1CAN081202, Request for Extension of Enforcement Discretion

Request for Extension of Enforcement Discretion

ML12236A407
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/23/2012
From:	Schwarz C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN081202
Download: ML12236A407 (39)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 1CAN081202 August 23, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Extension of Enforcement Discretion Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51

References:

1. NRC letter dated July 28, 2011, Arkansas Nuclear One, Units 1 and 2 -

Commitment to Submit a License Amendment Request to Transition to 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, and Request to Extend Enforcement Discretion (TAC Nos. ME6691 and ME6692) (ML112030193) (0CNA071107)

2. NRC letter dated May 25, 2012, Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC No. ME8282) (ML121380395) (2CNA051202)

3. Entergy letter dated July 10, 2012, Supplemental to License Amendment Request to Adopt NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

(2CAN071202)

4. Entergy letter dated August 14, 2012, Request for Extension of Enforcement Discretion, Arkansas Nuclear One - Unit 2 (2CAN081202)

5. 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)

1CAN081202 Page 2 of 3

Dear Sir or Madam:

By letter dated July 28, 2011 (Reference 1), Entergy Operations, Inc. (Entergy) received enforcement discretion for fire protection issues for Renewed Facility Operating License No.

DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The 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.

ANO, Unit 2 (ANO-2) submitted a request to adopt a new licensing basis (i.e., transition to 10 CFR 50.48(c), National Fire Protection Association (NFPA) Standard 805, commonly called NFPA 805) in March 2012. By letter dated May 25, 2012 (Reference 2), the NRC informed Entergy that supplemental information was required to support completion of the NRCs acceptance review of the ANO-2 submittal. As a result, supplemental information, including a regulatory commitment to provide additional information by November 2, 2012, was submitted to the NRC on July 10, 2012 (Reference 3). By teleconference on August 9, 2012, the NRC informed Entergy that additional information would be required to complete the NRC acceptance review and, therefore, the ANO-2 letter would not be accepted. The NRC identified three generic information items, but not in sufficient detail for Entergy to fully comprehend the scope and resources required to resolve all open issues. Subsequently, Entergy applied for an extension of the ANO-2 enforcement discretion period in Reference 4.

From a fire protection perspective, both ANO units are similar and supported by a single NFPA 805 transition team. Given the unexpected and significant resources likely to be required to resolve the aforementioned ANO-2 NFPA 805 submittal issues and, assuming that the same information would need to be developed and submitted for ANO-1, the August 31, 2012, ANO-1 submittal commitment is no longer achievable.

Because additional time is required to better understand the NRC concerns and develop an acceptable response into the ANO-1 submittal, in addition to the development of a subsequent ANO-2 NFPA 805 submittal, Entergy requests an extension of enforcement discretion for fire protection issues associated with ANO-1 until August 31, 2013. Entergy, therefore, commits to submit an ANO-1 License Amendment Request (LAR) implementing 10 CFR 50.48(c) prior to August 31, 2013 (see Enclosure 2 of this letter). Per the enforcement discretion policy, once the request is submitted and accepted, the enforcement discretion would then continue until the NRC dispositions the LAR.

By letter dated May 25, 2012 (Reference 2), the NRC outlined justification that would be required for an extension of enforcement discretion should Entergy be unable to provide sufficient supplemental information in a timely fashion that would support NRC acceptance of the ANO-2 LAR. Enclosure 1 to this letter contains information necessary to meet the Reference 2 requirements for enforcement discretion application as it would pertain to ANO-1.

Entergy requests the NRC issue a Confirmatory Order approving the requested enforcement discretion extension for ANO-1 as permitted by Reference 5.

Should you have any questions concerning this letter, or require additional information, please contact Stephenie Pyle at 479-858-4704.

1CAN081202 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 23, 2012.

