ML13009A292
| ML13009A292 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/24/2013 |
| From: | Markley M Plant Licensing Branch IV |
| To: | Entergy Operations |
| Kalyanam N | |
| References | |
| TAC ME9429 | |
| Download: ML13009A292 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 24, 2013 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT NO.1 - SAFETY EVALUATION REGARDING THE ADDITIONAL FIRE PROTECTION ENFORCEMENT DISCRETION (TAC NO. ME9429)
Dear Sir or Madam:
By letter dated August 23, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12236A407), as supplemented by letters dated November 15, December 13, and December 18, 2012 (ADAMS Accession Nos. ML123210137, ML12349A318, and ML12353A617, respectively), Entergy Operations Inc. (Entergy, the licensee), requested an extension of enforcement discretion for the Arkansas Nuclear One, Unit 1 (ANO-1) National Fire Protection Association Standard (NFPA) 805 license amendment request (LAR) submittal to August 31,2013. In its submittal, Entergy described the need for additional time to correct the deficiencies identified in the U.S. Nuclear Regulatory Commission (NRC) staff's non-acceptance letter dated September 7,2012 (ADAMS Accession No. ML12208A196), for the Arkansas Nuclear One, Unit 2 (ANO-2) NFPA 805 LAR. Entergy had scheduled the ANO-2 resubmittal by the end of 2012, ahead of the ANO-1 LAR effort, so that the ANO-2 deficiencies could be incorporated into the ANO-1 LAR prior to submittal. Entergy also reasoned that the request for an extension was due to the lack of resources needed to correct both the ANO-1 and ANO-2 LARs simultaneously and, therefore, added to the delay.
By letter dated December 18, 2012, Entergy documented its review of the NFPA 805 modification schedule and refined many of the milestone dates. In addition, Entergy requested additional time for its LAR submittal, to January 31, 2014, to account for the potential unforeseen circumstances that were likely to cause ANO-1 LAR submittal delays.
The NRC staff has reviewed the licensee's strategy performing modifications, in parallel with the development of its NFPA 805 transition to reduce current fire risk and the planned and completed NFPA 805 modifications and associated schedules. The staff concludes that the schedule supports completing some of these modifications prior to completion of the staff's 2-year LAR review period and the identified modifications would be expected to reduce plant fire risk.
Based on the licensee's status, scheduled key activities, and planned NFPA 805 modification schedule, the NRC staff concludes that the licensee has provided adequate justification for extending enforcement discretion. Based on the enclosed safety evaluation, the staff concludes that if the licensee completes the identified actions, follows the proposed schedule, and agrees to a confirmatory order as described in SECY 0031, "Enforcement Alternatives for Sites That
-2 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 (ADAMS Accession No. ML12025A349), there is a reasonable assurance that the licensee's new submittal date of January 31,2014, for the ANO-1 NFPA 805 LAR is achievable.
If you have any questions, please contact N. Kalyanam, Project Manager, at (301) 415-1480 or bye-mail at kaly.kalyanam@nrc.gov.
Sincerely,
~-I.~
Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-313
Enclosure:
As stated cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR EXTENSION OF FIRE PROTECTION ENFORCEMENT DISCRETION FACILITY OPERATING LICENSE NO. DPR-51 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313
1.0 INTRODUCTION
By letter dated August 23, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12236A407), as supplemented by letters dated November 15, December 13, and December 18, 2012 (ADAMS Accession Nos. ML123210137, ML12349A318, and ML12353A617, respectively), Entergy Operations Inc. (Entergy, the licensee), requested an extension of enforcement discretion for the Arkansas Nuclear One, Unit 1 (ANO-1) National Fire Protection Association Standard (NFPA) 805 license amendment request (LAR) submittal to August 31, 2013. In its submittal, Entergy described the need for additional time to correct the deficiencies identified in the U.S. Nuclear Regulatory Commission (NRC) staff's non-acceptance letter dated September 7,2012 (ADAMS Accession No. ML12208A196), for the Arkansas Nuclear One, Unit 2 (ANO-2) NFPA 805 LAR. Entergy had scheduled the ANO-2 resubmittal by the end of 2012, ahead of the ANO-1 LAR effort, so that the ANO-2 deficiencies could be incorporated into the ANO-1 LAR prior to submittal. Entergy also reasoned that the request for an extension was due to the lack of resources needed to correct both the ANO-1 and ANO-2 LARs simultaneously and, therefore, added to the delay.
