1CAN051602, Update to Tables S-1 and S-2 - Adoption of National Fire Protection Association Standard NFPA-805

Update to Tables S-1 and S-2 - Adoption of National Fire Protection Association Standard NFPA-805

ML16145A349
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/2016
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN051602, NFPA-805
Download: ML16145A349 (41)

Text

~Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One

. 1CAN051602 May 19, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Update to Tables S-1 and S-2 Adoption of National Fire Protection Association Standard NFPA-805 Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

By letter dated Jan*uary 29, 2014 (Reference 1), Entergy Operations, Inc. (Entergy) submitted a request to amend the Arkansas Nuclear One, Unit 1 (AN0-1) Technical Specifications (TS) and licensing bases to comply with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." The amendment request followed Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)." This submittal described the methodology used to demonstrate compliance with, and transition to, National Fire Protection Association (NFPA)-805, and included regulatory evaluations, PRAs, change evaluations, proposed modifications for non-compliances, and supporting attachments.

Entergy notified the NRC in a conference call on May 12, 2016, at 1430 eastern time, of plans to revise the wording previously proposed in certain Plant Modification and Implementation Items contained in Attachment S, Tables S-1 and S-2, of the original amendment request, as updated by letter dated March 25, 2016 (Reference 16).

Entergy proposes clarifications to Table S-1, Plant Modifications, Items S1-2, S1-3, S1-5, S1-6, and S1-23. Medification items S1-2, S1-3, S1-5, and S1-6 involve installation of an alternate control power source for non-vital 4160 V switchgear A 1 and A2, and non-vital 6900 V switchgear H1 and H2. The current wording includes Entergy's plan to install a "redundant" power source when the alternate power source will be "diverse" only, not redundant. Therefore, the "redundant" terms are replaced with the term "diverse". The final risk quantifications provided in the latest Attachment W (Reference 16) are not impacted by the proposed wording change as the original PRA credited only a diverse means of supplying control power to the respective switchgear. The source of this diverse power has remained unchanged since original conception.

1CAN051602 Page 2 of 5 Table 8-1, Item 81-23, is revised to clarify that modification of the subject Reactor Building purge valve will prevent spurious "opening" of the valve vice spurious "operation," consistent with the wording which follows in the "Proposed Modification" column of the table. Closure of this valve is a conservative measure (provides for Reactor Building isolation) and, therefore, spurious closure need not be addressed, nor does valve closure impact the final risk quantifications provided in the latest Attachment W (Reference 16). Note that operation of the Reactor Building purge system is not an AN0-1 credited safety function; however, isolation of the system (valves closed) is credited as a Reactor Building* isolation function. This change is for clarification purposes only and does not impact the original assumptions associated with the AN0-1 transition to NFPA-805.

With respect to Table 8-2, Implementation Items, one sentence of Implementation Item 82-9 is revised as follows:

The wording proposed in Entergy by letter dated March 25, 2016 (Reference 16):

If the as-built change-in-risk from each modification or implementation item, including the procedure changes in Implementation Item 82-6, exceeds RG 1.205 acceptance criteria, the results shall be entered into the corrective action program to evaluate the cause of risk increase and determine appropriate resolution.

New proposed wording:

The PRA review plan will ensure the as-built change-in-risk, including the procedure changes in Implementation Item 82-6, does not exceed the RG 1.205 acceptance criteria,

• and if it does, the cause of the risk increase will be evaluated and an appropriate resolution will be identified to verify that the acceptance guidelines are met.

Entergy's March 25, 2016 (Reference 16) letter included an update to Table 8-1 which identified those items which have been complete to date (Items 81-9, 81-12, 81-13, 81-14, 81-27, 81-28, 81-29, 81-30, 81-32, and 81-33). No additional Table 8-1 items.have completed since the Reference 16 submittal; however, Table 8-2, Implementation Items 82-3, 82-7, and 82-8 have been completed and Table 8-2 updated accordingly (see Attachment 1 of this letter).

To accommodate the above changes, a revised Attachment 8, "Modifications and Implementation Items," which contains the updated Tables 8-1 and 8-2, is included in Attachment 1 of this letter. Because the planned modifications and implementation items are.

• 'required to be completed as part of the AN0-1 transition to NFPA-805, revised markup and clean copies of the affected Operating License pages are included in Attachments 2 and 3 of this letter, respectively. Although no changes were made to the previously proposed Page 8 of the Operating License, all Operating License pages provided in the original license amendment request (LAR) (Reference 1) as updated by Entergy letter dated March 25, 2016 (Reference 16) are included in this submittal for completeness. Entergy requests the NRC to replace the respective Operating License pages submitted in letter dated March 25, 2016 (Reference 16) with those attached to this letter.

1CAN051602 Page 3 of 5 Section 2.c(8) of the Operating License is also revised to add the following sentence at the end of the first bullet under the heading "Other Changes that may be Made Without Prior NRC Approval," to be consistent with the NFPA 805 Operating License approved previously for ANO, Unit 2:

This License Condition does not apply to any demonstration of equivalency under Section 1. 7 ofNFPA 805.

The information, as detailed in this letter, with respect to the original Entergy request (Reference 1) has been reviewed and Entergy has determined that the information does not invalidate the no significant hazards consideration included in the Reference 1 letter.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this application is being provided to the designated Arkansas state official.

This letter contains no new commitments.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 19, 2016.

• JGB/dbb Attachments:

1. Updated Attachment S - Modifications and Implementation Items

2. Updated Mark-up of Enclosure 2 Operating License Pages

3. Updated Enclosure 3 Revised Operating License Pages

1CAN051602 Page 4 of 5 cc: Mr. Marc L. Dapas 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. 0. Box 310 London, AR 7284 7 U.S. Nuclear Regulatory Commission Attn: Mr. Stephen Koenick MS 0-8B1A One White Flint North 11555 Rockville Pik~

Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

REFERENCES:

1*. ' . . . .. '~"'*' ~*. l ~ ' '; *, . ,

1. Entergy letter dated January 29, 2014, License Amendment Request to AdoptNFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (1 CAN011401) (ML14029A438)

2. NRC letter dated May 5, 2015, Arkansas Nuclear One, Unit 1 - Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC No. MF3419) (1 CNA051501) (ML15091A431)

3. Entergy letter dated May 19, 2015, Response to Request for Additional Information -

Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN051501)

(ML15139A196)

4. Entergy letter dated June 16, 2015, 60-Day Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN061501) (ML15167A503)

5. Entergy letter dated July 21, 2015, 90-Day Response to Request for Additional Information

- Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN071501)

(ML15203A205)

6. Entergy letter dated August 12, 2015, 120-Day Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN081501) (ML15224A729)

1CAN051602 Page 5 of 5 REFERENCES (continued):

7. NRC email dated September 8, 2015, Arkansas Nuclear One, Unit 1 - 2nd Round Request for Additional Information - AN0-1 NFPA-805 LAR (TAC No. MF3419) (1 CNA091501)

(ML15251A220)

8. Entergy letter dated September 22, 2015, Round 2 Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN091501) (ML15265A113)

9. NRC email dated October 6, 2015, Arkansas Nuclear One, Unit 1 - 2nd Round Part 2 Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419)

(1CNA101501) (ML15280A114)

10. Entergy letter dated November 4, 2015, Second Set of Round 2 Responses to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1.CAN111501) (ML15308A452)

11. Entergy letter*dated November 17, 2015, Clarification of Response to Round 2 Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN111502) (ML15321A076)

12. NRC email dated January 12, 2016, Arkansas Nuclear One, Unit 1-3'd Round Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419) (1CNA011601)

(ML16012A049)

13. Entergy letter dated January 15, 2016, Response to Round 3 Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN011601) (ML16015A421)

14. NRC email dated February 3, 2016, Arkansas Nuclear One, Unit 1 - PRA Integrated Analysis Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419)

(1CNA021601)

15. NRC email dated March 10, 2016, Arkansas Nuclear One, Unit 1 - 4th Round Request for Additional Information - AN0-1 NFPA-805 LAR - TAC No. MF3419 (1 CNA031601)

(ML16070A131)

16. Entergy letter dated March 25, 2016, Response to PRA RAJ 03 - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN031602) (ML16088A299)

17. Entergy letter dated April 7, 2016, Response to PRA RAJ 19 -Adoption of National Fire Protection Association Standard NFPA-805 (1CAN041601) (ML16099A057)

\ .

Attachment 1 to 1CAN051602 Updated Attachment S - Modifications and Implementation Items

Arkansas Nuclear One - Unit 1 Att. 5 - Modifications and Implementation Items

5. 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. to 1CAN011401 Page 5-1

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-1 High New Auxiliary Feedwater (AFW) ANO plans a modification to install a Yes Yes This AFW modification is credited (PRA) pump: new AFW pump (common globally from a PRA perspective to Due to multiple impacts to the feedwater system for both units) and provide a reliable additional source Emergency Feedwater (EFW) associated motor operated valves of feedwater.

system, the need for an additional with diverse power sources and The lotal control panel modification source of feedwater to the Steam controls independent of the existing is also credited from a PRA Generators (SGs) was identified. EFW pumps. The pump will be perspective to provide an alternate capable of feeding either SG The means to perform required actions LAR Source: new AFW pump will be designed to outside the AN0-1 Control Room.

Attachment C, listed as a global meet or exceed the flow modification to reduce risk requirements of the AN0-1 EFW Manual actions are credited in fire pump P-78. areas that contain redundant safe shutdown equipment. The The new AFW pump proposed modification process will ensure design includes: these actions are feasible.

The capability to be operated Compensatory measures have from the AN0-1 Control been established until compliance Room and locally. can be achieved by transitioning to Electrical isolation from a 10 CFR 50.48(c) licensing basis.

Control Room functions to prevent a fire in the Control Room from affecting local control of AFW components.

Local controls and monitoring instrumentation to ensure proper operation and water flow to the SG. to1CAN011401 Page S-2

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 81-2 High Switchgear A-1: ANO plans a modification to install a Yes Yes This modification is credited (PRA) In multiple fire areas, a loss of diverse DC control power supply to globally from a PRA perspective.

normal DC control power could switchgear A-1 to eliminate loss of Installation of an alternate A-1 result in a loss of switchgear A-1. switchgear due to loss of normal DC switchgear DC control power control power. In the event the source reduces the rtsk of a fire LAR Source:

normal DC control power source is induced A-1 DC control power Attachment C, listed as a global lost, an automatic transfer to this cable failure causing a loss of modification to reduce rtsk alternate DC power source will offsite power.

occur.

In accordance with station The modification for the backup or directives, compensatory alternate DC power source will add measures per OP-1003.014 have a battery eliminator which is been established as approprtate.

supplied from either an AN0-1 or AN0-2 non-1 E source via an automatic transfer switch.

Installation of automatic transfer switches, cables and electrical conduit is proposed.

S1-3 High Switchgear A-2: ANO plans a modification to install a Yes Yes This modification is credited (PRA) In multiple fire areas, a loss of diverse DC control power supply to globally from a PRA perspective.

normal DC control power could switchgear A-2 to eliminate loss of Installation of an alternate A-2 result in a loss of switchgear A-2 switchgear due to loss of normal DC switchgear DC control power control power. In the event the source reduces the risk of a fire LAR Source: normal DC control power source is induced A-2 DC control power Attachment C, listed as a global lost, an automatic transfer to this cable failure causing a loss of modification to reduce rtsk alternate DC power source will offsite power.

occur.

In accordance with station The modification for the backup or directives, compensatory alternate DC power source will add measures per OP-1003.014 have a battery eliminator which is been established as approprtate.

supplied from either an AN0-1 or AN0-2 non-1 E source via an automatic transfer switch.

