automatic features via preclude spurious opening of circuit failure. This MOV interlocks to preclude spurious the MOV due to intercable or modification will preclude spurious operation to reduce overall plant risk as intracable hot shorts. operation to reduce plant risk Fire a result of a fire induced circuit failure. Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-20 Med 1 AOV CV-7401: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-7401 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building purge valve CV-7401 should be modified to preclude spurious This modification adds an This modification reduces the risk operation. CV-7401 does not have inhibit circuit which will of fire induced AOV hot short automatic features via interlocks to preclude spurious opening of circuit failure. This AOV preclude spurious operation to reduce the AOV due to intercable or modification will preclude spurious overall plant risk as a result of a fire intracable hot shorts. operation to reduce plant risk in induced circuit failure. Fire Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 14 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-21 Med 1 AOV CV-7402: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-7402 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building purge valve CV-7402 should be modified to preclude spurious This modification adds an This modification reduces the risk operation. CV-7402 does not have inhibit circuit which will of fire induced AOV hot short automatic features via interlocks to preclude spurious opening of circuit failure. This AOV preclude spurious operation to reduce the AOV due to intercable or modification will preclude spurious overall plant risk as a result of a fire intracable hot shorts. operation to reduce plant risk in induced circuit failure. Fire Area G as a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-22 Med 1 AOV CV-7403: ANO plans a modification for Yes Yes This modification is specifically (PRA) In Fire Area G, PRA determined that CV-7403 to preclude spurious credited from a PRA perspective in Reactor Building purge valve CV-7403 operation. Fire Area G.
should be modified to preclude spurious operation. CV-7403 does not have This modification adds an This modification reduces the risk automatic features via interlocks to inhibit circuit which will of fire induced AOV hot short preclude spurious operation to reduce preclude spurious opening of circuit failure. This AOV overall plant risk as a result of a fire the AOV due to intercable or modification will preclude spurious induced circuit failure. intracable hot shorts. operation to reduce plant risk in Fire Area G as a result of a fire LAR Source: induced hot short circuit failure.
Attachment C (NEI-04-02 Table B-3) In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.
, Attachment 1 1CAN111204 Page 15 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-23 Med 1 AOV CV-7404: ANO plans a modification for Yes Yes This modification is specifically (PRA) CV-7404 to preclude spurious credited from a PRA perspective in In Fire Area G, PRA determined that operation. Fire Area G.
Reactor Building purge valve CV-7404 should be modified to preclude spurious This modification adds an Modification reduces the risk of fire operation. CV-7404 does not have inhibit circuit which will induced AOV hot short circuit automatic features via interlocks to preclude spurious operation of failure. This AOV modification will preclude spurious operation to reduce the AOV due to intercable or preclude spurious operation to overall plant risk as a result of a fire intracable hot shorts. reduce plant risk in Fire Area G as induced circuit failure. a result of a fire induced hot short circuit failure.
LAR Source:
In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory measures per OP-1003.014 have been established as appropriate.
S1-24 Med 1 SW Pump P-4A: ANO plans a circuit Yes Yes This modification is specifically (PRA) modification to reroute cables credited from a PRA perspective in In Fire Area I-2, the PRA identified the that support remote operation Fire Area I-2.
possible loss of SW pump P-4A due to of SW pump P-4A.
circuit impacts. This modification to reroute cables Circuits are planned to be reduces the risk of a fire induced LAR Source: rerouted to avoid Fire Area I-2 circuit failure.
Attachment C (NEI-04-02 Table B-3) using embedded conduit as available or routed in In accordance with station raceways that already contain directives, compensatory other cables that would impact measures per OP-1000.120 have P-4A. Any new raceway been established as appropriate.
needed for these circuits will be installed outside of any zone of influence for postulated fire sources or routed in locations where deterministic compliance can be demonstrated.