1.1 Background By letter of intent (LOI) dated November 2, 2005 (ADAMS Accession No. ML053140128),
Entergy notified the NRC of its intent to transition the ANO-1 Fire Protection Program (FPP) to a performance-based (PB) licensing basis in accordance with Section 50.48(c) of Title 10 of the Code of Federal Regulations (10 CFR), entitled "National Fire Protection Association Standard NFPA 805," also known as NFPA 805. By letter dated January 31, 2006 (ADAMS Accession No. ML053500434), the NRC staff responded to Entergy's LOI and granted the licensee 2 years of enforcement discretion to evaluate its NFPA 805 transition and submit its ANO-1 LAR.
During the NFPA 805 pilot program years, by letter dated December 22, 2008 (ADAMS Accession No. ML083500404), the NRC staff granted Entergy additional enforcement discretion for ANO-1 to complete its transition evaluations 6 months past the date of the safety evaluation approving the second pilot plant LAR.
Enclosure
-2 By letter dated August 23, 2012, the licensee provided a list of ANO-1 plant modifications, recovery actions, and the risk of recovery actions by fire area for the NFPA 805 transition.
Entergy assured the NRC that the following information would remain available on-site for staff review: (1) a listing of all fire protection related non-compliances and related compensatory measures, (2) documentation ensuring each Operator Manual Action put in place as a compensatory measure is feasible and reliable, and (3) a description of the physical modifications already performed to address fire protection issues and noncompliances.
By letter dated November 5,2012 (ADAMS Accession No. ML12310A462), the NRC staff requested additional information (RAI) to justify and assure completion of an acceptable LAR submittal, prior to granting a revised date. By letter dated November 15, 2012, Entergy responded to the RAls. Subsequently, the staff requested the following information:
(1) Justification for the length of time needed to install the circuit modifications addressing spurious operations, and (2) Clarification if enough time was planned for potential unforeseen circumstances that would delay the licensee's submittal.
By letter dated December 18, 2012, Entergy documented its review of the NFPA 805 modification schedule and refined many of the milestone dates. In addition, Entergy requested additional time for its LAR submittal to account for the potential unforeseen circumstances that were likely to cause ANO-1 LAR submittal delays.
2.0 REGULATORY EVALUATION
In 2004, the Commission approved NFPA 805 enforcement discretion to encourage licensees to identify and correct long standing fire protection design noncompliances that improve nuclear safety. Under the new NFPA 805 requirements; performance criteria are set and the quantification of risk may indicate that correcting some of the design non-compliances provide minimal nuclear safety benefit and will not need to be corrected under NFPA 805 requirements.
On June 10, 2011 (ADAMS Accession No. ML111610616), the Commission approved a revision to Section 9.1 of the NRC Enforcement Policy titled, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" (ADAMS Accession No. ML11117A264). This revision provided additional enforcement discretion to stagger the LAR submittals, which allowed the staff enough time to properly review multiple submittals with the resources available.
Entergy, by letter dated June 28, 2011 (ADAMS Accession No. ML111790756), requested additional time to make the new submittal. The NRC staff, by letter dated July 28, 2011 (ADAMS Accession No. ML112030193), granted Entergy a new commitment date of August 31, 2012, for the ANO-1 LAR submittal In SECY 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 (ADAMS Accession No. ML12025A349), the NRC staff informed the Commission of a number of regulatory options the staff would utilize in addressing licensees who were unable to submit their NFPA 805 LARs
-3 by their commitment dates. By letter dated August 23, 2012, Entergy requested to utilize one of these regulatory alternatives for ANO-1.
