ML033580398

Letter to Craig G. Anderson - Response to Backfit Claim Re NRC Inspection Report

ML033580398
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/21/2003
From:	NRC Region 4
To:	Anderson C Entergy Operations
References
FOIA/PA-2003-0358, IR-01-006
Download: ML033580398 (1)

Text

4t*^ tC1t, UNITED STATES 0 in NUCLEAR REGULATORY COMMISSION 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 760111-B064 Craig G. Anderson, Vice President Operations 0071 Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russeliville, Arkansas 72801-0967

SUBJECT:

RESPONS GARDING NRC INSPECTION REPOR

Dear Mr. Anderson:

a ..

As documented in NRC Inspection Report 50-313;-368/01-06, dated August 20, 2001, the NRC identified an unresolved item in the Unit 1 emergency diesel generator corridor and the Unit 1.

north electrical switchgear room concerning use of manual actions in lieu of providing protection for cables associated with equipment necessary for achieving and maintaining hot shutdown as specified in 10 CFR Part 50, Appendix R.Section III.G.2. This issue was considered unresolved pending further NRC review and the determination of its risk. Subsequently, in an exit meeting held on August 30, 2001, the NRC informed Entergy Operations, Inc., that the existing configurations did not conform to the .requirements of 10 CFR Part 50, Appendix R, Section III.G.2. However, the issue remained unresolved pending the completion of the NRC's risk determination.

Your letter of September 28, 2001, claimed that our position that manual actions cannot be used to comply with 10 CFR Part 50, Appendix R, Section Il1.G.2, was a backfit. At issue is your use of manual actions for achieving and maintaining hot shutdown conditions in the event of a fire in the Unit 1 emergency diesel generator corridor (Fire Zone 98J) and north switchgear room (Fire Zone 99M). In this letter, you asserted that the NRC has accepted such manual actions in the past, and stated that our position with respect to disallowing the use of manual actions for complying with Section III.G.2 of Appendix R should be considered a backlit that is generic to all plants.

On October 26, 2001, and again on January 17, 2002, we convened a backfit panel in accordance with NRC Management Directive 8.4, NRC Program for Management of Plant-Specific Backfitting of Nuclear Power Plants," to review your backfit claim as stated in your letter of September 28, 2001. After careful consideration of your appeal, we have determined that (1) the NRC did not impose a regulatory staff position that is new or different from a

- previously applicable staff position relative to the requirements of 10 CFR Part 50, Appendix R, SectionJll.G.2; (2) the NRC did not approve the use of manhual'actions for complying with 10 CFR Part 50, Appendix R, Section III.G.2, in the Unit 1 diesel generator corridor and north

• ~ electrical switchgear room in lieu of meeting the requirements of 10 CFR Part 50, Appendix R, Section II.G.2.a, Il.G.2.b, or IllI.G.2.c; and (3) youflethodology for using manual actions (in 1he event of a fire in the Unit 1 diesel generator corridor and north switchgear room), in lieu of

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