, Attachment 1 1CAN111204 Page 16 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-25 Med 1 EFW Pump P-7B: ANO plans a circuit Yes Yes This modification is specifically (PRA) modification to reroute cables credited from a PRA perspective in In Fire Area I-2, the PRA identified the that support remote operation Fire Area I-2.
possible loss of EFW pump P-7B due to of P-7B.
circuit impacts. This modification to reroute cables Circuits are planned to be reduces the risk of a fire induced LAR Source: rerouted to avoid Fire Area I-2 circuit failure.
Attachment C (NEI-04-02 Table B-3) using embedded conduit as available or routed in In accordance with station raceways that already contain directives, compensatory other cables that would impact measures per OP-1000.120 have P-7B. Any new raceway been established as appropriate.
needed for these circuits will be installed outside of any zone of influence for postulated fire sources or routed in locations where deterministic compliance can be demonstrated.
, Attachment 1 1CAN111204 Page 17 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-26 Med 1 Primary Makeup Pump P-36A: ANO plans a circuit Yes Yes This modification is specifically (PRA) modification to reroute cables credited from a PRA perspective in In Fire Area I-2, the PRA identified the that support remote operation Fire Area I-2 possible loss of Primary Makeup pump of P-36A.
P-36A due to circuit impacts. Modification to reroute cables Circuits are planned to be reduces the risk of a fire induced LAR Source: rerouted to avoid Fire Area I-2 circuit failure.
Attachment C (NEI-04-02 Table B-3) using embedded conduit as available or routed in In accordance with station raceways that already contain directives, compensatory other cables that would impact measures per OP-1000.120 have P-36A. Any new raceway been established as appropriate.
needed for these circuits will be installed outside of any zone of influence for postulated fire sources or routed in locations where deterministic compliance can be demonstrated.
S1-27 High 1 Sluice Gate Valve SG-1: ANO plans to install a Yes Yes This modification is credited (PRA) modification for Sluice Gate globally from a PRA perspective In multiple Fire Areas, PRA determined valve SG-1. and affects multiple fire areas.
that Sluice Gate valve SG-1 should be A modification is planned to be modified to remove the potential of completed to remove the This modification removes the spurious operation to reduce overall potential for spurious closing potential of spurious operation to plant risk as a result of a fire induced as a result of a fire induced reduce overall plant risk for SG-1 circuit failure. circuit failure. as a result of a fire induced circuit failure.
LAR Source: The modification is planned to allow Sluice Gate Valve SG-1 In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory to remain open in all PRA fire scenarios. measures per OP-1003.014 have been established as appropriate
, Attachment 1 1CAN111204 Page 18 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-28 High 1 Sluice Gate Valve SG-2: ANO plans to install a Yes Yes This modification is credited (PRA) modification for Sluice Gate globally from a PRA perspective In multiple Fire Areas, PRA determined valve SG-2. and affects multiple fire areas.
that Sluice Gate valve SG-2 should be A modification is planned to be modified to remove the potential of completed to remove the This modification removes the spurious operation to reduce overall potential for spurious closing potential of spurious operation to plant risk as a result of a fire induced as a result of a fire induced reduce overall plant risk for SG-2 circuit failure. circuit failure. as a result of a fire induced circuit failure.
LAR Source: The modification is planned to allow Sluice Gate Valve SG-2 In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory to remain open in all PRA fire scenarios. measures per OP-1003.014 have been established as appropriate S1-29 High 1 Sluice Gate Valve SG-3: ANO plans to install a Yes Yes This modification is credited (PRA) modification for Sluice Gate globally from a PRA perspective In multiple Fire Areas, PRA determined valve SG-3. and affects multiple fire areas.
that Sluice Gate valve SG-3 should be A modification is planned to be modified to remove the potential of completed to remove the This modification removes the spurious operation to reduce overall potential for spurious closing potential of spurious operation to plant risk as a result of a fire induced as a result of a fire induced reduce overall plant risk for SG-3 circuit failure. circuit failure. as a result of a fire induced circuit failure.
