ML101310501

Notification of an NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000313-10-006; 05000368-10-006) and Request for Information

ML101310501
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/11/2010
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Walsh K Entergy Operations
References
IR-10-006
Download: ML101310501 (9)

See also: IR 05000313/2010006

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

May 11, 2010

Kevin Walsh, Vice President, Operations

Entergy Operations, Inc.

Arkansas Nuclear One

1448 S.R. 333

Russellville, AR 72802

SUBJECT: ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NOTIFICATION OF AN NRC

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT 05000313/2010006; 05000368/2010006) AND REQUEST FOR

INFORMATION

Dear Mr. Walsh:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC),

Region IV staff will conduct a triennial fire protection baseline inspection at your Arkansas

Nuclear One, Units 1 and 2 in August, 2010. The inspection team will be comprised of reactor

inspectors from the NRC Region IV office. The team will conduct the inspection in accordance

with the baseline Inspection Procedure 71111.05TTP, "Fire Protection-NFPA 805 Transition

Period (Triennial)."

The schedule for the inspection is as follows:

• Information gathering visit: July 27-29, 2010

• Onsite inspection: August 9-13, 2010

August 23-27, 2010

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, to become familiar with the fire protection programs, fire

protection features, post-fire safe shutdown capabilities and plant layout, mitigating strategies to

address Section B.5.b of the Interim Compensatory Measures Order, EA-02-026, of February

25, 2002/10 CFR 50.54(hh)(2). Four inspectors will participate in the information gathering visit

to select the fire areas for evaluation, identify additional documents needed to support the

inspection, obtain unescorted access, and meet with the key personnel who will support the

inspection. The fire area selection will require a walkdown of candidate fire areas in company

with key personnel from your staff. The enclosure to this letter provides an initial list of the

documents the team will need for their review. We request that your staff transmit copies of the

documents listed in the enclosure to the NRC Region IV office for team use in preparation for

the inspection. Please send this information so that it will arrive in our office in Arlington, Texas,

by the dates listed in the enclosure.

Entergy Operations, Inc. -2-

During the information gathering visit, the team will also discuss the following inspection support

administrative details: office space size and location; specific documents requested to be made

available to the team in their office spaces; arrangements for reactor site access; and the

availability of knowledgeable plant engineering and licensing organization personnel to serve as

points of contact during the inspection.

We request that during the onsite inspection weeks, you ensure that copies of analyses,

evaluations, or documentation regarding the implementation and maintenance of the fire

protection program, including post-fire safe shutdown capability, be readily accessible to the

team for their review. Of specific interest for the fire protection portion of the inspection are

those documents that establish that your fire protection program satisfies the NRC regulatory

requirements and conforms to applicable NRC and industry fire protection guidance. For the

B.5.b portion of the inspection, those documents implementing your mitigating strategies and

demonstrating the management of your commitments for the strategies are of specific interest.

Also, please ensure the availability of appropriate personnel knowledgeable of: (1) plant

systems required to achieve and maintain safe shutdown conditions from inside and outside the

control room, (2) the electrical aspects of the post-fire safe shutdown analyses, (3) reactor plant

fire protection systems, and (4) the fire protection program and its implementation.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, control number 3150-

0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection or the inspection team's information or logistical needs, please

contact Sam Graves, the team lead inspector, in the Region IV office at (817) 860-8102, or by

email, samuel.graves@nrc.gov.

Sincerely,

/RA/

N. OKeefe, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-313

50-368

Entergy Operations, Inc. -3-

License: DPR-51

NPF-6

Enclosure: Triennial Fire Protection

Inspection Documentation Request List

Senior Vice President

& Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, MS 39286-1995

Thomas Palmisano

Vice President, Oversight

Entergy Operations, Inc.