Installation of automatic transfer switches, cables and electrical conduit is proposed. to 1 CAN011401 Page S-3

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 Med Switchgear A-3: ANO plans a modification to install a Yes Yes This modification is credited for (PRA) In Fire Area 1-2, loss of DC control second diverse cable route to the Fire Area 1-2.

power to 4160kV switchgear A-3 A-3 DC control power. An In conjunction with the could result in the loss of control auctioneering feature will be modifications described in items functions for Primary Makeup employed such that a fire induced S1-2, S1-25, and S1-26, the Pump (P-36A), EFW pump failure in a single fire zone will not second diverse cable route (P-78), Service Water (SW) pump render the DC control function reduces the risk of a fire induced P-4A. unavailable. circuit failure of the switchgear and LAR Source: Routing of the second red train A-3 the possible loss of control switchgear room DC power cables functions to pumps P-36A, P-78, Attachment C, Fire Area 1-2 Risk outside the green train A-4 and P-4A.

Summary, VFDR 12-01-b, switchgear equipment room in Fire In accordance with station VFDR 12-02-a, and VFDR 12-03-c Area 99-M is planned. directives, compensatory The new second cable route is measures per OP-1003.014 have expected to impact Fire Zones 100-N, been established as appropriate.

197-X, 161-8, 159-8, 67-U, and 110-L.

The proposed scheme will also ensure availability of the A-3 DC control power should there be a fire in Fire Zones 67-U or 98-J. to1CAN011401 Page 5-4

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-5 High Switchgear H-1: ANO plans a modification to install a Yes Yes The modification to install a diverse (PRA) In multiple fire areas, the loss of diverse DC control power supply to DC control power supply is normal DC control power to H-1 switchgear to eliminate loss of credited globally from a PRA switchgear H-1 could preclude the switchgear due to loss of normal DC perspective.

Reactor Coolant Pumps (RCPs) control power. The modification to separate line from being tripped in the Control Additionally, ANO plans a and load breaker control power is Room. modification to remove internal DC only credited in Fire Area LAR Source: jumpers and separately protect H-1 B-1@BOFZ.

switchgear line and load breaker Both modifications reduce the risk Attachment C, listed as a global control power. This will prevent a of a fire induced circuit failure to modification to reduce risk, fire originating in a cubicle from VFDR B-1@BOFZ-04, the DC power cables feeding disabling the ability to trip the RCPs switchgear H-1, which could VFDR F-02, VFDR 11-04, and due to loss of shared control power.

VFDR 0-01 preclude tripping the RCPs from the Control Room.

In accordance with station directives, compensatory measures per.OP-1003.014 have been established as appropriate.

S1-6 High Switchgear H-2: ANO plans a modification to install a Yes Yes The modification to install a diverse (PRA) In multiple fire areas, the loss of diverse DC control power supply to DC control power supply is normal DC control power to H-2 switchgear to eliminate loss of credited globally from a PRA switchgear H-2 could preclude the switchgear due to loss of normal DC perspective.

RCPs from being tripped in the control power. The modification to separate line Control Room. Additionally, ANO plans a and lo.ad breaker control power is LAR Source: modification to remove internal DC only credited in Fire Area jumpers and separately protect H-2 B-1@BOFZ.

Attachment C, listed as a global switchgear line and load breaker Both modifications reduce the risk modification to reduce risk, VFDR control power. This will prevent a B-1@BOFZ-04, VFDR F-02, of a fire induced circuit failure to fire originating in a cubicle from the DC power cables feeding VFDR 11-04, and VFDR 0-01 disabling the ability to trip the RCPs switchgear H-2, which could due to loss of shared control power. preclude tripping the RCPs from the Control Room.

In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate. to1CAN011401 Page 5-5

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-7 Med A-309, 4160V AC Breaker: ANO plans to modify circuits for Yes Yes This modification is credited from a (PRA) In Fire Area B-1@BOFZ, a fire breaker A-309 to assure the PRA perspective in Fire Area induced fault in the turbine protective features remain intact, B-1@BOFZ.

building could result in spurious i.e., breakers remain tripped and do Modification to the circuits closing or preclude automatic trip not impede automatic start of the associated with breaker A-309 is functions at A-309 (vital associated EDG and associated planned to assure the protective switchgear A-3 supply breaker closure of EDG output breaker features remain intact, i.e., breaker from switchgear A-1) that could A-308. remains tripped and does not challenge the automatic start of impede automatic start of the the credited Emergency Diesel associated EDG and closure of Generator (EDG). EDG output breaker (A-308).

LAR Source: In accordance with station Attachment C, Fire Area directives, compensatory B-1@BOFZ Risk Summary, measures per OP-1003.014 have VFDR B-1@BOFZ-01 been established as appropriate.

S1-8 Med A-409, 4160V AC Breaker: ANO plans to modify circuits for Yes Yes This modification is credited from a (PRA) In Fire Area B-1@BOFZ, a fire breaker A-409 to assure the PRA perspective in Fire Area induced fault in the turbine protective features remain intact, B-1@BOFZ.

building could result in spurious i.e., breakers remain tripped and do Modification to the circuits closing or preclude automatic trip not impede automatic start of the associated with breaker A-409 is functions at A-409 (vital associated EDG and associated planned to assure the protective switchgear A-4 supply breaker closure of EDG output breaker features remain intact, i.e., breaker from switchgear A-2) that could A-408. remains tripped and does not challenge the automatic start of impede automatic start of the the credited EDG. associated EDG and closure of LAR Source: EDG output breaker (A-408).

Attachment C, Fire Area In accordance with station B-1@BOFZ Risk Summary, directives, compensatory VFDR B-1@BOFZ-01 measures per OP-1003.014 have been established as appropriate. to1CAN011401 Page S-6

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-9 Med Control Room Cabinet C20: ANO has installed a smoke detector Yes Yes This modification is credited from a (PRA) In Fire Area G, Fire Zone 129-F, in AN0-1 Control Room Cabinet PRA perspective in Fire Area G.

PRA determined that the C20 in accordance with the The modification to install a smoke installation of smoke detector(s) in NFPA 72, Fire Alarm Detection, detector system in AN0-1 Control Control Room Cabinet C20 will code of record. The new smoke Room Cabinet C20 reduces the reduce risk of a fire induced circuit detector loop is connected via signal risk of a fire induced circuit and and equipment failure. cable to the AN0-1 Control Room equipment failure that could result Fire Alarm Panel C-463 for trouble in the loss of Control Room LAR Source:

and alarm functions. Cabinet C20.

Attachment C, Fire Area G Risk Summary In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.

S1-10 Med Air Operated Valve (AOV) ANO plans a modification to add an Yes Yes This modification is credited from a (PRA) CV-1052: automatic feature to prevent PRA perspective in Fire Area G.

In Fire Area G, PRA determined solenoid or electro-pneumatic valve This modification reduces the risk that Quench Tank drain valve positioner from opening CV-1052 as of fire induced AOV circuit failures CV-1052 control circuit should be a result of a fire induced circuit (hot shorts, open circuits, and short modified to preclude spurious failure in the Control Room. to ground) and can preclude operation. CV-1052 control circuit spurious operation.

does not have automatic features In accordance with station via interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-7

Arkansas Nuclear One - Unit 1 Att. 5 - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-11 Med Motor Operated Valve (MOV) ANO plans to modify CV-1053 by Yes Yes This modification is credited from a (PRA) CV-1053: adding an "inhibit" circuit which will PRA perspective in Fire Area G.

In Fire Area G, PRA determined preclude spurious opening of the This modification reduces the risk that Quench Tank drain valve MOV due to intercable or intracable of fire induced MOV hot short CV-1053 should be modified to hot shorts. circuit failure and will preclude preclude spurious operation. spurious operation.

CV-1053 does not have automatic In accordance with station features via interlocks to preclude directives, compensatory spurious operation to reduce measures per OP-1003.014 have overall plant risk as a result of a been established as appropriate.

fire induced circuit failure.

LARSource:

Attachment C, Fire Area G Risk Summary S1-12 High MOVCV-1221: ANO has modified CV-1221 to meet Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined the requirements of IN 92-18. PRA perspective in Fire Area G.

that Letdown isolation valve This modification added an "inhibit" The modification reduces the risk CV-1221 should be modified to circuit which will preclude spurious of fire induced MOV hot short meet requirements per IN 92-18. opening of the MOV due to circuit failure and will preclude CV-1221 does not have automatic intercable or intracable hot shorts. spurious operation.

features via interlocks to preclude The circuit modification incorporated In accordance with station spurious operation to reduce an available spare conductor in an directives, compensatory overall plant risk as a result of a existing cable between the Control measures per OP-10'03.014 have fire induced circuit failure. Room cabinet and the 480 V MCC. been established as appropriate.

LAR Source:

Attachment C, Fire Area G Risk Summary, VFDR G-02-a to 1CAN011401 Page 5-8

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 81-13 High MOV CV-1405: ANO has modified CV-1405 to meet Yes Yes This modification is credited (PRA) In multiple fire areas, PRA the requirements of IN 92-18. globally from a PRA perspective.

determined that Train A This modification added an "inhibit" This modification reduces the risk Emergency Core Cooling (ECCS) circuit which will preclude spurious of fire induced MOV hot short Reactor Building sump suction opening of the MOV due to circuit failure and will preclude valve CV-1405 should be intercable or intracable hot shorts. spurious operation.

modified to meet requirements of The circuit modification incorporated In accordance with station IN 92-18. CV-1405 does not have an available spare cable for the directives, compensatory automatic features via interlocks conductor needed between the measures per OP-1003.014 have to preclude spurious operation to Control Room cabinet and the 480 V been established as appropriate.

reduce overall plant risk as a MCC.

result of a fire induced circuit failure.

LAR Source:

Attachment C, listed as a global modification to reduce risk, VFDR B173-02-b, VFDR B8SEPR-03-b, VFDR C-01-b, and VFDR G-02-c S1-14 High MOV CV-1406: ANO has modified CV-1406 to meet Yes Yes This modification is credited (PRA) In multiple fire areas, PRA the requirements of IN 92-18. globally from a PRA perspective.

determined that Train B ECCS This modification added an "inhibit" This modification reduces the risk Reactor Building sump suction circuit which will preclude spurious of fire induced MOV hot short valve CV-1406 should be opening of the MOV due to circuit failure and will preclude modified to meet reqyirements of intercable or intracable hot shorts. spurious operation.

IN 92-18. CV-1406 does not have The circuit modification incorporated In accordance with station automatic features via interlocks an available spare cable for the directives, compensatory to preclude spurious operation to conductor needed between the measures per OP-1003.014 have reduce overall plant risk as a Control Room cabinet and the 480 V been established as appropriate.

result of a fire induced circuit MCC.

failure.

