ML040360411
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| ML040360411 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/14/2004 |
| From: | NRC Region 4 |
| To: | |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML040360411 (2) | |
Text
RIV STATUS OF FIRE PROTECTION INSPECTIONS Completed first round of FP Triennial Inspections in 2002 Completed second round of FP Triennials at 3 sites to date (DC, CGS, PV)
Early Focus/Findings (January 2000 - June 2001)
- Separation of redundant trains in the same fire area (App R, III.G.2)
- Redundant SSD equipment was free of fire damage (App R, III.G.2)
- Fire barriers, fire doors, and fire rated penetrations
- Fire protection features (detection, suppression)
Later Focus/Findings (June 200i to Present, Incorporated Lessons-learned)
- Manual actions in lieu of ensuring SSD equipment is free of fire damage (III.G.2)
- Alternative shutdown - timing of manual actions
- Emergency communications
- Fire barriers, doors, penetrations Findings in Second Round of Triennials
- Select less risk significant areas - expect the issues to be of less risk significance
- URI for manual actions in III.G.2 areas (pending licensing basis review)
- APV for associated circuits r Manual Actions Findings (manual actions In lieu of meeting Il.G.2 requirements)
- Early findings were processed as non-compliances using the SDP process.
- Later findings were processed iaw IP 71111 .05T guidance (Green NCV if manual actions are reasonable and feasible)
Alternative Shutdown Findings (III.G.3)
- Findings associated with the ability of operators to perform actions outside the control room within analyzed time constraints.
- Findirf~s associated with the timing of ASD _lactionsJheejbentidh e regosg ions______________ ________
- Findings associated with the adequacy and quality of ASD procedures.
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Associated Circuits/Multiple Hot Shorts/Mechanistic Damage Issues \ U 0
- EGM 98-006 put these issues on hold
- For these issues, we have opened 4 URIs and 2 APVs
- Guidance coming in early Sept for NRC and in Oct for industry and public
- mechanistic damage and multiple hot shorts issues?
- definition of associated circuits vs. required circuits?
- Begin inspections using the new guidance early next year?
Compensatory Measures
- RIV reviews comp measures in place at the time of the inspections.
- RIV inspectors perform walkdowns to verify that comp measures are in place, if necessary.
- To date no findings of significance have been identified.
- The licensee's FPP defines comp measures. Licensee's may change their FPP as long as it doesn't affect their ability to achieve and maintain SSD. .
Licensing Basis
- Difficult and time-consuming for both the licensee and NRC to assemble the licensing basis. SERs not always clear wrt what exactly was reviewed and approved.
- Understanding of the LB is time-consuming and sometimes controversial, requiring the region to consult with OGC.
- At least one other region saves/files the LB of each plant during the first round, so that this does not need to be performed from scratch during subsequent triennials.
Would like to see
- Resolution of Heymc issue
- Definition of adversely affect (re: license condition that states that licensee's may make changes to their FPP as long as they do not adversely affect their ability to achieve and maintain SSD.)