LAR Source: The modification is planned to allow Sluice Gate Valve SG-3 In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory to remain open in all PRA fire scenarios. measures per OP-1003.014 have been established as appropriate
, Attachment 1 1CAN111204 Page 19 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-30 High 1 Sluice Gate Valve SG-4: ANO plans to install a Yes Yes This modification is credited (PRA) modification for Sluice Gate globally from a PRA perspective In multiple Fire Areas, PRA determined valve SG-4. and affects multiple fire areas.
that Sluice Gate valve SG-4 should be A modification is planned to be modified to remove the potential of completed to remove the This modification removes the spurious operation to reduce overall potential for spurious closing potential of spurious operation to plant risk as a result of a fire induced as a result of a fire induced reduce overall plant risk for SG-4 circuit failure. circuit failure. as a result of a fire induced circuit failure.
LAR Source: The modification is planned to allow Sluice Gate Valve SG-4 In accordance with station Attachment C (NEI-04-02 Table B-3) directives, compensatory to remain open in all PRA fire scenarios. measures per OP-1003.014 have been established as appropriate S1-31 High C New PRA Credited Fire Barriers ANO plans to provide a Yes Yes This modification is credited (PRA) identified: modification to upgrade globally from a PRA perspective insurance required fire barriers and affects multiple fire areas.
NFPA 805 non-compliance issues were such as multiple walls, encountered when smaller fire area dampers, penetration seals, In accordance with station barriers such as multiple walls, and doors to rated barriers. directives, compensatory dampers, penetration seals, and doors These barriers will be measures per OP-1000.120 have required by insurance were credited identified as NRC regulatory been established as appropriate.
and used in the Fire PRA model as basis to ensure compliance rated fire barriers in the NRC regulatory with NFPA 805. These basis for NFPA 805. barriers will be upgraded as Multiple walls and doors barriers will required per EC 1956.
require upgrading to comply with NFPA 805.
LAR Source:
Attachment A (NEI-04-02 Table B-1)
, Attachment 1 1CAN111204 Page 20 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-32 Low C NFPA 50A, Gaseous Hydrogen ANO plans to provide a No No The subject hydrogen gas system (Code) Systems, code non-compliance issues modification to remove the bottle storage area is not credited were identified: hydrogen bottles and manifold by the PRA.
outside the room (reference NFPA 50A code issues exist in the EC 25606). This modification is planned to be Hydrogen Gas Bottle Storage Room completed to meet NFPA 805 code related to inadequate vent piping and requirements.
room ventilation. Hydrogen relief valve vent piping is not routed to the outside of the building. The hydrogen storage room light switch was identified as not meeting Article 501 for Class I, Division II locations of the National Electric Code (NEC).
LAR Source:
Attachment A (NEI-04-02 Table B-1)
S1-33 Low C NFPA 10, Fire Extinguishers, code non- ANO plans to provide a No No The subject fire extinguishers are (Code) compliance issues were identified: modification to install the not credited in the Fire PRA.
proper number of fire NFPA 10 code issues (such as extinguishers to meet travel This modification is planned to be incorrect number of fire extinguishers distance requirements in completed to meet NFPA 805 code for travel distance, incorrect type and coverage areas. requirements.
size for the hazard area) were identified with ANO portable fire extinguishers in ANO plans to install multiple Fire Areas. adequately sized fire extinguishers and correct type LAR Source: fire extinguishers that are Attachment A (NEI-04-02 Table B-1) rated for the fire hazard to meet NFPA 10 requirements.
, Attachment 1 1CAN111204 Page 21 of 21 Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-34 Low 1 NFPA 30, Oil Storage Tank, code non- ANO plans to provide a No No The subject oil storage tank vaults (Code) compliance issues were identified: modification to reroute the are not credited in the Fire PRA.
ventilation air supply duct to In the Dirty and Clean Lube Oil Tank remove the oil leakage path This modification is planned to be Room, Fire Area B-1, Fire Zone from the oil storage vault. completed to meet NFPA 805 code 187-DD, the air supply duct location in requirements.
the vault wall near the floor provides an ANO plans to modify the oil leakage path via the supply duct ventilation air duct to meet outside of the vault; therefore the vault NFPA 30 requirements.
is not liquid tight.
The oil storage vault contains Lube Oil Tank (T-26) with the capacity of 30,000 gallons, which could rupture resulting in lube oil leak into the air supply duct.