LAR Source:

Attachment C, listed as a global .

modification to reduce risk, VFDR B-1@120-03-d, VFDR G-02-c, VFDR 11-03-c, and VFDR 13-03-e to1CAN011401 Page S-9

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-15 Not Used S1-16 Med AOV CV-4400: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-4400 by adding an PRA perspective in Fire Area G.

that Reactor Building sump drain "inhibit" circuit which will preclude This modification reduces the risk valve CV-4400 control circuit spurious opening of the AOV due to of fire induced AOV hot short should be modified to preclude intercable or intracable hot shorts. circuit failure and will preclude spurious operation. CV-4400 The circuit modification plan adds spurious operation.

control circuit does not have an automatic feature to prevent In accordance with station automatic features via interlocks to solenoid or electro-pneumatic valve directives, compensatory preclude spurious operation to positioner from opening CV-4400 as measures per OP-1003.014 have reduce overall plant risk as a result a result of a fire induced circuit been established as appropriate.

of a fire induced circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-17 Med MOV CV-4446: ANO plans to modify CV-4446 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building sump drain preclude spurious opening of the This modification reduces the risk valve CV-4446 should be MOV due to intercable or intracable of fire induced MOV circuit failures modified to preclude spurious hot shorts. (hot shorts, open circuits, and short operation. CV-4446 does not to ground) and will preclude have automatic features via spurious operation.

interlocks to preclude spurious In accordance with station operation to reduce overall plant directives, compensatory risk as a result of a fire induced measures per OP-1003.014 have circuit failure. been established as appropriate.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page 5-10

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-18 Med MOV CV-5611: ANO plans to modify CV-5611 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building firewater preclude spurious opening of the This modification reduces the risk valve CV-5611 should be MOV due to intercable or intracable of fire induced MOV hot short modified to preclude spurious hot shorts. circuit failure and will preclude operation. CV-5611 does not spurious operation.

have automatic features via In accordance with station interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary, S1-19 Med MOV CV-5612: ANO plans to modify CV-5612 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building firewater preclude spurious opening of the This modification reduces the risk valve CV-5612 should be MOV due to intercable or intracable of fire induced MOV hot short modified to preclude spurious hot shorts. circuit failure and will preclude operation. CV-5612 does not spurious operation.

have automatic features via In accordance with station interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary to 1CAN011401 Page S-11

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-20 Med AOV CV-7401: ANO plans lo modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7401 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7401 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7401 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature lo prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation lo reduce overall plant positioner from opening CV-7401 as measures per OP-1003.014 have risk as a 'result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-21 Med AOV CV-7402: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7402 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7402 control circuit should be spurious opening of the AOV due to offire induced AOV hot short modified lo preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7402 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks lo preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening CV-7402 as measures per OP-1003.014 have risk as a result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-12

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table 5-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-22 Med AOV CV-7403: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7403 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7403 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7403 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening CV-7403 as measures per OP-1003.014 have risk as a result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-23 Med AOV CV-7404: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit of CV-7404 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7404 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7404 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening AOV valve measures per OP-1003.014 have risk as a result of a fire induced CV-7404 as a result of a fire been established as appropriate.

circuit failure. induced circuit failure in the Control LAR Source: Room.

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-13

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-24 Med SW Pump P-4A: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reconfigure the circuit that supports PRA perspective in Fire Area 1-2.

may cause a loss of SW pump remote operation of SW pump P-4A. This modification to reconfigure the P-4A. Circuits are planned to be P-4A circuit reduces the risk of a LAR Source: reconfigured to avoid Fire Area 1-2. fire induced circuit failure.

Any new raceway or cables needed In accordance with station Attachment C, Fire Area 1-2 Risk for these circuits will be installed directives, compensatory Summary, VFDR 12-02-a outside of any zone of influence for measures per OP-1003.014 have postulated fire sources or routed in been established as appropriate.

locations where deterministic compliance can be demonstrated.

S1-25 Med EFW Pump P-78: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reroute cables that support remote PRA perspective in Fire Area 1-2.

may result in loss of EFW pump operation of P-78. This modification to reroute cables P-78. Circuits are planned to be rerouted reduces the risk of a fire induced LARSource: to avoid Fire Area 1-2 using circuit failure.

embedded conduit as available or In accordance with station Attachment C, Fire Area 1-2 Risk routed in raceways that already Summary, VFDR 12-01-b directives, compensatory contain other cables that would measures per OP-1003.014 have impact P-78. 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. to 1CAN011401 Page S-14

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-26 Med Primary Makeup Pump P-36A: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reconfigure cables that support PRA perspective in Fire Area 1-2 may result in a loss of Primary remote operation of P-36A. This modification to reconfigure the Makeup pump P-36A. P-36A circuits are planned to be P-36A circuits reduces the risk of a LAR Source: reconfigured to avoid Fire Area 1-2. fire induced circuit failure.

Any new raceway or cables needed In accordance with station Attachment C, Fire Area 1-2 Risk for these circuits will be installed Summary, VFDR 12-03-c directives, compensatory outside of any zone of influence for measures per OP-1003.014 have postulated fire sources or routed in been established as appropriate.

locations where deterministic compliance can be demonstrated.

S1-27 High Sluice Gate Valve SG-1: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-1 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closirig as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-1 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-1 to reduce overall plant risk for SG-1 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR B-1@120-02-c and VFDR C-03-e to1CAN011401 Page S-15

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-28 High Sluice Gate Valve SG-2: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-2 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-2 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-2 to reduce overall plant risk for SG-2 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LARSource: an available spare conductor in an directives. compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR G-05-a S1-29 High Sluice Gate Valve SG-3: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-3 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve induced circuit failure. This modification removes the SG-3 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-3 to reduce overall plant risk for SG-3 operation to reduce overall plant remain open ih all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk to 1CAN011401 _Page 5-16

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-30 High Sluice Gate Valve SG-4: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-4 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-4 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-4 to reduce overall plant risk for SG-4 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR G-05-a to1CAN011401 Page S-17

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-31 High c NFPA 805 non-compliance issues ANO plans to provide an adequate- Yes Yes This modification will be completed (PRA) were encountered when smaller for-the-hazard evaluation and if to meet NFPA 805 code fire area were defined such that necessary a modification to upgrade requirements.

multiple walls, dampers, fire barrier walls, dampers, In accordance with station penetration seals, and doors were penetration seals, and doors to directives, compensatory credited and used in the Fire PRA rated barriers for those barriers measures per OP-1003.014 have model as rated fire barriers in the credited for deterministic been established as appropriate.

NRG regulatory basis for compliance and subsequently NFPA 805. credited in the Fire PRA analysis.

Multiple walls and doors barriers These fire barriers below have been will require upgrading to comply previously identified as NRG with NFPA 805. regulatory basis to ensure LAR Source: compliance with NFPA 805 and have compensatory measures Attachment A, Section 3.11.2 established.

Fire barriers to be addressed as identified by EG-1956 are: 15-5, 15-4, 39-5, 44-2, 45-2, 46-4, 64-3, 67-4, 70-7, 72-5, 73-5, 75-2, 75-3, 75-4, 76-2, 76-3, 77-2, 78-2, 79-6, 81-4, 81-6, 81-7, 82-2, 88-1, 88-3, 88-5, 89-1, 89-5, 90-2, 90-4, 93-4, 101-5, 103-2, 103-4, 104-2, 105-2, 120-5, 121-1, 122-5, 123-1, 125-1, 143-1, 144-2, 144-3, 144-5, 144-6, 147-4, 149-2, 162-3, 162-4, 162-5, 170-1, 183-4, and 183-5. to1CAN011401 Page 5-18

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items 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 has modified the ventilation for No No The subject hydrogen gas system (Code) Systems. code non-compliance the Hydrogen Bottle Storage area to bottle storage area is not credited issues were identified in the ensure compliance with NFPA 50A. by the PRA.

Hydrogen Gas Bottle Storage In addition, electrical equipment and This modification has been Room related to inadequate vent wiring changes were made to meet completed to meet NFPA 50A code piping and room ventilation. The the requirements of NFPA 70 requirements.

hydrogen storage room light (NEC), Article 501 for Class I, Compliance with this code is not switch was identified as not Division 2.

part of the current licensing basis, meeting Article 501 for Class I, therefore, no compensatory Division 2 locations of the measures were needed.

National Electric Code (NEC).

LAR Source:

Attachment A, Section 3.3.7.1 S1-33 Low c NFPA 10, Fire Extinguishers, ANO has resolved NFPA 10 No No The subject fire extinguishers are (Code) code non-compliance issues deficiencies identified in not credited in the PRA.

(such as incorrect number of fire CALC-ANOC-FP-09-00009. This modification has been extinguishers for travel distance, In general, this modification involved completed to meet NFPA 10 code and incorrect type and size for the portable fire extinguisher physical requirements.

hazard area) were identified with relocation, substitution of existing Compliance with this code is not ANO portable fire extinguishers. extinguishers, and documentation part of the current licensing basis, LAR Source: updates to reflect these plant therefore, no compensatory Attachment A, Section 3.7 changes. The proper number of fire measures were needed.

extinguishers that meet travel distance requirements in coverage areas, adequately sized fire extinguishers, and the correct type of extinguisher that is rated for the fire hazard in each area have been installed. to 1CAN011401 Page S-19

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-34 Cabinet C539: ANO plans a modification to rework Yes Yes This modification is credited from a In Fire Area 1-1. impacts against the power circuits from panel RS-1 PRA perspective in Fire Area 1-1 the power supply for EFIC Signal to C539 that will eliminate the This modification removes the Conditioning Cabinet C539 can impacts in Fire Area 1-1. potential of a loss of result in a loss of instrumentation instrumentation as a result of fire and the operator cues necessary induced circuit failure.

for post fire shutdown. In accordance with station LAR Source: directives, compensatory Attachment C, Fire Area 1-1 Risk measures per OP-1003.014 have Summary, VFDR 11-05-a been established as appropriate.

S1-35 Med Non Power Operation (NPO) ANO plans a modification for No Yes The NPO modification reduces the (92-18) MOVs CV-1050, CV-1410, CV-1404 to meet the requirements risk of fire induced MOV circuit CV-1404: of IN 92-18. failures (hot shorts, open circuits, AN0-1 has no redundancy to the This modification adds an "inhibit" and short to ground). This MOV single Reactor Coolant System circuit which will preclude spurious modification can prevent a non-(RCS) drop line to the Decay Heal closing of the MOV due to intercable recoverable position failure Removal (OHR) system with three or intracable hot shorts. resulting in the loss of OHR.

in-series valves CV-1050, Procedural changes are planned to In accordance with station CV-1410, and CV-1404. The secure MOVs CV-1050 and directives, compensatory NPO assessment determined that CV-1410 in the open position by measures per OP-1003.014 have any one of the three RCS drop opening breakers to remove power. been established as appropriate.

line valves could fail in a closed and unrecoverable position resulting in a loss of DHR.

LAR Source:

Attachment D, VFDR NPO-RCS-DHR to1CAN011401 Page S-20

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table 5-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-36 High NFPA 13, Standard for the ANO plans to provide a modification Yes Yes These modifications will be (PRA) Installation of Sprinkler Systems to physically relocate/rework completed to meet NFPA 13 (1971 Edition). code non- existing sprinklers, add sprinklers, requirements.

compliance issues were identified add or rework hangers and fire The Fire PRA model credited the in CALC-AN01-FP-09-00007, protection branch line piping, and non-compliant sprinkler systems in Rev. 1, Unit 1 Electrical add sprinkler deflectors to resolve the fire areas to reduce the risk in Penetration. These non- non-compliant code issues and the hot gas layer (HGL) and multi-compliance issues are allowable meet NFPA 13 requirements. component analysis (MCA) sprinkler spacing exceeded and scenarios. The sprinkler systems obstructions blocking sprinkler were not designed or installed for spray patterns located in the full sprinkler coverage in these fire Upper (South and North) areas.

Electrical Penetration Rooms and In accordance with station Lower (South and North) directives, compensatory Electrical Penetration Rooms.

measures per OP-1003.014 have LAR Source: been established as appropriate.

Attachment A, Section 3.9.1 (1) to 1CAN011401 Page S-21

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-2 items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program.

Table S-2 Implementation Items Item Unit Description LAR Section I Source S2-1 C Develop a monitoring program required by NFPA 805 that will include a process to monitor and trend LAR Section 4.6 and Attachment A, the fire protection program based on specific goals established to measure effectiveness. Section 3.2.3 (3) s2-2* Revise or develop fire protection flushing activity to perform fixed water spray system flushing and Attachment A, Section 3.9.1 (2) drainage of underground lead-in connections in accordance with NFPA 15, 1977 Edition Code.

S2-3 c Entergy has revised appropriate fire protection administrative procedures to include the following: Attachment A, Section 3.3.1.2 (5)

In accordance with FAQ 06-0020, the term "applicable NFPA Standards" is considered to be equivalent to those NFPA Standards identified in the current licensing basis (CLB) for existing procedures and systems in the fire protection program that are transitioning to NFPA 805.

New Fire Protection Systems would be subject to the most current code or standard.

Terminology for zero transient combustibles and changes needed to support Fire PRA assumptions.

