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{{#Wiki_filter:1 NRR-PMDAPEm Resource From: George, Andrea Sent: Tuesday, January 12, 2016 7:33 AM To: BICE, DAVID B (ANO)
{{#Wiki_filter:NRR-PMDAPEm Resource From:                             George, Andrea Sent:                             Tuesday, January 12, 2016 7:33 AM To:                               BICE, DAVID B (ANO)
Cc: CLARK, ROBERT W; PYLE, STEPHENIE L
Cc:                               CLARK, ROBERT W; PYLE, STEPHENIE L


==Subject:==
==Subject:==
3rd Round Request for Additional Info rmation - ANO-1 NFPA 805 LAR - TAC No.
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.
MF3419 Attachments:
MF3419 Attachments:                     ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS)
ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Managemen t System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c).  
Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.48(c).
In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached. A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.
Sincerely, Andrea George Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081 1


In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached.
Hearing Identifier:   NRR_PMDA Email Number:         2588 Mail Envelope Properties  (Andrea.George@nrc.gov20160112073200)
A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.
 
Sincerely,  Andrea George
 
Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081
 
Hearing Identifier: NRR_PMDA Email Number: 2588   Mail Envelope Properties  (Andrea.George@nrc.gov20160112073200)


==Subject:==
==Subject:==
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No. MF3419 Sent Date:   1/12/2016 7:32:58 AM Received Date: 1/12/2016 7:32:00 AM From:   George, Andrea Created By:   Andrea.George@nrc.gov Recipients:     "CLARK, ROBERT W" <RCLARK@entergy.com> Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com> Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com> Tracking Status: None Post Office:     Files     Size     Date & Time MESSAGE   1490     1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx   28785 Options Priority:     Standard   Return Notification:   No   Reply Requested:   Yes   Sensitivity:     Normal Expiration Date:     Recipients Received:
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.
Enclosure REQUEST FOR ADDITIONAL INFORMATION  REGARDING LICENSE AMENDM ENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC. ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313
MF3419 Sent Date:           1/12/2016 7:32:58 AM Received Date:       1/12/2016 7:32:00 AM From:                 George, Andrea Created By:           Andrea.George@nrc.gov Recipients:
"CLARK, ROBERT W" <RCLARK@entergy.com>
Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com>
Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com>
Tracking Status: None Post Office:
Files                       Size                       Date & Time MESSAGE                     1490                       1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx                       28785 Options Priority:                   Standard Return Notification:         No Reply Requested:             Yes Sensitivity:                 Normal Expiration Date:
Recipients Received:


By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),
REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC.
submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.  
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313 By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),
submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.
In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional information (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e.,
a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, Potential for Loss of Remote Capability during a Control Room Fire (ADAMS Accession No.
ML031200481), for several valves at ANO-1. Based on the licensees response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.
The NRC staff cannot conclude that spurious actuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition risk evaluations (i.e., less than the self-approval risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.
Enclosure


In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional informat ion (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e., a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, "Potential for Loss of Remote Capability during a Control Room Fire" (ADAMS Accession No.
NRR-PMDAPEm Resource From:                             George, Andrea Sent:                             Tuesday, January 12, 2016 7:33 AM To:                               BICE, DAVID B (ANO)
ML031200481), for several valves at ANO-1. Based on the licensee's response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.
Cc:                               CLARK, ROBERT W; PYLE, STEPHENIE L
The NRC staff cannot conclude that spurious ac tuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition
 
risk evaluations (i.e., less than the self-approv al risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.
1 NRR-PMDAPEm Resource From: George, Andrea Sent: Tuesday, January 12, 2016 7:33 AM To: BICE, DAVID B (ANO)
Cc: CLARK, ROBERT W; PYLE, STEPHENIE L


==Subject:==
==Subject:==
3rd Round Request for Additional Info rmation - ANO-1 NFPA 805 LAR - TAC No.
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.
MF3419 Attachments:
MF3419 Attachments:                     ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS)
ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Managemen t System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c).  
Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.48(c).
In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached. A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.
Sincerely, Andrea George Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081 1


In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached.
Hearing Identifier:   NRR_PMDA Email Number:         2588 Mail Envelope Properties  (Andrea.George@nrc.gov20160112073200)
A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.
 
Sincerely,  Andrea George
 
Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081
 
Hearing Identifier: NRR_PMDA Email Number: 2588   Mail Envelope Properties  (Andrea.George@nrc.gov20160112073200)


==Subject:==
==Subject:==
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No. MF3419 Sent Date:   1/12/2016 7:32:58 AM Received Date: 1/12/2016 7:32:00 AM From:   George, Andrea Created By:   Andrea.George@nrc.gov Recipients:     "CLARK, ROBERT W" <RCLARK@entergy.com> Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com> Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com> Tracking Status: None Post Office:     Files     Size     Date & Time MESSAGE   1490     1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx   28785 Options Priority:     Standard   Return Notification:   No   Reply Requested:   Yes   Sensitivity:     Normal Expiration Date:     Recipients Received:
3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.
Enclosure REQUEST FOR ADDITIONAL INFORMATION  REGARDING LICENSE AMENDM ENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC. ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313
MF3419 Sent Date:           1/12/2016 7:32:58 AM Received Date:       1/12/2016 7:32:00 AM From:                 George, Andrea Created By:           Andrea.George@nrc.gov Recipients:
 
"CLARK, ROBERT W" <RCLARK@entergy.com>
By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),
Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com>
submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.
Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com>
 