By letter dated December 18, 2012, Entergy requested the NRC issue a Confirmatory Order approving the requested enforcement discretion extension for ANO-1 in order to extend the ANO-1 enforcement discretion for a new LAR submittal date of January 31, 2014.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed and evaluated ANO-1 NFPA 805 transition progress and milestones by conSidering ANO-1 's key transition activities in Classical Fire Protection, Nuclear Safety Capability Assessment, Probabilistic Risk Assessment (PRA), and Non-Power Operations, as well as its efforts to address identified fire protection non-compliances and reduce fire risk ahead of an approved NFPA 805 LAR. The evaluations below and the Task Matrix in Section 3.5 of this safety evaluation show the progress that the licensee has made.
3.1 Classical Fire Protection The NRC staff reviewed the status of the licensee's classical fire protection efforts in support of completing the ANO-1 NFPA 805 LAR. The licensee indicated that ANO-1 has completed all of the code compliance reviews, the existing engineering equivalency evaluations, and the fire area-by-fire-area licensing action reviews. Therefore, unless the fire PRA shows a new mitigation system is needed, the staff concludes that the information for this key activity provides reasonable assurance that this portion of the NFPA 805 LAR submittal is achievable.
3.2 Nuclear Safety Capability Assessment The NRC staff reviewed the status of the licensee's nuclear safety capability assessment efforts in support of completing the ANO-1 NFPA 805 LAR. The efforts associated with the safe shutdown equipment list, safe shutdown circuit analyses, and fire area assessments were shown as complete. The initial submittal provided the known NFPA 805 modifications with a scoping schedule. The NRC staff requested additional information on Entergy's completed modifications for NFPA 805 since it started its transition in 2005, and its plans to complete design and installation of these known modifications. In its RAI responses, Entergy stated that most of the modification designs will not be completed until July 2015, and installation will not take place until either the 2016 or 2017 refueling outage. The NRC staff held a call with the licensee to discuss the basis for the extended schedule. Entergy stated that this was a "worst case" schedule and suggested most modifications would be installed in earlier refueling outages prior to those in the schedule.
In its letter dated December 18, 2012, Entergy provided a refined schedule for its known modifications with a less extended timeframe for the design and installation of the circuit modifications to protect against fire-induced spurious operations. The NRC staff concludes that the refined schedule and the additional information and clarifications provide reasonable assurance that the licensee is making progress towards fire safety improvements and that the milestones for this portion of the ANO-1 NFPA 805 LAR submittal are achievable.
- 4 3.3 Probabilistic Risk Assessment The NRC staff reviewed Entergy's request for the extension and the status of the licensee's fire PRA development efforts in support of completing the NFPA 805 LAR. Entergy stated that it has completed their fire PRA full-scope peer review, scoping fire modeling, circuit failure modellikelihood analysis, and human reliability analysis. The licensee plans to have the following analyses completed by the end of the first quarter of calendar year 2013:
- the main control room analysis (after ANO-2 is resolved),
- detailed fire modeling,
- the documentation for the focus-scoped peer review,
- fire risk quantification,
- fire risk evaluations, and
- revisions to the fire PRA.
The licensee notes that the completed sections of the LAR have been fully drafted and initial reviews are complete; however, further revisions may be required pending the final results of the ANO-2 fire PRA resolution results.