Sincerely, ORIGINAL SIGNED BY CHRISTOPHER J. SCHWARZ CJS/dbb

Enclosures:

1. Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c)

2. List of Regulatory Commitments 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 1CAN081202 Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c) to 1CAN081202 Page 1 of 2 Enforcement Policy Requirements for Fire Protection Issues - 10 CFR 50.48(c)

In accordance with Section 9.1, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," of the NRC Enforcement Policy, dated July 12, 2011, and NRC letter to Entergy Operations, Inc. (Entergy) dated May 25, 2012, Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Adopt National Fire Protection Association Standard 805 (ML121380395), Entergy is providing the following justification in support of extending the current enforcement discretion period for fire protection issues for Arkansas Nuclear One, Unit 1 (ANO-1) as described in the cover letter to this Enclosure. The required information stated below is excerpted from the aforementioned NRC letter dated May 25, 2012. Key information associated with Entergys NFPA 805 transition process is included in italics.

1. Schedule of the key transition activities and major milestones for achieving the proposed new date including:

a. The preliminary design of specific plant modifications used to reduce site risk.

The preliminary design of specific plant modifications that are necessary to support the ANO-1 transition to NFPA 805 is included in Attachment 1 of this Enclosure.

Physical modifications are generally in the scoping phase at this time; however, the modification design phase includes verification by key ANO NFPA 805 project team personnel to ensure the final design meets the risk-based requirements credited in the ANO-1 NFPA 805 transition process.

b. Identification of all required NFPA 805 operator recovery actions.

Operator recovery actions are provided in Attachment 2 of this Enclosure. Although the final ANO-1 NFPA 805 submittal is not complete, the ANO-1 NFPA 805 transition process is not expected to identify any additional operator recovery actions.

c. Identification of all the NFPA 805 recovery action risk.

Recovery action risk is included in Attachment 3 of this Enclosure. The risk associated with the recovery actions is conservatively calculated within the context of the Fire Area in which the recovery actions are credited. The information provided in Attachment 3 is preliminary; however, Entergy does not expect the enclosed risk values to differ significantly in the final NFPA 805 submittal from that provided in Attachment 3.

d. Completion of the subsequent fire risk evaluations, sensitivity analyses, and formulation of the LAR.

The fire risk evaluations (FREs) and any necessary sensitivity analyses have been completed and are undergoing final review. Completion of the ANO-1 NFPA 805 submittal is not expected to require any significant changes to the fire risk evaluations or sensitivity analyses. However, the scope of the NRC identified ANO-2 open items, which must be evaluated for impacts on the ANO-1 NFPA 805 submittal, could require further review of the FREs and/or sensitivity analyses.

to 1CAN081202 Page 2 of 2 In light of the above, Entergy expects to submit the ANO-1 LAR by August 31, 2013, to accommodate gaps identified in the ANO-2 LAR and to account for unforeseen circumstances that may arise over this time period that could have a significant, currently undefined, impact on the timing of the ANO-1 LAR. Therefore, Entergy requests an extension of enforcement discretion until August 31, 2013. Nevertheless, Entergy intends to submit the ANO-1 LAR as soon as possible and will continue to interface with NRC personnel to support this effort.

2. Transition status should also identify and describe the additional progress that will be made in the following areas between the original ANO-1 LAR submittal date and the proposed new submittal date:

a. Classical fire protection transition.

b. Nuclear safety performance criteria transition.

c. Defining and installing transition modifications.

A summary of the ANO-1 NFPA 805 transition schedule over the requested enforcement discretion extension period is provided in Attachment 4 of this Enclosure.

Note that the uncertainties described above and accommodation of the ANO-2 NFPA 805 submittal can affect the schedule. Issues that have been raised on ANO-2 will need to be addressed for ANO-1 and resolved separately. The schedule is continuously updated to reflect necessary changes in start and finish dates and to reflect current plans.

The aforementioned May 25, 2012, NRC letter also requested Entergy ensure the following transition-related information remains available, on-site, for NRC staff review:

a. Listing of all fire protection-related non-compliances and the related compensatory measures for those non-compliances.

b. Documentation ensuring each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements," dated April 19, 2005 (ADAMS Accession No. ML042360547).

c. A description of the physical modifications performed, if any, to address existing fire protection issues and non-compliances.

The above information is available, on-site, for NRC staff review.