Tracking Status: None Post Office:
In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional informat ion (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e., a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, "Potential for Loss of Remote Capability during a Control Room Fire" (ADAMS Accession No.
Files                       Size                       Date & Time MESSAGE                     1490                       1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx                       28785 Options Priority:                   Standard Return Notification:         No Reply Requested:             Yes Sensitivity:                 Normal Expiration Date:
ML031200481), for several valves at ANO-1. Based on the licensee's response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.
Recipients Received:
The NRC staff cannot conclude that spurious ac tuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition


risk evaluations (i.e., less than the self-approv al risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.}}
REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313 By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),
submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.
In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional information (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e.,
a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, Potential for Loss of Remote Capability during a Control Room Fire (ADAMS Accession No.
ML031200481), for several valves at ANO-1. Based on the licensees response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.
The NRC staff cannot conclude that spurious actuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition risk evaluations (i.e., less than the self-approval risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.
Enclosure}}

Revision as of 03:20, 31 October 2019

3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No. MF3419
ML16012A049
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 01/12/2016
From: Andrea George
Plant Licensing Branch IV
To: David Bice
Entergy Nuclear Operations
References
MF3419
Download: ML16012A049 (3)


Text

NRR-PMDAPEm Resource From: George, Andrea Sent: Tuesday, January 12, 2016 7:33 AM To: BICE, DAVID B (ANO)

Cc: CLARK, ROBERT W; PYLE, STEPHENIE L

Subject:

3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.

MF3419 Attachments: ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.48(c).

In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached. A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.

Sincerely, Andrea George Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081 1

Hearing Identifier: NRR_PMDA Email Number: 2588 Mail Envelope Properties (Andrea.George@nrc.gov20160112073200)

Subject:

3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.

MF3419 Sent Date: 1/12/2016 7:32:58 AM Received Date: 1/12/2016 7:32:00 AM From: George, Andrea Created By: Andrea.George@nrc.gov Recipients:

"CLARK, ROBERT W" <RCLARK@entergy.com>

Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com>

Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1490 1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx 28785 Options Priority: Standard Return Notification: No Reply Requested: Yes Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313 By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),

submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.

In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional information (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e.,

a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, Potential for Loss of Remote Capability during a Control Room Fire (ADAMS Accession No.

ML031200481), for several valves at ANO-1. Based on the licensees response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.

The NRC staff cannot conclude that spurious actuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition risk evaluations (i.e., less than the self-approval risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.

Enclosure

NRR-PMDAPEm Resource From: George, Andrea Sent: Tuesday, January 12, 2016 7:33 AM To: BICE, DAVID B (ANO)

Cc: CLARK, ROBERT W; PYLE, STEPHENIE L

Subject:

3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.

MF3419 Attachments: ANO-1 SSA 11-01 RAI response clarification.docx Mr. Bice, By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee), submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO 1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.48(c).

In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation. Please treat this email as formal transmittal of the third round RAI which is attached. A clarification call was held with your staff on January 6, 2016, during which it was agreed that a response would be provided by January 20, 2016. If there are difficulties in meeting this date, please call or email.

Sincerely, Andrea George Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1081 1

Hearing Identifier: NRR_PMDA Email Number: 2588 Mail Envelope Properties (Andrea.George@nrc.gov20160112073200)

Subject:

3rd Round Request for Additional Information - ANO-1 NFPA 805 LAR - TAC No.

MF3419 Sent Date: 1/12/2016 7:32:58 AM Received Date: 1/12/2016 7:32:00 AM From: George, Andrea Created By: Andrea.George@nrc.gov Recipients:

"CLARK, ROBERT W" <RCLARK@entergy.com>

Tracking Status: None "PYLE, STEPHENIE L" <SPYLE@entergy.com>

Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1490 1/12/2016 7:32:00 AM ANO-1 SSA 11-01 RAI response clarification.docx 28785 Options Priority: Standard Return Notification: No Reply Requested: Yes Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET NO. 50-313 By letter dated January 29, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A438), as supplemented by letters dated May 19, June 16, July 21, August 12, September 22, November 4, and November 17, 2015 (ADAMS Accession Nos. ML15139A196, ML15167A503, ML15203A205, ML15224A729, ML15265A113, ML15308A452, and ML15321A076, respectively), Entergy Operations, Inc. (the licensee),

submitted a license amendment request (LAR) to change the Arkansas Nuclear One, Unit 1 (ANO-1), fire protection program to one based on the National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). In the course of its review, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required in order to complete its evaluation, as detailed below.

In its letter dated November 4, 2015, the license submitted a response to Safe Shutdown Analysis (SSA) request for additional information (RAI) 11.01. Specifically, the licensee provided an extensive qualitative explanation concluding that installation of an inhibit circuit (i.e.,

a shorting switch) addresses the circuit failure modes identified in Information Notice (IN) 92-18, Potential for Loss of Remote Capability during a Control Room Fire (ADAMS Accession No.

ML031200481), for several valves at ANO-1. Based on the licensees response to SSA RAI 11.01, it appears that these shorting switches are credited with precluding spurious actuations of the IN 92-18 valves, and so fire-induced damage on DC control circuits located in the vicinity of cables having fusing greater than 10 amps of the inhibit circuits is not modeled in the Fire PRA.

The NRC staff cannot conclude that spurious actuations can be precluded without additional information. As an alternative to concluding that spurious actuation is precluded, spurious actuation need not be modelled if the risk is insignificant for both transition and post-transition risk evaluations (i.e., less than the self-approval risk guidelines); however, the NRC staff cannot reach this conclusion with the limited risk information provided by the licensee. Please provide a sensitivity study demonstrating that the risk impact of failing the protected valves is insignificant, or that the risk of the excluded scenarios in which a fire causes a spurious actuation and the inhibit switch fails is insignificant with regard to the plant change evaluations.

Enclosure