P.O. Box 31995

Jackson, MS 39286-1995

David Bice

Acting Manager, Licensing

Arkansas Nuclear One

1448 SR 333

Russellville, AR 72802

Joseph A. Aluise

Associate General Counsel - Nuclear

Entergy Services, Inc

639 Loyola Avenue

New Orleans, LA 70113

Senior Manager, Nuclear Safety & Licensing

Entergy Nuclear Operations

P.O. Box 31995

Jackson, MS 39286-1995

Chief, Radiation Control Section

Arkansas Department of Health

4815 West Markham Street, Slot 30

Little Rock, AR 72205-3867

Jim E. Gibson

County Judge of Pope County

100 West Main Street

Russellville, AR 72801

Entergy Operations, Inc. -4-

Arkansas Department of Health

Radiation Control Section

4815 West Markham Street, Slot 30

Little Rock, AR 72205-3867

David E. Maxwell, Director

Arkansas Department of Emergency

Management, Bldg. 9501

Camp Joseph T. Robinson

North Little Rock, AR 72199

Chief, Technological Hazards

Branch

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, TX 76209

Entergy Operations, Inc. -5-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Alfred.Sanchez@nrc.gov)

Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Jeff.Rotton@nrc.gov)

Branch Chief, DRP/E (Jeff.Clark@nrc.gov)

Senior Project Engineer, DRP/E (Ray.Azua@nrc.gov)

ANO Administrative Assistant (Vicki.High@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Kaly.Kalyanam@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

File located: R:\REACTORS\ANO2010006 RFI - STG MLXX

SUNSI Rev Compl. ;Yes No ADAMS ;Yes No Reviewer Initials STG

Publicly Avail Yes ;No Sensitive Yes ; No Sens. Type Initials STG

RIV:DRS/EB2 C:DRS/ EB 2

SGraves NOkeefe/GAP for

/RA/ /RA/

05/10/2010 05/11/2010

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

Triennial Fire Protection Inspection Documentation Request

Please provide the following documentation (items 1 - 4) prior to the onsite

information-gathering visit, preferably no later than July 19, 2010. Where practical, please

provide copies electronically.

1. The current version of your fire protection program and fire hazards analysis.

2. Post-fire safe shutdown analysis and the supporting calculations that demonstrate

acceptable plant response.

3. Copies of the licensing basis documents for fire protection (safety evaluation reports,

pertinent sections of the final safety analysis report, exemptions, deviations, letters

to/from the NRC regarding fire protection/fire safe shutdown, etc.).

4. The fire probabilistic risk assessment or portions of the plants individual plant

examination for external events report addressing fire events.

Please provide the following documentation (items 5 - 46) during the information-gathering

visit or by July 29, 2010, in order to support inspection preparation. Whenever practical,

please provide copies electronically. However, drawings should be provided as paper

copies of sufficient size that all details are legible.

5. Plant layout and equipment drawings for the selected fire areas (these areas will be

selected during the information gathering trip) that identify: (a) the physical plant

locations of major hot standby and cold shutdown equipment; (b) plant fire area and/or

fire zone delineation; and (c) the locations of fire protection equipment, such as

detection, suppression, and post-fire emergency lighting units; and (d) fire area

boundaries.

6. Fire protection program implementing procedures (e.g., administrative controls, operator

response procedures for fires, fire fighting procedures, etc.).

7. Operating procedures used for achieving and maintaining hot and cold shutdown

conditions from the control room in the event of a fire outside the control room (III.G.2

areas).

8. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas)

capability with or without control room evacuation.

9. Pre-fire plans for the selected fire areas (areas to be selected by the team during the

information-gathering trip).

-1- Enclosure

10. A list of equipment used to achieve and maintain hot standby and cold shutdowns in the

event of a fire (safe shutdown equipment lists).

11. Piping and instrumentation (flow) diagrams showing the components used to achieve

and maintain hot standby and cold shutdown for normal and alternate shutdown. Please

provide one copy of the piping and instrumentation (flow) diagrams for these systems of

a size sufficient to read all details. These should include the systems used for reactor

coolant system (RCS) makeup, RCS pressure control, decay heat removal, and

reactivity control, including the essential support systems.

12. A listing, with descriptions, of design change packages which were determined to impact

fire protection and post-fire safe shutdowns, performed in the last 3 years.

13. Copies of Generic Letter 86-10 evaluations performed in the last 3 years.

14. A listing of open and closed Condition Reports initiated in the last 3 years, which relate

to the fire protection program or equipment. Include Corrective Action Process

document number, date, and subject.

15. A listing of the applicable codes and standards (with the versions) related to the design

of plant fire protection features and evaluations of any code deviations. Copies of these

codes should be available for review.

16. Drawings of the portions of the emergency lighting system which support fire response.

17. Procedures used to remove smoke from safety-related areas and the engineering

studies or calculations which support the design basis.