Attachments

1. ANO-1 NFPA 805 Modifications

2. ANO-1 NFPA Operator Recovery Actions

3. ANO-1 Recovery Action Risk

4. ANO-1 Transition Status

Attachment 1 ANO-1 NFPA 805 Modifications

, Attachment 1 1CAN081202 Page 1 of 21 S. Plant Modifications and Items 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 1CAN081202 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 Compensatory measures have Control Room functions to been established until compliance prevent a fire in the Control can be achieved by transitioning to Room from affecting local a 10 CFR 50.48(c) licensing basis.

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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 1CAN081202 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 Operator Recovery Actions

, Attachment 2 1CAN081202 Page 1 of 3 A multi-compartment analysis has been performed that has identified the need for operator action should the fire impact adjacent areas. These actions are required in the event of a multi-compartment fire interaction. The probability of such an interaction is low and therefore the need to implement these actions is not expected based upon the low failure probability of breaches that affect the associated barriers and creates an interaction beyond the initiating fire requiring recovery actions due to the fire impact in the adjacent area. The incorporation of these actions in post fire shutdown procedures will be evaluated in a manner that clearly differentiates these actions from those primary recovery actions which are associated with the initiating fire. The recovery actions identified below are associated with the initiating fire.

Recovery Actions and Activities Fire Area Component Component Description Actions Reactor Coolant Pumps Manually trip load breakers (H-11, H-22, H-12, H-21) and trip RCPs. For fire at switchgear B-1@BOFZ P-32A/B/C/D (RCPs) H1/H2/A1/A2, the DC modification design maintains trip capability of the RCPs.

4160V Vital Power G A-4 Verify breaker A-409 open and open DC control power breaker.

Switchgear Vital Power Switchgear G A-410 Verify breaker open and open DC control power breaker.

A4-A3 Crosstie De-energize B6 locally by opening A-401 and open DC control power when ERV isolation valve G B-6 480V Vital Power position verified.

Pressurizer Electromatic G CV-1000 Relief Valve (ERV) Isolation Remotely close valve.

Valve G CV-1206 RCP Seal Injection Valve Verify valve closed.

Letdown Coolers Outlet De-energize CV-1221 at panel B-61, breaker B6154, located in Fire Area B-1, Fire Zone 149-E.

G CV-1221 Valve Verify closed/manually close CV-1221 in Fire Area B-1, Fire Zone 79-U.

CV-1227 High Pressure Injection G Verify valves open.

CV-1228 (HPI) Block Valves RCP Seal Bleed Off G CV-1274 Verify valve closed.

Isolation Valve G CV-1275 Makeup Tank Outlet Valve Verify valve closed.

, Attachment 2 1CAN081202 Page 2 of 3 Recovery Actions and Activities Fire Area Component Component Description Actions Borated Water Storage G CV-1408 Manually open CV-1408 while monitoring flow.

Tank (BWST) Outlet Valve Auxiliary Cooling Water G CV-3643 Verify valve closed.

(ACW) Isolation Valve Service Water (SW) to G CV-3807 Emergency Diesel Verify valve open.

Generator #2 (EDG2) Coolers D21-1, -3, -9, DC Power To Various Open breakers to remove DC power to switchgear H2 and A2, and load center B6 (RCP seal G

-29 and -32 Equipment return to Quench Tank and High Point Vents).

G K-1 Main Turbine Manually trip Main Turbine with TRIP lever at front standard.

G K-2A, K-2B Main Feed Pumps Manually trip both Main Feedwater Pumps locally.

If EDG2 output breaker (A-408) is open, secure EDG by opening EDG2 Engine Control Power G K-4B EDG2 breaker (D-2114A) inside Control Panel C108.

G K-4B EDG2 Place EDG2 in no DC override condition to start or maintain operating if running.

G P-32A RCP Manually open H1 and H2 feeder breakers to trip RCPs following fire damage to control circuits.

G P-32B RCP Manually open H1 and H2 feeder breakers to trip RCPs following fire damage to control circuits.