S2-4 Revise existing procedure(s) or develop new procedure(s) for NPO required to transition to NFPA 805 Attachment D, VFDR NPO-based upon insights gained from AN0-1 NPO calculation. Procedure S2-5 Revise operator manual action (OMA) procedures/documents to include feasibility criteria in Attachment G, Step 4 FAQ 07-0030 for the recovery actions listed in Table G-1 of Attachment G, Recovery Action Transition.

S2-6 c Develop or revise technical documents and procedures that relate to new Fire Protection design and LAR Sections 4.7.1, 4.7.2, and licensing basis (e.g., ANO Fire Protection Program, OP-1003.014, Technical Requirements Manual, 4.7.3, Attachment E Table E-1 Design Basis Document, Pre-Fire Plans, Maintenance and Surveillance Procedures, Configuration Control Program, Training and Qualification Guidelines, etc.) as required for implementation of NFPA 805.

S2-7 Entergy has completed a revision to CALC-ANOC-FP-09-00007 for NFPA 30 to update the code report Attachment A, Section 3.3.8 for Oil Tank T-25 dike/berm compliance and has performed an engineering evaluation for Oil Tank T-26 in tank vault, Fire Area B-1, Fire Zone 187 DD, with respect to the potential oil leakage path at the air supply duct location in the vault wall near the floor via the supply duct outside of the vault.

S2-8 Entergy has completed an evaluation which determined that Oil Tank T-29 supports are acceptable in Attachment A, Section 3.3.8 accordance with American Petroleum Institute (API) and National Fire Protection Association (NFPA) codes/standards, since T-29 supports documentation from construction is not available. Straps were added to provide additional assurance that the tank would remain in its saddle following a seismic event.

Enclosure 1 to 1CAN011401 Page S-22

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-2 Implementation Items Item Unit Description LAR Section I Source S~-9 Validate the change in risk by revising the FPRA model for each modification or implementation item LAR Section 4.8.2 completed that is credited either. directly or indirectly by f'RA. The PRA review plan will ensure the as-built change-in-risk, including the procedure changes in Implementation Item S2-6, does not exceed the RG 1.205 acceptance criteria, and if it does, the cause of the risk increase will be evaluated and an appropriate resolution will be identified to verify that the acceptance guidelines are met. The FPRA update will be performed in accordance with Entergy fleet PSA Maintenance procedure EN-DC-151, Section 5.2.

S2-10 Revise drawings and pre-fire plans for Fire Area 1-1, Fire Z:one 98-J corridor; since this wall will be Attachment C, FireArea 1*1 Fire credited by PRA as a radiant energy barrier Wall.with Door 57. PRA requires corridor to be divided or Zone 98-J split into two separate fire compartments at C-4 Line wall on EL 372. This division of the Fire Zone 98-J corridor will reduce the risk in the HGUMCA scenarios. to1CAN011401 Page S-23

Attachment 2 to 1CAN051602 Updated Mark-up of Enclosure 2 Operating License Pages

(8) Fire Protection Entergy Operations, Inc . ~ shall implement and maintain in effect all provisions of the approved f~ire pP.rotection pP.rogram as described in Appendix QA to the SAR and as approved in the Safety E>.1aluation dated March 31 , 1992, subject to the following provision :that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c) , as specified in the licensee amendment request dated January 29 , 2014 , and supplements dated May 19, 2015 , June 16, 2015 , July 21, 2015, August 12, 2015 ,

September 22 , 2015 , November 4, 2015 , November 17, 2015 , January 15, 2016 , March 25 , 2016 , April 7, 2016 , and May 19, 2016 , and as approved in the SE dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation , technical specification , license condition or requirement would require prior NRC approval ,

1. AP&L ~ may proceed 'Nith and is required to complete the modifications identified in Paragraphs 3.1 through 3.19 of the NRC's rire Protection Safety Evaluation on the facility dated August 22 ,

1978, and supplements thereto. These modifications shall be completed as specified in Table 3.1 of the Safety Evaluation Report or supplements thereto. In addition , the licensee may proceed 'Nith and is required to complete the modifications identified in Supplement 1 to the rire Protection Safety Evaluation Report, and any future supplements . These modifications shall be completed by the dates identified in the supplement.

2-:--------Tthe licensee may make changes to the approved f~ire pP.rotection pP.rogram without prior approval of the Commission GfH.y-if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c) , the change does not require a change to a technical specification or a license condition , and the criteria listed below are satisfiedwould not adversely affect the ability to achieve and maintain safe shutdmvn in the event of a fire .

Risk-Informed Changes that may be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach , methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated ; be based on the as-built, as-operated , and maintained plant; and reflect the operating experience at AN0-1. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRG through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments , or methods that have been demonstrated to bound the risk impact.

~ The Original licensee authorized to possess, use, and operate the facility was AP&L.

Consequently , certain historical references to AP&L remain in the license conditions.

Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation .

2. Prior NRC review and approval is not required for individual changes o-that result in a risk increase less than 1x1 7/year (yr) for CDF and less than 1x1 o-8 /yr for LERF . The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation .

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas :

1. Fire fighting response strategy with the following elements :

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel Moved to 2. Operations to mitigate fuel damage considering the following :

Page 7 (a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders 4- The Original licensee authorized to possess, use, and operate the facility was /\P&L.

Consequently, certain historical references to AP&L remain in the license conditions .

Renewed License No. DPR-51 Amendment No . ~ .

Revised by letter dated July 18, 2007

Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805 , Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805 , Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard . The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805 , Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard .

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard ." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805 , Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system , procedure , or physical arrangement, using a relevant technical requirement or standard . The four specific sections of NFPA 805 , Chapter 3, are as follows :

• Fire Alarm and Detection Systems (Section 3.8) ;

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9) ;

• Gaseous Fire Suppression Systems (Section 3.1O); and ,

• Passive Fire Protection Features (Section 3.11 ).

This License Cond ition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805 .

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated _ _ __ _

to determine that certain fire protection program changes meet the minimal criterion . The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-51 Amendment No. ~ .