Based on the above, it appears that additional fire PRA development and another ANO-1 focus-scope peer review on elements that the ANO-2 fire PRA deficiencies reveal may be needed. This follow-on focus scope peer review is currently not identified or scheduled. In support of its request to extend enforcement discretion, the licensee provided a schedule that includes the activities to complete the fire PRA additional areas by the first quarter 2013. This coincides with the integration of the ANO-2 fire PRA identified deficiencies. The licensee's RAI responses identified this as a potential unforeseen circumstance that could delay completing the ANO-1 LAR on time. The NRC staff had a call with the licensee to get clarification of these potential unforeseen circumstances and their effect on completing an acceptable LAR development and LAR submittal by the committed date. By letter dated December 18, 2012, Entergy requested additional time to submit the ANO-1 NFPA 805 LAR to account for these unforeseen circumstances. The staff concludes that the new schedule (January 31, 2014) proposed by the licensee for this key activity provides reasonable assurance that the new ANO-1 NFPA 805 LAR submittal schedule is achievable.
3.4 Non-Power Operations The NRC staff reviewed the status of the licensee's non-power efforts in support of completing the ANO-1 NFPA 805 LAR. The circuit analysis and pinch-point analysis are reported as complete. The staff notes that the main parts of this key activity are complete.
-5 3.5 Licensee's Progress with Key Transition Activities TASK MATRIX Key Transition Activities Completion Status Reported Classical Fire Protection NFPA Code Compliance Reviews Complete Existing Equivalency Evaluations Complete Fire Area Licensing Action Review Complete Nuclear Safety Capability Assessment Safe Shutdown Equipment List Complete Safe Shutdown Circuit Analysis Complete Fire Area Assessments Complete Known Transition Modification Complete Probabilistic Risk Assessment (PRA)
Fire PRA Peer Review Complete Scoping Fire Modeling Complete Circuit Failure Mode/Likelihood Analysis Complete Human Reliability Analysis Complete Main Control Room Analysis 151 Quarter 2013 Detailed Fire Modeling 151 Quarter 2013 Focus Scope Peer Review 151 Quarter 2013 Fire Risk Qualification 151 Quarter 2013 Revised Fire PRA 151 Quarter 2013 Fire Risk Evaluations (FREs) 151 Quarter 2013 Non-Power Operations Circuit Analysis Complete Pinch-Point Analysis Complete Resolution of ANO-2 LAR Deficiencies Deficiency No. 1 151 Quarter 2013 Deficiency No.2 15t Quarter 2013 Resolution and inclusion in the PRA are complete Deficiency No.3 15t Quarter 2013 Programmatic Complete All Analysis 2nd Quarter 2013 Complete All Reviews 3rd Quarter 2013 Finalize ANO-1 LAR 4th Quarter 2013 Management Approval 4th Quarter 2013
- 6 3.6 Fire Protection Non-Compliances The NRC staff reviewed the licensee's information provided in its letters dated November 15 and December 18,2012, the transition strategy, and efforts to address fire protection non compliances. The licensee stated that its strategy included performing modifications, in parallel with the development of its NFPA 805 transition to reduce current fire risk. The staff reviewed the status of the completed and planned NFPA 805 modifications and associated schedule.
Based on its review, the NRC staff concludes that the schedule supports the licensee completing some of these modifications prior to completion of the staff's 2-year LAR review period and the identified modifications would be expected to reduce plant fire risk.
4.0 CONCLUSION
Based on the licensee's status, proposed schedule of key activities, and planned plant modification schedule, the NRC staff concludes that the licensee provided adequate justification for extending enforcement discretion. Furthermore, the staff concludes that if the licensee completes the actions as identified, follows the proposed schedule, and agrees to a confirmatory order as described in SECY-12-0031, there is a reasonable assurance that the licensee's new submittal date of January 31,2014, for the ANO-1 NFPA 805 LAR is achievable.
Principal Contributors: Paul W. Lain Jonathan Evans Date: January 24, 2013
IVIL12025A349), there is a reasonable assurance that the licensee's new submittal date of January 31,2014, for the ANO-1 NFPA 805 LAR is achievable.
If you have any questions, please contact N. Kalyanam, Project Manager, at (301) 415-1480 or bye-mail at kaly.kalyanam@nrc.gov.
Sincerely, IRAI Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-313
Enclosure:
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