G P-32C RCP Manually open H1 and H2 feeder breakers to trip RCPs following fire damage to control circuits.

G P-32D RCP Manually open H1 and H2 feeder breakers to trip RCPs following fire damage to control circuits.

Low Pressure Injection /

G P-34B Decay Heat Removal Verify breaker A-405 open and open DC control power breaker.

(LPI/DHR) Pump G P-35B Reactor Building Spray Pump Verify breaker A-404 open and open DC control power breaker.

De-energize DC control power to P-36A at D11, D-1104, located in Fire Area F, Fire G P-36A Primary Makeup Pump Zone 110-L. Verify tripped/manually trip A-306 in Fire Area E, Fire Zone 100-N.

, Attachment 2 1CAN081202 Page 3 of 3 Recovery Actions and Activities Fire Area Component Component Description Actions De-energize DC control power to P-36B(C) at RA2, RA-204, located in Fire Area I-1, Fire Zone 98-J. Verify closed/manually close A-801 in Fire Area B-8, Fire Zone 104-S.

G P-36B Primary Makeup Pump De-energize DC control power to P-36B at A4, A-407, located in Fire Area I-2, Fire Zone 99-M.

Verify tripped/manually trip A-407, in Fire Area I-2, Fire Zone 99-M.

G P-36B Primary Makeup Pump Manually start P-36B(G) at A4, breaker A-407, located in Fire Area I-2, Fire Zone 99-M.

De-energize DC control power to P-36C at A4, A-406, located in Fire Area I-2, Fire Zone 99-M.

G P-36C Primary Makeup Pump Verify tripped/manually trip A-406 in Fire Area I-2, Fire Zone 99-M.

G P-36C Primary Makeup Pump Manually start P-36C at A4, breaker A-406, located in Fire Area I-2, Fire Zone 99-M.

G P-4B, P-4C SW Pump Align Loop 2 SW.

New Auxiliary Feedwater G TBD Manually start and align AFW pump to establish primary to secondary heat removal.

(AFW) Pump G PSV-1000 Pressurizer ERV Manually disable PSV-1000 at breaker D-1124, local panel D11 in Fire Area I-1, Fire Zone 98-J.

SW Pump P-4B and Primary Makeup Pump P-36B Motor G RA2-3 and -4 Open breakers RA2-3 and -4.

Operated Disconnect Control Power Letdown Coolers Outlet De-energize CV-1221 at panel B61, breaker B-6154, located in Fire Area B-1, Fire Zone 149-E.

I-1 CV-1221 Valve Verify closed/manually close CV-1221 in Fire Area B-1, Fire Zone 79-U.

Letdown Coolers Outlet De-energize CV-1221 at panel B61, breaker B-6154, located in Fire Area B-1, Fire Zone 149-E.

J-North CV-1221 Valve Verify closed/manually close CV-1221 in Fire Area B-1, Fire Zone 79-U.

Letdown Coolers Outlet De-energize CV-1221 at panel B61, breaker B-6154, located in Fire Area B-1, Fire Zone 149-E.

J-South CV-1221 Valve Verify closed/manually close CV-1221 in Fire Area B-1, Fire Zone 79-U.

Attachment 3 to ANO-1 Recovery Action Risk

, Attachment 3 1CAN081202 Page 1 of 1 Risk of Recovery Summary by Fire Area Fire Area CDF Risk of Recovery LERF Risk of Recovery B-1@1201 2.72E-09 2.72E-09 1

B-1@73W 7.52E-07 9.88E-08 B1@BOFZ 6.72E-07 3.94E-09 B-91 4.04E-11 4.04E-11 E1 5.03E-10 5.29E-11 F1 3.08E-07 1.41E-08 G 4.74E-06 1.23E-06 1

H 1.94E-09 1.94E-09 I-1 6.90E-07 1.30E-08 I-21 1.40E-09 1.27E-10 J-North 9.74E-07 1.34E-07 J-South 4.88E-07 4.76E-08 1

O 1.68E-10 1.68E-10 Total 8.63E-06 1.54E-06 1

These Fire Areas contribute to the delta risk via recoveries associated with the multi-compartment analysis only.