Revised by letter dated July 18, 2007

Moved to _ _

Page 8 6

~~~~~---==========-~~~~-~-~~~~~~~~~~~~~~

,,.----- (10) Upon implementation of Amendment 239 adopting TSTF-448 , Revisio~

the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4 , in accordance with Specifications 5.5 .5.c.(i) ,

5.5.5.c.(ii), and 5.5.5.d, shall be considered met. Following implementation :

1. The first performance of SR 3.7.9.4 , in accordance with Specification 5.5.5 .c.(i) , shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii) , shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

3. The first performance of the periodic measurement of CRE pressure ,

Specification 5.5.5.d, shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

3. Th is renewed license is effective as of the date of issuance and shall expire at midnight, May 20, 2034 .

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by :

Jon R. Johnson Jon R. Johnson , Acting Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A - Technical Specifications and Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20 , 2001 Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c) , as specified by 2. below, risk-informed changes to the Entergy Operations , Inc.

fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility , as described in Table S-1 , "Plant Modifications," Attachment S, of Entergy Operations , Inc. letter 1CAN051602Ldated May 19, 2016 ,

prior to startup from the second refueling outage following issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of the modifications.

3. The licensee shall complete the implementation items as listed in Table S-2 , "Implementation Items," Attachment S, of Entergy Operations , Inc. letter 1CAN051602 , dated May 19, 2016 , within six months after issuance of the Safety Evaluation .

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas :

1. Fire fighting response strategy with the following elements :

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel From 2. Operations to mitigate fuel damage considering the following:

Page 5 (a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to on site responders Renewed License No. DPR-51 Amendment No. ~ .

Revised by letter dated July 18, 2007

From Page 6 ~~~~~--=========-~~~~-~-~~~~~~~~~~~~~~

,---- (10) Upon implementation of Amendment 239 adopting TSTF-448 , Revisio~

the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4, in accordance with Specifications 5.5.5 .c.(i) ,

5.5.5.c.(ii), and 5.5 .5.d, shall be considered met. Following implementation :

1. The first performance of SR 3.7.9.4 , in accordance with Specification 5.5.5.c.(i), shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii) , shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance .

3. The first performance of the periodic measurement of CRE pressure ,

Specification 5.5.5 .d, shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance .

3. This renewed license is effective as of the date of issuance and shall expire at midnight, May 20 , 2034.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by :

Jon R. Johnson Jon R. Johnson , Acting Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A - Technical Specifications and Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20 , 2001 Renewed License No. DPR-51 Amendment No . ~ .

Revised by letter dated July 18, 2007

Attachment 3 to 1CAN051602 Updated Enclosure 3 Revised Operating License Pages

(8) Fire Protection Entergy Operations, Inc. shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated January 29, 2014, and supplements dated May 19, 2015, June 16, 2015, July 21, 2015, August 12, 2015, September 22, 2015, November 4, 2015, November 17, 2015, January 15, 2016, March 25, 2016, April 7, 2016, and May 19, 2016, and as approved in the SE dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, Risk-Informed Changes that may be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at AN0-1. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specifiG license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x1 o-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.1 O); and,

' \

• Passive Fire Protection Features (Section 3.11 ).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated _ _ _ __

to determine that certain fire protection program changes meet the

• minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-51 Amendment N,a. ~.

Revised by letter dated July 1B, 2007

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified*

by 2. below, risk-informed changes to the Entergy Operations, Inc.

fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications," Attachment S, of Entergy Operations, Inc. letter 1CAN051602, dated May 19, 2016, prior to startup from the second refueling outage following issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of the modifications.

3. The licensee shall complete the implementation items as listed in Table S-2, "Implementation Items," Attachment S, of Entergy Operations, Inc. letter 1CAN051602, dated May 19, 2016, within six months after issuance of the Safety Evaluation.

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas:

1. Fire fighting response strategy with the following elements:

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fig~ting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel

2. Operations to mitigate fuel damage considering the following:

(a) Protection and use of personnel assets (b) Communications (c} Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders Renewed License No. DPR-51 Amendment No. 24-5, Revised by letter dated July 18, 2007

(10) Upon implementation of Amendment 239 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4, in accordance with Specifications 5.5.5.c.(i),

5.5.5.c.(ii), and 5.5.5.d, shall be considered met. Following implementation:

1. The first performance of SR 3.7.9.4, in accordance with Specification 5.5.5.c.(i), shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii), shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

3. The first performance of the periodic measurement of CRE pressure, Specification 5.5.5.d, shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

3. This renewed license is effective as of the date of issuance and shall expire at midnight, May 20, 2034.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by:

Jon R. Johnson Jon R. Johnson, Acting Director Office of Nuclea( Reactor Regulation

Attachment:

Appendix A - Technical Specifications and

• Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20, 2001 Renewed License No. DPR-51 Amendment No. ~.

Re\'ised by letter dated July 18, 2007

~Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One

. 1CAN051602 May 19, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Update to Tables S-1 and S-2 Adoption of National Fire Protection Association Standard NFPA-805 Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

By letter dated Jan*uary 29, 2014 (Reference 1), Entergy Operations, Inc. (Entergy) submitted a request to amend the Arkansas Nuclear One, Unit 1 (AN0-1) Technical Specifications (TS) and licensing bases to comply with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." The amendment request followed Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)." This submittal described the methodology used to demonstrate compliance with, and transition to, National Fire Protection Association (NFPA)-805, and included regulatory evaluations, PRAs, change evaluations, proposed modifications for non-compliances, and supporting attachments.

Entergy notified the NRC in a conference call on May 12, 2016, at 1430 eastern time, of plans to revise the wording previously proposed in certain Plant Modification and Implementation Items contained in Attachment S, Tables S-1 and S-2, of the original amendment request, as updated by letter dated March 25, 2016 (Reference 16).

Entergy proposes clarifications to Table S-1, Plant Modifications, Items S1-2, S1-3, S1-5, S1-6, and S1-23. Medification items S1-2, S1-3, S1-5, and S1-6 involve installation of an alternate control power source for non-vital 4160 V switchgear A 1 and A2, and non-vital 6900 V switchgear H1 and H2. The current wording includes Entergy's plan to install a "redundant" power source when the alternate power source will be "diverse" only, not redundant. Therefore, the "redundant" terms are replaced with the term "diverse". The final risk quantifications provided in the latest Attachment W (Reference 16) are not impacted by the proposed wording change as the original PRA credited only a diverse means of supplying control power to the respective switchgear. The source of this diverse power has remained unchanged since original conception.

1CAN051602 Page 2 of 5 Table 8-1, Item 81-23, is revised to clarify that modification of the subject Reactor Building purge valve will prevent spurious "opening" of the valve vice spurious "operation," consistent with the wording which follows in the "Proposed Modification" column of the table. Closure of this valve is a conservative measure (provides for Reactor Building isolation) and, therefore, spurious closure need not be addressed, nor does valve closure impact the final risk quantifications provided in the latest Attachment W (Reference 16). Note that operation of the Reactor Building purge system is not an AN0-1 credited safety function; however, isolation of the system (valves closed) is credited as a Reactor Building* isolation function. This change is for clarification purposes only and does not impact the original assumptions associated with the AN0-1 transition to NFPA-805.

With respect to Table 8-2, Implementation Items, one sentence of Implementation Item 82-9 is revised as follows:

The wording proposed in Entergy by letter dated March 25, 2016 (Reference 16):

If the as-built change-in-risk from each modification or implementation item, including the procedure changes in Implementation Item 82-6, exceeds RG 1.205 acceptance criteria, the results shall be entered into the corrective action program to evaluate the cause of risk increase and determine appropriate resolution.

New proposed wording:

The PRA review plan will ensure the as-built change-in-risk, including the procedure changes in Implementation Item 82-6, does not exceed the RG 1.205 acceptance criteria,

• and if it does, the cause of the risk increase will be evaluated and an appropriate resolution will be identified to verify that the acceptance guidelines are met.

Entergy's March 25, 2016 (Reference 16) letter included an update to Table 8-1 which identified those items which have been complete to date (Items 81-9, 81-12, 81-13, 81-14, 81-27, 81-28, 81-29, 81-30, 81-32, and 81-33). No additional Table 8-1 items.have completed since the Reference 16 submittal; however, Table 8-2, Implementation Items 82-3, 82-7, and 82-8 have been completed and Table 8-2 updated accordingly (see Attachment 1 of this letter).

To accommodate the above changes, a revised Attachment 8, "Modifications and Implementation Items," which contains the updated Tables 8-1 and 8-2, is included in Attachment 1 of this letter. Because the planned modifications and implementation items are.

• 'required to be completed as part of the AN0-1 transition to NFPA-805, revised markup and clean copies of the affected Operating License pages are included in Attachments 2 and 3 of this letter, respectively. Although no changes were made to the previously proposed Page 8 of the Operating License, all Operating License pages provided in the original license amendment request (LAR) (Reference 1) as updated by Entergy letter dated March 25, 2016 (Reference 16) are included in this submittal for completeness. Entergy requests the NRC to replace the respective Operating License pages submitted in letter dated March 25, 2016 (Reference 16) with those attached to this letter.

1CAN051602 Page 3 of 5 Section 2.c(8) of the Operating License is also revised to add the following sentence at the end of the first bullet under the heading "Other Changes that may be Made Without Prior NRC Approval," to be consistent with the NFPA 805 Operating License approved previously for ANO, Unit 2:

This License Condition does not apply to any demonstration of equivalency under Section 1. 7 ofNFPA 805.

The information, as detailed in this letter, with respect to the original Entergy request (Reference 1) has been reviewed and Entergy has determined that the information does not invalidate the no significant hazards consideration included in the Reference 1 letter.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this application is being provided to the designated Arkansas state official.

This letter contains no new commitments.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 19, 2016.

• JGB/dbb Attachments:

1. Updated Attachment S - Modifications and Implementation Items

2. Updated Mark-up of Enclosure 2 Operating License Pages

3. Updated Enclosure 3 Revised Operating License Pages

1CAN051602 Page 4 of 5 cc: Mr. Marc L. Dapas 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. 0. Box 310 London, AR 7284 7 U.S. Nuclear Regulatory Commission Attn: Mr. Stephen Koenick MS 0-8B1A One White Flint North 11555 Rockville Pik~

Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

REFERENCES:

1*. ' . . . .. '~"'*' ~*. l ~ ' '; *, . ,

1. Entergy letter dated January 29, 2014, License Amendment Request to AdoptNFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (1 CAN011401) (ML14029A438)

2. NRC letter dated May 5, 2015, Arkansas Nuclear One, Unit 1 - Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC No. MF3419) (1 CNA051501) (ML15091A431)

3. Entergy letter dated May 19, 2015, Response to Request for Additional Information -

Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN051501)

(ML15139A196)

4. Entergy letter dated June 16, 2015, 60-Day Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN061501) (ML15167A503)

5. Entergy letter dated July 21, 2015, 90-Day Response to Request for Additional Information

- Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN071501)

(ML15203A205)

6. Entergy letter dated August 12, 2015, 120-Day Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN081501) (ML15224A729)

1CAN051602 Page 5 of 5 REFERENCES (continued):

7. NRC email dated September 8, 2015, Arkansas Nuclear One, Unit 1 - 2nd Round Request for Additional Information - AN0-1 NFPA-805 LAR (TAC No. MF3419) (1 CNA091501)

(ML15251A220)

8. Entergy letter dated September 22, 2015, Round 2 Response to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1 CAN091501) (ML15265A113)

9. NRC email dated October 6, 2015, Arkansas Nuclear One, Unit 1 - 2nd Round Part 2 Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419)

(1CNA101501) (ML15280A114)

10. Entergy letter dated November 4, 2015, Second Set of Round 2 Responses to Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1.CAN111501) (ML15308A452)

11. Entergy letter*dated November 17, 2015, Clarification of Response to Round 2 Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN111502) (ML15321A076)

12. NRC email dated January 12, 2016, Arkansas Nuclear One, Unit 1-3'd Round Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419) (1CNA011601)

(ML16012A049)

13. Entergy letter dated January 15, 2016, Response to Round 3 Request for Additional Information - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN011601) (ML16015A421)

14. NRC email dated February 3, 2016, Arkansas Nuclear One, Unit 1 - PRA Integrated Analysis Request for Additional Information -AN0-1 NFPA-805 LAR (TAC No. MF3419)

(1CNA021601)

15. NRC email dated March 10, 2016, Arkansas Nuclear One, Unit 1 - 4th Round Request for Additional Information - AN0-1 NFPA-805 LAR - TAC No. MF3419 (1 CNA031601)

(ML16070A131)

16. Entergy letter dated March 25, 2016, Response to PRA RAJ 03 - Adoption of National Fire Protection Association Standard NFPA-805 (1CAN031602) (ML16088A299)

17. Entergy letter dated April 7, 2016, Response to PRA RAJ 19 -Adoption of National Fire Protection Association Standard NFPA-805 (1CAN041601) (ML16099A057)

\ .

Attachment 1 to 1CAN051602 Updated Attachment S - Modifications and Implementation Items

Arkansas Nuclear One - Unit 1 Att. 5 - Modifications and Implementation Items

5. 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. to 1CAN011401 Page 5-1

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-1 High New Auxiliary Feedwater (AFW) ANO plans a modification to install a Yes Yes This AFW modification is credited (PRA) pump: new AFW pump (common globally from a PRA perspective to Due to multiple impacts to the feedwater system for both units) and provide a reliable additional source Emergency Feedwater (EFW) associated motor operated valves of feedwater.

system, the need for an additional with diverse power sources and The lotal control panel modification source of feedwater to the Steam controls independent of the existing is also credited from a PRA Generators (SGs) was identified. EFW pumps. The pump will be perspective to provide an alternate capable of feeding either SG The means to perform required actions LAR Source: new AFW pump will be designed to outside the AN0-1 Control Room.

Attachment C, listed as a global meet or exceed the flow modification to reduce risk requirements of the AN0-1 EFW Manual actions are credited in fire pump P-78. areas that contain redundant safe shutdown equipment. The The new AFW pump proposed modification process will ensure design includes: these actions are feasible.

The capability to be operated Compensatory measures have from the AN0-1 Control been established until compliance Room and locally. can be achieved by transitioning to Electrical isolation from a 10 CFR 50.48(c) licensing basis.

Control Room functions to prevent a fire in the Control Room from affecting local control of AFW components.

Local controls and monitoring instrumentation to ensure proper operation and water flow to the SG. to1CAN011401 Page S-2

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 81-2 High Switchgear A-1: ANO plans a modification to install a Yes Yes This modification is credited (PRA) In multiple fire areas, a loss of diverse DC control power supply to globally from a PRA perspective.

normal DC control power could switchgear A-1 to eliminate loss of Installation of an alternate A-1 result in a loss of switchgear A-1. switchgear due to loss of normal DC switchgear DC control power control power. In the event the source reduces the rtsk of a fire LAR Source:

normal DC control power source is induced A-1 DC control power Attachment C, listed as a global lost, an automatic transfer to this cable failure causing a loss of modification to reduce rtsk alternate DC power source will offsite power.

occur.

In accordance with station The modification for the backup or directives, compensatory alternate DC power source will add measures per OP-1003.014 have a battery eliminator which is been established as approprtate.

supplied from either an AN0-1 or AN0-2 non-1 E source via an automatic transfer switch.

Installation of automatic transfer switches, cables and electrical conduit is proposed.

S1-3 High Switchgear A-2: ANO plans a modification to install a Yes Yes This modification is credited (PRA) In multiple fire areas, a loss of diverse DC control power supply to globally from a PRA perspective.

normal DC control power could switchgear A-2 to eliminate loss of Installation of an alternate A-2 result in a loss of switchgear A-2 switchgear due to loss of normal DC switchgear DC control power control power. In the event the source reduces the risk of a fire LAR Source: normal DC control power source is induced A-2 DC control power Attachment C, listed as a global lost, an automatic transfer to this cable failure causing a loss of modification to reduce rtsk alternate DC power source will offsite power.