18. Drawings of communication systems credited in the license basis for firefighting and

plant operations during fires where control room is occupied and/or evacuated.

19. Piping and instrumentation (flow) diagrams for the fire water and sprinkler systems.

20. A listing of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps and suppression systems.

21. Maintenance rule performance criteria and a summary of the last 3 years performance

history for fire protection program systems or functions monitored within the

maintenance rule program.

22. A copy of fire protection program requirements (e.g., limiting conditions for operation,

surveillance test requirements) covered by technical specifications, technical

requirements manual, updated final safety analysis report, or similar documents.

23. Copies of internal and external self-assessments, audits, peer-assessments or similar

reviews related to post-fire safe shutdown capability or the fire protection program

completed since December 3, 2007.

-2- Enclosure

24. A list of manual actions taken outside the control room which are credited to mitigate the

consequences of fires in III.G.2 areas (non-alternative shutdown areas). The list should

group actions by the initiating fire area or zone and indicate where the action must take

place.

25. Electronic copies of operator study guides (i.e., lesson plan text and graphics) or design

basis documents that describe the purpose/function/operating characteristics of the safe

shutdown systems (RCS makeup, RCS pressure control, decay heat removal, and

reactivity control, including the essential support systems).

26. Two copies of one-line diagrams of the electrical distribution system. These should

depict how power gets from the switchyard to the engineered safety feature loads (480V

and 4160V). Also, include the vital DC distribution system one-line diagrams.

27. A list of automatic and manually initiated gaseous fire suppression systems in the plant,

giving location and the key equipment being protected.

28. A list of repairs (and the procedure that controls the actions) needed to: a) reach and/or

maintain hot shutdown and b) reach and/or maintain cold shutdown.

29. A list of high to low pressure interface valves.

30. A copy of procedures governing the training and operation of the fire brigade.

31. Organization charts of site personnel down to the level of fire protection staff personnel.

32. A contact list of key site personnel who will be supporting this inspection, giving location

of their office and phone number onsite.

33. The team would like to observe an unannounced fire brigade drill in the plant, if possible,

during the week of August 23, 2010. Please put us in contact, during the onsite

information gathering trip, with the appropriate personnel for planning drills.

34. The team would like to perform a walkthrough of the procedure for control room

evacuation due to fire with qualified operators in the plant during the week of August 9,

2010. Please put us in contact, during the onsite information gathering trip, with the

appropriate personnel for planning the walkthrough.

The following documents involve B.5.b mitigating strategies.

35. A copy of the license condition that incorporated the requirements issued to address the

requirements of Section B.5.b of the ICM Order, EA-02-026, dated February 25, 2002,

and 10 CFR 50.54(hh)(2).

36. A list of all modifications to regulatory commitments made to meet the requirements of

Section B.5.b of the ICM Order, EA-02-026, dated February 25, 2002, the subsequently

imposed license conditions, and 10 CFR 50.54(hh)(2).

-3- Enclosure

37. A list of procedures/guidelines which were revised or generated to implement the

mitigation strategies. These could be extensive damage mitigation guidelines (EDMGs),

severe accident management guidelines (SAMGs), emergency operating procedures

(EOPs), abnormal operating procedures (AOPs), etc.

38. A matrix that shows the correlation between the mitigation strategies identified in

Nuclear Energy Institute 06-12 and the site-specific procedures or guidelines that are

used to implement each strategy.

39. A list of engineering evaluations/calculations that were used to verify engineering bases

for the mitigation strategies.

40. Copies of piping and instrumentation diagram (P&ID) or simplified flow diagrams for

systems relied upon in the mitigation strategies. These could be the type used for

training.

41. A list of modification packages and simplified drawings/descriptions of modifications that

were made to plant systems to implement the mitigation strategies.

42. Copies of procedure(s) used to inventory equipment (hoses, fittings, pumps, etc.)

required to be used to implement the mitigation strategies.

43. A list of B.5.b strategies, if any, which have implementing details that differ from that

documented in the submittals to the NRC and the safety evaluation report.

44. A copy of site general arrangement drawing(s) that show the majority of buildings/areas

referenced in B.5.b documents.

45. Training records/ training matrix/ lesson plans related to B.5.b.

46. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)

required to implement any mitigating strategies.

-4- Enclosure