LAR Source:
Attachment A (NEI-04-02 Table B-1)
S1-35 Med Non Power Operation (NPO) MOVs ANO plans a modification for No Yes The NPO modification reduces the (92-18) CV-1050, CV-1410, CV-1404: CV-1404 to meet requirements risk of fire induced MOV circuit per IN 92-18. failures (hot shorts, open circuits ANO 1 has no redundancy to the single and short to ground). This MOV RCS drop line to the Decay Heat This modification adds an modification can prevent a non-Removal (DHR) system with three inhibit circuit which will recoverable position failure in-series valves CV-1050, CV-1410, preclude spurious closing of resulting in the loss of decay heat and CV-1404. The NPO assessment the MOV due to intercable or removal.
determined that any one of the three intracable hot shorts.
RCS drop line valves could fail in a In accordance with station closed and unrecoverable position Procedural changes are directives, compensatory resulting in a loss of DHR. planned to secure MOVs measures per OP-1003.014 have CV-1050 and CV-1410 in the been established as appropriate.
LAR Source: open position by opening breakers to remove power.
Attachment D (NEI-04-02 Table F-1)
Attachment 2 ANO-1 NFPA 805 Modifications Design and Installation Schedule
, Attachment 2 1CAN111204 Page 1 of 2 ANO-1 NFPA 805 Modifications Design and Installation Schedule Scoping Design Installation Modification Description (based on ANO-1 LAR Table S-1 numbering)
Complete Complete Complete S1-1 Additional Auxiliary Feedwater (AFW) source to Steam Generators 03/01/2013 07/01/2013 1R26 / 1R27 S1-2 thru S1-6 Provide redundant DC control power to Switchgear A-1, A-2, 10/25/2013 07/01/2015 1R26 / 1R27 A-3, H-1 and H-2 and re-route some cabling S1-7 and S1-8 4160V AC breaker circuit modification to prevent spurious 10/25/2013 07/01/2015 1R26 / 1R27 operation of A-309 and A-409 S1-9 Incipient Fire Detection for Control Room Panel C20 09/06/2013 12/15/2013 1R25 / 1R26 S1-10 Air Operated Valve (AOV) CV-1052 (Quench Tank Drain) circuit 08/16/2013 07/01/2015 1R26 modification to preclude spurious operation S1-11 Motor Operated Valve (MOV) CV-1053 (Quench Tank Drain) circuit 08/16/2013 07/01/2015 1R27 modification to preclude spurious operation S1-12 MOV CV-1221 (Letdown Isolation) circuit modification to preclude 08/16/2013 07/01/2015 1R26 spurious operation S1-13 MOV CV-1405 (Emergency Core Cooling Reactor Building Sump 08/16/2013 07/01/2015 1R27 Suction) circuit modification to preclude spurious operation S1-14 MOV CV-1406 (Emergency Core Cooling Reactor Building Sump 08/16/2013 07/01/2015 1R26 Suction) circuit modification to preclude spurious operation S1-15 MOV CV-3643 (Service Water Auxiliary Cooling Water Supply) circuit 08/16/2013 07/01/2015 1R26 modification to preclude spurious operation S1-16 AOV CV-4400 (Reactor Building Sump Drain) circuit modification to 08/16/2013 07/01/2015 1R26 preclude spurious operation S1-17 MOV CV-4446 (Reactor Building Sump Drain) circuit modification to 08/16/2013 07/01/2015 1R27 preclude spurious operation S1-18 MOV CV-5611 (Reactor Building Firewater Supply) circuit modification 08/16/2013 07/01/2015 1R26 to preclude spurious operation
, Attachment 2 1CAN111204 Page 2 of 2 Scoping Design Installation Modification Description (based on ANO-1 LAR Table S-1 numbering)