occur.

In accordance with station The modification for the backup or directives, compensatory alternate DC power source will add measures per OP-1003.014 have a battery eliminator which is been established as approprtate.

supplied from either an AN0-1 or AN0-2 non-1 E source via an automatic transfer switch.

Installation of automatic transfer switches, cables and electrical conduit is proposed. to 1 CAN011401 Page S-3

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-4 Med Switchgear A-3: ANO plans a modification to install a Yes Yes This modification is credited for (PRA) In Fire Area 1-2, loss of DC control second diverse cable route to the Fire Area 1-2.

power to 4160kV switchgear A-3 A-3 DC control power. An In conjunction with the could result in the loss of control auctioneering feature will be modifications described in items functions for Primary Makeup employed such that a fire induced S1-2, S1-25, and S1-26, the Pump (P-36A), EFW pump failure in a single fire zone will not second diverse cable route (P-78), Service Water (SW) pump render the DC control function reduces the risk of a fire induced P-4A. unavailable. circuit failure of the switchgear and LAR Source: Routing of the second red train A-3 the possible loss of control switchgear room DC power cables functions to pumps P-36A, P-78, Attachment C, Fire Area 1-2 Risk outside the green train A-4 and P-4A.

Summary, VFDR 12-01-b, switchgear equipment room in Fire In accordance with station VFDR 12-02-a, and VFDR 12-03-c Area 99-M is planned. directives, compensatory The new second cable route is measures per OP-1003.014 have expected to impact Fire Zones 100-N, been established as appropriate.

197-X, 161-8, 159-8, 67-U, and 110-L.

The proposed scheme will also ensure availability of the A-3 DC control power should there be a fire in Fire Zones 67-U or 98-J. to1CAN011401 Page 5-4

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-5 High Switchgear H-1: ANO plans a modification to install a Yes Yes The modification to install a diverse (PRA) In multiple fire areas, the loss of diverse DC control power supply to DC control power supply is normal DC control power to H-1 switchgear to eliminate loss of credited globally from a PRA switchgear H-1 could preclude the switchgear due to loss of normal DC perspective.

Reactor Coolant Pumps (RCPs) control power. The modification to separate line from being tripped in the Control Additionally, ANO plans a and load breaker control power is Room. modification to remove internal DC only credited in Fire Area LAR Source: jumpers and separately protect H-1 B-1@BOFZ.

switchgear line and load breaker Both modifications reduce the risk Attachment C, listed as a global control power. This will prevent a of a fire induced circuit failure to modification to reduce risk, fire originating in a cubicle from VFDR B-1@BOFZ-04, the DC power cables feeding disabling the ability to trip the RCPs switchgear H-1, which could VFDR F-02, VFDR 11-04, and due to loss of shared control power.

VFDR 0-01 preclude tripping the RCPs from the Control Room.

In accordance with station directives, compensatory measures per.OP-1003.014 have been established as appropriate.

S1-6 High Switchgear H-2: ANO plans a modification to install a Yes Yes The modification to install a diverse (PRA) In multiple fire areas, the loss of diverse DC control power supply to DC control power supply is normal DC control power to H-2 switchgear to eliminate loss of credited globally from a PRA switchgear H-2 could preclude the switchgear due to loss of normal DC perspective.

RCPs from being tripped in the control power. The modification to separate line Control Room. Additionally, ANO plans a and lo.ad breaker control power is LAR Source: modification to remove internal DC only credited in Fire Area jumpers and separately protect H-2 B-1@BOFZ.

Attachment C, listed as a global switchgear line and load breaker Both modifications reduce the risk modification to reduce risk, VFDR control power. This will prevent a B-1@BOFZ-04, VFDR F-02, of a fire induced circuit failure to fire originating in a cubicle from the DC power cables feeding VFDR 11-04, and VFDR 0-01 disabling the ability to trip the RCPs switchgear H-2, which could due to loss of shared control power. preclude tripping the RCPs from the Control Room.

In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate. to1CAN011401 Page 5-5

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-7 Med A-309, 4160V AC Breaker: ANO plans to modify circuits for Yes Yes This modification is credited from a (PRA) In Fire Area B-1@BOFZ, a fire breaker A-309 to assure the PRA perspective in Fire Area induced fault in the turbine protective features remain intact, B-1@BOFZ.

building could result in spurious i.e., breakers remain tripped and do Modification to the circuits closing or preclude automatic trip not impede automatic start of the associated with breaker A-309 is functions at A-309 (vital associated EDG and associated planned to assure the protective switchgear A-3 supply breaker closure of EDG output breaker features remain intact, i.e., breaker from switchgear A-1) that could A-308. remains tripped and does not challenge the automatic start of impede automatic start of the the credited Emergency Diesel associated EDG and closure of Generator (EDG). EDG output breaker (A-308).

LAR Source: In accordance with station Attachment C, Fire Area directives, compensatory B-1@BOFZ Risk Summary, measures per OP-1003.014 have VFDR B-1@BOFZ-01 been established as appropriate.

S1-8 Med A-409, 4160V AC Breaker: ANO plans to modify circuits for Yes Yes This modification is credited from a (PRA) In Fire Area B-1@BOFZ, a fire breaker A-409 to assure the PRA perspective in Fire Area induced fault in the turbine protective features remain intact, B-1@BOFZ.

building could result in spurious i.e., breakers remain tripped and do Modification to the circuits closing or preclude automatic trip not impede automatic start of the associated with breaker A-409 is functions at A-409 (vital associated EDG and associated planned to assure the protective switchgear A-4 supply breaker closure of EDG output breaker features remain intact, i.e., breaker from switchgear A-2) that could A-408. remains tripped and does not challenge the automatic start of impede automatic start of the the credited EDG. associated EDG and closure of LAR Source: EDG output breaker (A-408).

Attachment C, Fire Area In accordance with station B-1@BOFZ Risk Summary, directives, compensatory VFDR B-1@BOFZ-01 measures per OP-1003.014 have been established as appropriate. to1CAN011401 Page S-6

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-9 Med Control Room Cabinet C20: ANO has installed a smoke detector Yes Yes This modification is credited from a (PRA) In Fire Area G, Fire Zone 129-F, in AN0-1 Control Room Cabinet PRA perspective in Fire Area G.

PRA determined that the C20 in accordance with the The modification to install a smoke installation of smoke detector(s) in NFPA 72, Fire Alarm Detection, detector system in AN0-1 Control Control Room Cabinet C20 will code of record. The new smoke Room Cabinet C20 reduces the reduce risk of a fire induced circuit detector loop is connected via signal risk of a fire induced circuit and and equipment failure. cable to the AN0-1 Control Room equipment failure that could result Fire Alarm Panel C-463 for trouble in the loss of Control Room LAR Source:

and alarm functions. Cabinet C20.

Attachment C, Fire Area G Risk Summary In accordance with station directives, compensatory measures per OP-1003.014 have been established as appropriate.

S1-10 Med Air Operated Valve (AOV) ANO plans a modification to add an Yes Yes This modification is credited from a (PRA) CV-1052: automatic feature to prevent PRA perspective in Fire Area G.

In Fire Area G, PRA determined solenoid or electro-pneumatic valve This modification reduces the risk that Quench Tank drain valve positioner from opening CV-1052 as of fire induced AOV circuit failures CV-1052 control circuit should be a result of a fire induced circuit (hot shorts, open circuits, and short modified to preclude spurious failure in the Control Room. to ground) and can preclude operation. CV-1052 control circuit spurious operation.

does not have automatic features In accordance with station via interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-7

Arkansas Nuclear One - Unit 1 Att. 5 - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-11 Med Motor Operated Valve (MOV) ANO plans to modify CV-1053 by Yes Yes This modification is credited from a (PRA) CV-1053: adding an "inhibit" circuit which will PRA perspective in Fire Area G.

In Fire Area G, PRA determined preclude spurious opening of the This modification reduces the risk that Quench Tank drain valve MOV due to intercable or intracable of fire induced MOV hot short CV-1053 should be modified to hot shorts. circuit failure and will preclude preclude spurious operation. spurious operation.

CV-1053 does not have automatic In accordance with station features via interlocks to preclude directives, compensatory spurious operation to reduce measures per OP-1003.014 have overall plant risk as a result of a been established as appropriate.

fire induced circuit failure.

LARSource:

Attachment C, Fire Area G Risk Summary S1-12 High MOVCV-1221: ANO has modified CV-1221 to meet Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined the requirements of IN 92-18. PRA perspective in Fire Area G.

that Letdown isolation valve This modification added an "inhibit" The modification reduces the risk CV-1221 should be modified to circuit which will preclude spurious of fire induced MOV hot short meet requirements per IN 92-18. opening of the MOV due to circuit failure and will preclude CV-1221 does not have automatic intercable or intracable hot shorts. spurious operation.

features via interlocks to preclude The circuit modification incorporated In accordance with station spurious operation to reduce an available spare conductor in an directives, compensatory overall plant risk as a result of a existing cable between the Control measures per OP-10'03.014 have fire induced circuit failure. Room cabinet and the 480 V MCC. been established as appropriate.

LAR Source:

Attachment C, Fire Area G Risk Summary, VFDR G-02-a to 1CAN011401 Page 5-8

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 81-13 High MOV CV-1405: ANO has modified CV-1405 to meet Yes Yes This modification is credited (PRA) In multiple fire areas, PRA the requirements of IN 92-18. globally from a PRA perspective.

determined that Train A This modification added an "inhibit" This modification reduces the risk Emergency Core Cooling (ECCS) circuit which will preclude spurious of fire induced MOV hot short Reactor Building sump suction opening of the MOV due to circuit failure and will preclude valve CV-1405 should be intercable or intracable hot shorts. spurious operation.

modified to meet requirements of The circuit modification incorporated In accordance with station IN 92-18. CV-1405 does not have an available spare cable for the directives, compensatory automatic features via interlocks conductor needed between the measures per OP-1003.014 have to preclude spurious operation to Control Room cabinet and the 480 V been established as appropriate.

reduce overall plant risk as a MCC.

result of a fire induced circuit failure.

LAR Source:

Attachment C, listed as a global modification to reduce risk, VFDR B173-02-b, VFDR B8SEPR-03-b, VFDR C-01-b, and VFDR G-02-c S1-14 High MOV CV-1406: ANO has modified CV-1406 to meet Yes Yes This modification is credited (PRA) In multiple fire areas, PRA the requirements of IN 92-18. globally from a PRA perspective.

determined that Train B ECCS This modification added an "inhibit" This modification reduces the risk Reactor Building sump suction circuit which will preclude spurious of fire induced MOV hot short valve CV-1406 should be opening of the MOV due to circuit failure and will preclude modified to meet reqyirements of intercable or intracable hot shorts. spurious operation.

IN 92-18. CV-1406 does not have The circuit modification incorporated In accordance with station automatic features via interlocks an available spare cable for the directives, compensatory to preclude spurious operation to conductor needed between the measures per OP-1003.014 have reduce overall plant risk as a Control Room cabinet and the 480 V been established as appropriate.

result of a fire induced circuit MCC.

failure.

LAR Source:

Attachment C, listed as a global .

modification to reduce risk, VFDR B-1@120-03-d, VFDR G-02-c, VFDR 11-03-c, and VFDR 13-03-e to1CAN011401 Page S-9

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-15 Not Used S1-16 Med AOV CV-4400: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-4400 by adding an PRA perspective in Fire Area G.

that Reactor Building sump drain "inhibit" circuit which will preclude This modification reduces the risk valve CV-4400 control circuit spurious opening of the AOV due to of fire induced AOV hot short should be modified to preclude intercable or intracable hot shorts. circuit failure and will preclude spurious operation. CV-4400 The circuit modification plan adds spurious operation.

control circuit does not have an automatic feature to prevent In accordance with station automatic features via interlocks to solenoid or electro-pneumatic valve directives, compensatory preclude spurious operation to positioner from opening CV-4400 as measures per OP-1003.014 have reduce overall plant risk as a result a result of a fire induced circuit been established as appropriate.

of a fire induced circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-17 Med MOV CV-4446: ANO plans to modify CV-4446 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building sump drain preclude spurious opening of the This modification reduces the risk valve CV-4446 should be MOV due to intercable or intracable of fire induced MOV circuit failures modified to preclude spurious hot shorts. (hot shorts, open circuits, and short operation. CV-4446 does not to ground) and will preclude have automatic features via spurious operation.

interlocks to preclude spurious In accordance with station operation to reduce overall plant directives, compensatory risk as a result of a fire induced measures per OP-1003.014 have circuit failure. been established as appropriate.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page 5-10

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-18 Med MOV CV-5611: ANO plans to modify CV-5611 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building firewater preclude spurious opening of the This modification reduces the risk valve CV-5611 should be MOV due to intercable or intracable of fire induced MOV hot short modified to preclude spurious hot shorts. circuit failure and will preclude operation. CV-5611 does not spurious operation.

have automatic features via In accordance with station interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary, S1-19 Med MOV CV-5612: ANO plans to modify CV-5612 by Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined adding an "inhibit" circuit which will PRA perspective in Fire Area G.

that Reactor Building firewater preclude spurious opening of the This modification reduces the risk valve CV-5612 should be MOV due to intercable or intracable of fire induced MOV hot short modified to preclude spurious hot shorts. circuit failure and will preclude operation. CV-5612 does not spurious operation.

have automatic features via In accordance with station interlocks to preclude spurious directives, compensatory operation to reduce overall plant measures per OP-1003.014 have risk as a result of a fire induced been established as appropriate.

circuit failure.

LAR Source:

Attachment C, Fire Area G Risk Summary to 1CAN011401 Page S-11

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-20 Med AOV CV-7401: ANO plans lo modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7401 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7401 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7401 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature lo prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation lo reduce overall plant positioner from opening CV-7401 as measures per OP-1003.014 have risk as a 'result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-21 Med AOV CV-7402: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7402 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7402 control circuit should be spurious opening of the AOV due to offire induced AOV hot short modified lo preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7402 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks lo preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening CV-7402 as measures per OP-1003.014 have risk as a result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-12

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table 5-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-22 Med AOV CV-7403: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit for CV-7403 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7403 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7403 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening CV-7403 as measures per OP-1003.014 have risk as a result of a fire induced a result of a fire induced circuit been established as appropriate.

circuit failure. failure in the Control Room.

LAR Source:

Attachment C, Fire Area G Risk Summary S1-23 Med AOV CV-7404: ANO plans to modify the control Yes Yes This modification is credited from a (PRA) In Fire Area G, PRA determined circuit of CV-7404 by adding an PRA perspective in Fire Area G.

that Reactor Building purge valve "inhibit" circuit which will preclude This modification reduces the risk CV-7404 control circuit should be spurious opening of the AOV due to of fire induced AOV hot short modified to preclude spurious intercable or intracable hot shorts. circuit failure and will preclude operation. CV-7404 control circuit The circuit modification plan adds spurious operation.

does not have automatic features an automatic feature to prevent In accordance with station via interlocks to preclude spurious solenoid or electro-pneumatic valve directives, compensatory operation to reduce overall plant positioner from opening AOV valve measures per OP-1003.014 have risk as a result of a fire induced CV-7404 as a result of a fire been established as appropriate.

circuit failure. induced circuit failure in the Control LAR Source: Room.

Attachment C, Fire Area G Risk Summary to1CAN011401 Page S-13

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-24 Med SW Pump P-4A: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reconfigure the circuit that supports PRA perspective in Fire Area 1-2.

may cause a loss of SW pump remote operation of SW pump P-4A. This modification to reconfigure the P-4A. Circuits are planned to be P-4A circuit reduces the risk of a LAR Source: reconfigured to avoid Fire Area 1-2. fire induced circuit failure.

Any new raceway or cables needed In accordance with station Attachment C, Fire Area 1-2 Risk for these circuits will be installed directives, compensatory Summary, VFDR 12-02-a outside of any zone of influence for measures per OP-1003.014 have postulated fire sources or routed in been established as appropriate.

locations where deterministic compliance can be demonstrated.

S1-25 Med EFW Pump P-78: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reroute cables that support remote PRA perspective in Fire Area 1-2.