Attachment 4 ANO-1 Transition Status

, Attachment 4 1CAN081202 Page 1 of 2 ANO-1 NFPA 805 Transition Project Schedule Overview NFPA 805 Project Activity Name Start Finish Clarification and Resolution of Three (3) NRC Identified LAR Deficiencies from August 9th On-going 12/03/2012 Conference Call for ANO-2 Finalize ANO-1 NFPA 805 LAR Update incorporating ANO-2 LAR deficiency corrections 12/04/2012 03/01/2013 Outside Expertise Review of ANO-1 Revised NFPA 805 LAR for Confirmation Prior to NRC Submittal 03/04/2013 05/15/2013 Procedure Development Corporate Procedures (Design Engineering, Work Management, Outage Management, On-going 05/16/2013 Training, Maintenance, Licensing, Operations, and Fire Protection) [~40 identified]

Site Fire Protection Procedures (Engineering, Operations, Maintenance, and Fire Protection) 08/29/2013 03/24/2014

[~80 identified]

Training Program Corporate Procedures Training On-going 10/07/2013 Site Procedures Training 10/25/2012 05/09/2014 Software Development (ARC-PLUS) 01/07/2013 04/02/2013 Attachment S Implementation Items Monitoring Program 01/07/2013 07/12/2013 Flushing Procedure in Accordance with NFPA 15 01/14/2013 04/12/2013 Revise Procedure EN-DC-161 Control of Combustibles Completed 01/27/2012 Revise Procedure(s) for NPO Transition 01/28/2013 07/26/2013 Revise OMA Procedures/Documents to include feasibility criteria for FAQ 07-0030 02/11/2013 08/16/2013 Develop/Revise Technical Documents/Procedures for NFPA 805 Licensing Basis 03/18/2013 11/22/2013 Revise NFPA 13 Documentation on Partial Suppression in Electrical Penetration Rooms 01/14/2013 04/12/2013 Revise NFPA 15 Documentation on Water Spray Release Modules 06/10/2013 12/20/2013

, Attachment 4 1CAN081202 Page 2 of 2 NFPA 805 Project Activity Name Start Finish Attachment S Modification Scoping S1-1 on Additional AFW Source to SGs On-going 09/27/2013 S1-2 thru S1-6 on DC Control Power to Switchgear A-1, A-2, A-3, H-1 and H-2 04/23/2013 10/25/2013 S1-7 and S1-8 on 4160V AC Breaker Circuit Modification to Prevent Spurious Operation of 07/25/2013 10/25/2013 A-309 and A-409 S1-9 on Incipient Fire Detection for Control Room Panel C20 03/04/2013 09/06/2013 S1-10 thru S1-23 on Circuit Modifications on 14 Valves to Preclude Spurious Operation 03/18/2013 08/16/2013 (MOVs and AOVs)

S1-24 thru S1-26 on Circuit Reroutes for P-4A, P-7B, and P-36A to Reduce Risk of Circuit 07/29/2013 12/20/2013 Failure in Specific Areas S1-27 thru S1-30 on Sluice Gate Valve Modification for SG-1, SG-2, SG-3, and SG-4 to 10/17/2012 03/15/2013 Prevent Spurious Closure S1-31 on Fire Barrier Upgrades 09/25/2012 09/23/2013 S1-32 on NFPA 50A Non-Compliance Corrections On-going 11/23/2012 S1-33 on NFPA 10 Non-Compliance Corrections On-going 01/25/2013 S1-34 on NFPA 30 Oil Storage Tank Ventilation Air Duct Relocation 03/04/2013 09/27/2013 S1-35 on MOVs Modification for IN 92-18 issues (NPO) 02/25/2013 08/30/2013

Enclosure 2 to 1CAN081202 List of Regulatory Commitments to 1CAN081202 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy Operations, Inc. (Entergy) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check one)

COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy will submit the License Amendment Request implementing August 31, 2013 10 CFR 50.48(c) for Arkansas Nuclear One, Unit 1