Complete Complete Complete S1-19 MOV CV-5612 (Reactor Building Firewater Supply) circuit modification 08/16/2013 07/01/2015 1R27 to preclude spurious operation S1-20 thru S1-23 AOVs CV-7401, CV-7402, CV-7403, and CV-7404 (Reactor Building Purge Isolations) circuit modifications to preclude 08/16/2013 07/01/2015 1R26 / 1R27 spurious operations S1-24 thru S1-26 Circuit re-routes for Service Water Pump P-4A, Emergency Feedwater Pump P-7B, and Primary Makeup Pump P-36A 12/20/2013 07/01/2015 1R27 to reduce risk of circuit failure in specific areas S1-27 thru S1-30 Service Water sluice gate valves SG-1, SG-2, SG-3, and 03/15/2013 12/15/2013 1R25 / 1R26 SG-4 modifications to prevent spurious closure S1-31 Fire Barrier Upgrades 09/23/2013 07/01/2015 1R26 S1-32 NFPA 50A Non-Compliance Corrections (related to Hydrogen Gas 12/21/2012 04/01/2014 12/15/2014 Bottle Storage Room)
S1-33 NFPA 10 Non-Compliance Corrections (related to fire extinguishers) 01/25/2013 04/01/2014 12/15/2014 S1-34 NFPA 30 Oil Storage Tank Ventilation Air Duct Relocation (related to 09/27/2013 04/01/2014 12/15/2014 Dirty and Clean Lube Oil Tank Room)
S1-35 MOVs CV-1050, CV-1410, and CV-1404 (Decay Heat Removal Suction Isolations) modification for NRC Information Notice (IN) 92-18 issues 08/30/2013 07/01/2015 1R26 / 1R27 (associated with non-power operations)
Refueling outage 1R25 (red train outage) is scheduled for the fall of 2014.
Refueling outage 1R26 (green train outage) is scheduled for the spring of 2016 Refueling outage 1R27 (red train outage) is scheduled for the fall of 2017.
Attachment 3 ANO-1 NFPA 805 License Amendment Request (LAR) Schedule
, Attachment 3 1CAN111204 Page 1 of 2 ANO-1 NFPA 805 LICENSE AMENDMENT REQUEST (LAR) SCHEDULE ACTIVITY STATUS*
Classical Fire Protection NFPA Code Compliance Reviews Complete Existing Engineering Equivalency Evaluations Complete Fire Area Licensing Action Reviews Complete Nuclear Safety Capability Assessment Safe Shutdown Equipment List Complete Safe Shutdown Circuit Analysis Complete Fire Area Assessment Complete Known Transition Modifications Complete Probabilistic Risk Assessment (PRA)
Fire PRA Peer Review Complete Scoping Fire Modeling Complete Self-Ignited Cable Fire Scenarios Not Applicable Circuit Failure Mode/Likelihood Analysis Complete Main Control Room Analysis 1st Quarter 2013 Detailed Fire Modeling 1st Quarter 2013 Focused Scope Peer Review 1st Quarter 2013 Human Reliability Analysis Complete Fire Risk Quantification 1st Quarter 2013 Revised Fire PRA 1st Quarter 2013 Fire Risk Evaluations (FREs) 1st Quarter 2013 Non-Power Operations Circuit Analysis Complete Pinch-Point Analysis Complete
, Attachment 3 1CAN111204 Page 2 of 2 ANO-1 NFPA 805 LICENSE AMENDMENT REQUEST (LAR) SCHEDULE (continued)
ACTIVITY STATUS*
Resolution of the Three ANO-2 LAR Deficiencies Deficiency No. 1 Steps to Resolution 1st Quarter 2013 Steps to Inclusion into the PRA 1st Quarter 2013 Steps to Inclusion into the FREs 1st Quarter 2013 Deficiency No. 2 Steps to Resolution Complete Steps to Inclusion into the PRA Complete Steps to Inclusion into the FREs 1st Quarter 2013 Deficiency No. 3 Steps to Resolution 1st Quarter 2013 Steps to Inclusion into the PRA 1st Quarter 2013 Steps to Inclusion into the FREs 1st Quarter 2013 Programmatic Finalize the ANO-1 LAR 2nd Quarter 2013 LAR Peer Review Not Applicable Management Approval 2nd Quarter 2013