may result in loss of EFW pump operation of P-78. This modification to reroute cables P-78. Circuits are planned to be rerouted reduces the risk of a fire induced LARSource: to avoid Fire Area 1-2 using circuit failure.

embedded conduit as available or In accordance with station Attachment C, Fire Area 1-2 Risk routed in raceways that already Summary, VFDR 12-01-b directives, compensatory contain other cables that would measures per OP-1003.014 have impact P-78. 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. to 1CAN011401 Page S-14

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-26 Med Primary Makeup Pump P-36A: ANO plans a circuit modification to Yes Yes This modification is credited from a (PRA) In Fire Area 1-2 circuit impacts reconfigure cables that support PRA perspective in Fire Area 1-2 may result in a loss of Primary remote operation of P-36A. This modification to reconfigure the Makeup pump P-36A. P-36A circuits are planned to be P-36A circuits reduces the risk of a LAR Source: reconfigured to avoid Fire Area 1-2. fire induced circuit failure.

Any new raceway or cables needed In accordance with station Attachment C, Fire Area 1-2 Risk for these circuits will be installed Summary, VFDR 12-03-c directives, compensatory outside of any zone of influence for measures per OP-1003.014 have postulated fire sources or routed in been established as appropriate.

locations where deterministic compliance can be demonstrated.

S1-27 High Sluice Gate Valve SG-1: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-1 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closirig as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-1 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-1 to reduce overall plant risk for SG-1 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR B-1@120-02-c and VFDR C-03-e to1CAN011401 Page S-15

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-28 High Sluice Gate Valve SG-2: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-2 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-2 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-2 to reduce overall plant risk for SG-2 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LARSource: an available spare conductor in an directives. compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR G-05-a S1-29 High Sluice Gate Valve SG-3: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-3 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve induced circuit failure. This modification removes the SG-3 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-3 to reduce overall plant risk for SG-3 operation to reduce overall plant remain open ih all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios. failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk to 1CAN011401 _Page 5-16

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-30 High Sluice Gate Valve SG-4: ANO has modified Sluice Gate valve Yes Yes This modification is credited (PRA) SG-4 to remove the potential for globally from a PRA perspective.

In multiple fire areas, PRA spurious closing as a result of a fire determined that Sluice Gate valve This modification removes the induced circuit failure.

SG-4 should be modified to potential of spurious operation to remove the potential of spurious The modification allows SG-4 to reduce overall plant risk for SG-4 operation to reduce overall plant remain open in all PRA fire as a result of a fire induced circuit risk as a result of a fire induced scenarios failure.

circuit failure. The circuit modification incorporated In accordance with station LAR Source: an available spare conductor in an directives, compensatory existing cable between the Control measures per OP-1003.014 have Attachment C, listed as a global Room cabinet and the 480 V MCC. been established as appropriate.

modification to reduce risk, VFDR G-05-a to1CAN011401 Page S-17

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-31 High c NFPA 805 non-compliance issues ANO plans to provide an adequate- Yes Yes This modification will be completed (PRA) were encountered when smaller for-the-hazard evaluation and if to meet NFPA 805 code fire area were defined such that necessary a modification to upgrade requirements.

multiple walls, dampers, fire barrier walls, dampers, In accordance with station penetration seals, and doors were penetration seals, and doors to directives, compensatory credited and used in the Fire PRA rated barriers for those barriers measures per OP-1003.014 have model as rated fire barriers in the credited for deterministic been established as appropriate.

NRG regulatory basis for compliance and subsequently NFPA 805. credited in the Fire PRA analysis.

Multiple walls and doors barriers These fire barriers below have been will require upgrading to comply previously identified as NRG with NFPA 805. regulatory basis to ensure LAR Source: compliance with NFPA 805 and have compensatory measures Attachment A, Section 3.11.2 established.

Fire barriers to be addressed as identified by EG-1956 are: 15-5, 15-4, 39-5, 44-2, 45-2, 46-4, 64-3, 67-4, 70-7, 72-5, 73-5, 75-2, 75-3, 75-4, 76-2, 76-3, 77-2, 78-2, 79-6, 81-4, 81-6, 81-7, 82-2, 88-1, 88-3, 88-5, 89-1, 89-5, 90-2, 90-4, 93-4, 101-5, 103-2, 103-4, 104-2, 105-2, 120-5, 121-1, 122-5, 123-1, 125-1, 143-1, 144-2, 144-3, 144-5, 144-6, 147-4, 149-2, 162-3, 162-4, 162-5, 170-1, 183-4, and 183-5. to1CAN011401 Page 5-18

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items 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 has modified the ventilation for No No The subject hydrogen gas system (Code) Systems. code non-compliance the Hydrogen Bottle Storage area to bottle storage area is not credited issues were identified in the ensure compliance with NFPA 50A. by the PRA.

Hydrogen Gas Bottle Storage In addition, electrical equipment and This modification has been Room related to inadequate vent wiring changes were made to meet completed to meet NFPA 50A code piping and room ventilation. The the requirements of NFPA 70 requirements.

hydrogen storage room light (NEC), Article 501 for Class I, Compliance with this code is not switch was identified as not Division 2.

part of the current licensing basis, meeting Article 501 for Class I, therefore, no compensatory Division 2 locations of the measures were needed.

National Electric Code (NEC).

LAR Source:

Attachment A, Section 3.3.7.1 S1-33 Low c NFPA 10, Fire Extinguishers, ANO has resolved NFPA 10 No No The subject fire extinguishers are (Code) code non-compliance issues deficiencies identified in not credited in the PRA.

(such as incorrect number of fire CALC-ANOC-FP-09-00009. This modification has been extinguishers for travel distance, In general, this modification involved completed to meet NFPA 10 code and incorrect type and size for the portable fire extinguisher physical requirements.

hazard area) were identified with relocation, substitution of existing Compliance with this code is not ANO portable fire extinguishers. extinguishers, and documentation part of the current licensing basis, LAR Source: updates to reflect these plant therefore, no compensatory Attachment A, Section 3.7 changes. The proper number of fire measures were needed.

extinguishers that meet travel distance requirements in coverage areas, adequately sized fire extinguishers, and the correct type of extinguisher that is rated for the fire hazard in each area have been installed. to 1CAN011401 Page S-19

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-34 Cabinet C539: ANO plans a modification to rework Yes Yes This modification is credited from a In Fire Area 1-1. impacts against the power circuits from panel RS-1 PRA perspective in Fire Area 1-1 the power supply for EFIC Signal to C539 that will eliminate the This modification removes the Conditioning Cabinet C539 can impacts in Fire Area 1-1. potential of a loss of result in a loss of instrumentation instrumentation as a result of fire and the operator cues necessary induced circuit failure.

for post fire shutdown. In accordance with station LAR Source: directives, compensatory Attachment C, Fire Area 1-1 Risk measures per OP-1003.014 have Summary, VFDR 11-05-a been established as appropriate.

S1-35 Med Non Power Operation (NPO) ANO plans a modification for No Yes The NPO modification reduces the (92-18) MOVs CV-1050, CV-1410, CV-1404 to meet the requirements risk of fire induced MOV circuit CV-1404: of IN 92-18. failures (hot shorts, open circuits, AN0-1 has no redundancy to the This modification adds an "inhibit" and short to ground). This MOV single Reactor Coolant System circuit which will preclude spurious modification can prevent a non-(RCS) drop line to the Decay Heal closing of the MOV due to intercable recoverable position failure Removal (OHR) system with three or intracable hot shorts. resulting in the loss of OHR.

in-series valves CV-1050, Procedural changes are planned to In accordance with station CV-1410, and CV-1404. The secure MOVs CV-1050 and directives, compensatory NPO assessment determined that CV-1410 in the open position by measures per OP-1003.014 have any one of the three RCS drop opening breakers to remove power. been established as appropriate.

line valves could fail in a closed and unrecoverable position resulting in a loss of DHR.

LAR Source:

Attachment D, VFDR NPO-RCS-DHR to1CAN011401 Page S-20

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table 5-1 Plant Modifications In Comp Item Rank Unit Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure S1-36 High NFPA 13, Standard for the ANO plans to provide a modification Yes Yes These modifications will be (PRA) Installation of Sprinkler Systems to physically relocate/rework completed to meet NFPA 13 (1971 Edition). code non- existing sprinklers, add sprinklers, requirements.

compliance issues were identified add or rework hangers and fire The Fire PRA model credited the in CALC-AN01-FP-09-00007, protection branch line piping, and non-compliant sprinkler systems in Rev. 1, Unit 1 Electrical add sprinkler deflectors to resolve the fire areas to reduce the risk in Penetration. These non- non-compliant code issues and the hot gas layer (HGL) and multi-compliance issues are allowable meet NFPA 13 requirements. component analysis (MCA) sprinkler spacing exceeded and scenarios. The sprinkler systems obstructions blocking sprinkler were not designed or installed for spray patterns located in the full sprinkler coverage in these fire Upper (South and North) areas.

Electrical Penetration Rooms and In accordance with station Lower (South and North) directives, compensatory Electrical Penetration Rooms.

measures per OP-1003.014 have LAR Source: been established as appropriate.

Attachment A, Section 3.9.1 (1) to 1CAN011401 Page S-21

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-2 items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program.

Table S-2 Implementation Items Item Unit Description LAR Section I Source S2-1 C Develop a monitoring program required by NFPA 805 that will include a process to monitor and trend LAR Section 4.6 and Attachment A, the fire protection program based on specific goals established to measure effectiveness. Section 3.2.3 (3) s2-2* Revise or develop fire protection flushing activity to perform fixed water spray system flushing and Attachment A, Section 3.9.1 (2) drainage of underground lead-in connections in accordance with NFPA 15, 1977 Edition Code.

S2-3 c Entergy has revised appropriate fire protection administrative procedures to include the following: Attachment A, Section 3.3.1.2 (5)

In accordance with FAQ 06-0020, the term "applicable NFPA Standards" is considered to be equivalent to those NFPA Standards identified in the current licensing basis (CLB) for existing procedures and systems in the fire protection program that are transitioning to NFPA 805.

New Fire Protection Systems would be subject to the most current code or standard.

Terminology for zero transient combustibles and changes needed to support Fire PRA assumptions.

S2-4 Revise existing procedure(s) or develop new procedure(s) for NPO required to transition to NFPA 805 Attachment D, VFDR NPO-based upon insights gained from AN0-1 NPO calculation. Procedure S2-5 Revise operator manual action (OMA) procedures/documents to include feasibility criteria in Attachment G, Step 4 FAQ 07-0030 for the recovery actions listed in Table G-1 of Attachment G, Recovery Action Transition.

S2-6 c Develop or revise technical documents and procedures that relate to new Fire Protection design and LAR Sections 4.7.1, 4.7.2, and licensing basis (e.g., ANO Fire Protection Program, OP-1003.014, Technical Requirements Manual, 4.7.3, Attachment E Table E-1 Design Basis Document, Pre-Fire Plans, Maintenance and Surveillance Procedures, Configuration Control Program, Training and Qualification Guidelines, etc.) as required for implementation of NFPA 805.

S2-7 Entergy has completed a revision to CALC-ANOC-FP-09-00007 for NFPA 30 to update the code report Attachment A, Section 3.3.8 for Oil Tank T-25 dike/berm compliance and has performed an engineering evaluation for Oil Tank T-26 in tank vault, Fire Area B-1, Fire Zone 187 DD, with respect to the potential oil leakage path at the air supply duct location in the vault wall near the floor via the supply duct outside of the vault.

S2-8 Entergy has completed an evaluation which determined that Oil Tank T-29 supports are acceptable in Attachment A, Section 3.3.8 accordance with American Petroleum Institute (API) and National Fire Protection Association (NFPA) codes/standards, since T-29 supports documentation from construction is not available. Straps were added to provide additional assurance that the tank would remain in its saddle following a seismic event.

Enclosure 1 to 1CAN011401 Page S-22

Arkansas Nuclear One - Unit 1 Att. S - Modifications and Implementation Items Table S-2 Implementation Items Item Unit Description LAR Section I Source S~-9 Validate the change in risk by revising the FPRA model for each modification or implementation item LAR Section 4.8.2 completed that is credited either. directly or indirectly by f'RA. The PRA review plan will ensure the as-built change-in-risk, including the procedure changes in Implementation Item S2-6, does not exceed the RG 1.205 acceptance criteria, and if it does, the cause of the risk increase will be evaluated and an appropriate resolution will be identified to verify that the acceptance guidelines are met. The FPRA update will be performed in accordance with Entergy fleet PSA Maintenance procedure EN-DC-151, Section 5.2.

S2-10 Revise drawings and pre-fire plans for Fire Area 1-1, Fire Z:one 98-J corridor; since this wall will be Attachment C, FireArea 1*1 Fire credited by PRA as a radiant energy barrier Wall.with Door 57. PRA requires corridor to be divided or Zone 98-J split into two separate fire compartments at C-4 Line wall on EL 372. This division of the Fire Zone 98-J corridor will reduce the risk in the HGUMCA scenarios. to1CAN011401 Page S-23

Attachment 2 to 1CAN051602 Updated Mark-up of Enclosure 2 Operating License Pages

(8) Fire Protection Entergy Operations, Inc . ~ shall implement and maintain in effect all provisions of the approved f~ire pP.rotection pP.rogram as described in Appendix QA to the SAR and as approved in the Safety E>.1aluation dated March 31 , 1992, subject to the following provision :that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c) , as specified in the licensee amendment request dated January 29 , 2014 , and supplements dated May 19, 2015 , June 16, 2015 , July 21, 2015, August 12, 2015 ,

September 22 , 2015 , November 4, 2015 , November 17, 2015 , January 15, 2016 , March 25 , 2016 , April 7, 2016 , and May 19, 2016 , and as approved in the SE dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation , technical specification , license condition or requirement would require prior NRC approval ,

1. AP&L ~ may proceed 'Nith and is required to complete the modifications identified in Paragraphs 3.1 through 3.19 of the NRC's rire Protection Safety Evaluation on the facility dated August 22 ,

1978, and supplements thereto. These modifications shall be completed as specified in Table 3.1 of the Safety Evaluation Report or supplements thereto. In addition , the licensee may proceed 'Nith and is required to complete the modifications identified in Supplement 1 to the rire Protection Safety Evaluation Report, and any future supplements . These modifications shall be completed by the dates identified in the supplement.

2-:--------Tthe licensee may make changes to the approved f~ire pP.rotection pP.rogram without prior approval of the Commission GfH.y-if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c) , the change does not require a change to a technical specification or a license condition , and the criteria listed below are satisfiedwould not adversely affect the ability to achieve and maintain safe shutdmvn in the event of a fire .

Risk-Informed Changes that may be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach , methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated ; be based on the as-built, as-operated , and maintained plant; and reflect the operating experience at AN0-1. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRG through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments , or methods that have been demonstrated to bound the risk impact.

~ The Original licensee authorized to possess, use, and operate the facility was AP&L.

Consequently , certain historical references to AP&L remain in the license conditions.

Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation .

2. Prior NRC review and approval is not required for individual changes o-that result in a risk increase less than 1x1 7/year (yr) for CDF and less than 1x1 o-8 /yr for LERF . The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation .

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas :

1. Fire fighting response strategy with the following elements :

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel Moved to 2. Operations to mitigate fuel damage considering the following :

Page 7 (a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders 4- The Original licensee authorized to possess, use, and operate the facility was /\P&L.

Consequently, certain historical references to AP&L remain in the license conditions .

Renewed License No. DPR-51 Amendment No . ~ .

Revised by letter dated July 18, 2007

Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805 , Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805 , Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard . The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805 , Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard .

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard ." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805 , Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system , procedure , or physical arrangement, using a relevant technical requirement or standard . The four specific sections of NFPA 805 , Chapter 3, are as follows :

• Fire Alarm and Detection Systems (Section 3.8) ;

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9) ;

• Gaseous Fire Suppression Systems (Section 3.1O); and ,

• Passive Fire Protection Features (Section 3.11 ).

This License Cond ition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805 .

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated _ _ __ _

to determine that certain fire protection program changes meet the minimal criterion . The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-51 Amendment No. ~ .

Revised by letter dated July 18, 2007

Moved to _ _

Page 8 6

~~~~~---==========-~~~~-~-~~~~~~~~~~~~~~

,,.----- (10) Upon implementation of Amendment 239 adopting TSTF-448 , Revisio~

the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4 , in accordance with Specifications 5.5 .5.c.(i) ,

5.5.5.c.(ii), and 5.5.5.d, shall be considered met. Following implementation :

1. The first performance of SR 3.7.9.4 , in accordance with Specification 5.5.5 .c.(i) , shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii) , shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

3. The first performance of the periodic measurement of CRE pressure ,

Specification 5.5.5.d, shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

3. Th is renewed license is effective as of the date of issuance and shall expire at midnight, May 20, 2034 .

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by :

Jon R. Johnson Jon R. Johnson , Acting Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A - Technical Specifications and Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20 , 2001 Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c) , as specified by 2. below, risk-informed changes to the Entergy Operations , Inc.

fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility , as described in Table S-1 , "Plant Modifications," Attachment S, of Entergy Operations , Inc. letter 1CAN051602Ldated May 19, 2016 ,

prior to startup from the second refueling outage following issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of the modifications.

3. The licensee shall complete the implementation items as listed in Table S-2 , "Implementation Items," Attachment S, of Entergy Operations , Inc. letter 1CAN051602 , dated May 19, 2016 , within six months after issuance of the Safety Evaluation .

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas :

1. Fire fighting response strategy with the following elements :

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel From 2. Operations to mitigate fuel damage considering the following:

Page 5 (a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to on site responders Renewed License No. DPR-51 Amendment No. ~ .

Revised by letter dated July 18, 2007

From Page 6 ~~~~~--=========-~~~~-~-~~~~~~~~~~~~~~

,---- (10) Upon implementation of Amendment 239 adopting TSTF-448 , Revisio~

the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4, in accordance with Specifications 5.5.5 .c.(i) ,

5.5.5.c.(ii), and 5.5 .5.d, shall be considered met. Following implementation :

1. The first performance of SR 3.7.9.4 , in accordance with Specification 5.5.5.c.(i), shall be within 15 months of the approval of TSTF-448 . SR 3.0.2 will not be applicable to this first performance .

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii) , shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance .

3. The first performance of the periodic measurement of CRE pressure ,

Specification 5.5.5 .d, shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance .

3. This renewed license is effective as of the date of issuance and shall expire at midnight, May 20 , 2034.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by :

Jon R. Johnson Jon R. Johnson , Acting Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A - Technical Specifications and Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20 , 2001 Renewed License No. DPR-51 Amendment No . ~ .

Revised by letter dated July 18, 2007

Attachment 3 to 1CAN051602 Updated Enclosure 3 Revised Operating License Pages

(8) Fire Protection Entergy Operations, Inc. shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated January 29, 2014, and supplements dated May 19, 2015, June 16, 2015, July 21, 2015, August 12, 2015, September 22, 2015, November 4, 2015, November 17, 2015, January 15, 2016, March 25, 2016, April 7, 2016, and May 19, 2016, and as approved in the SE dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, Risk-Informed Changes that may be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at AN0-1. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specifiG license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x1 o-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-51 Amendment No. ~.

Revised by letter dated July 18, 2007

Other Changes that may be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.1 O); and,

' \

• Passive Fire Protection Features (Section 3.11 ).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated _ _ _ __

to determine that certain fire protection program changes meet the

• minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-51 Amendment N,a. ~.

Revised by letter dated July 1B, 2007

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified*

by 2. below, risk-informed changes to the Entergy Operations, Inc.

fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications," Attachment S, of Entergy Operations, Inc. letter 1CAN051602, dated May 19, 2016, prior to startup from the second refueling outage following issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of the modifications.

3. The licensee shall complete the implementation items as listed in Table S-2, "Implementation Items," Attachment S, of Entergy Operations, Inc. letter 1CAN051602, dated May 19, 2016, within six months after issuance of the Safety Evaluation.

(9) Mitigation Strategies The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas:

1. Fire fighting response strategy with the following elements:

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fig~ting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel

2. Operations to mitigate fuel damage considering the following:

(a) Protection and use of personnel assets (b) Communications (c} Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (g) Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders Renewed License No. DPR-51 Amendment No. 24-5, Revised by letter dated July 18, 2007

(10) Upon implementation of Amendment 239 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.9.4, in accordance with Specifications 5.5.5.c.(i),

5.5.5.c.(ii), and 5.5.5.d, shall be considered met. Following implementation:

1. The first performance of SR 3.7.9.4, in accordance with Specification 5.5.5.c.(i), shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

2. The first performance of the periodic assessment of CRE habitability, Specification 5.5.5.c.(ii), shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

3. The first performance of the periodic measurement of CRE pressure, Specification 5.5.5.d, shall be within 15 months of the approval of TSTF-448. SR 3.0.2 will not be applicable to this first performance.

3. This renewed license is effective as of the date of issuance and shall expire at midnight, May 20, 2034.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by:

Jon R. Johnson Jon R. Johnson, Acting Director Office of Nuclea( Reactor Regulation

Attachment:

Appendix A - Technical Specifications and

• Technical Specifications Bases (ML011710071 and ML011710100)

Date of Issuance: June 20, 2001 Renewed License No. DPR-51 Amendment No. ~.

Re\'ised by letter dated July 18, 2007