ML14356A172

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Summary of Site Audit to Support the Review of a License Amendment Request for Arkansas Nuclear One, Unit 2 to Transition to the National Fire Protection Association (NFPA) Standard 805 Fire Protection Licensing Basis
ML14356A172
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 12/22/2014
From: Hamzehee H, Klein A
NRC/NRR/DRA/AFPB, NRC/NRR/DRA/APLA
To: Eric Oesterle
Plant Licensing Branch IV
Fields L, NRR/DRA
References
TAC MF0404
Download: ML14356A172 (9)


Text

December 22, 2014 MEMORANDUM TO: Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Alexander R. Klein, Chief /RA/ D Frumkin for/

Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation Hossein G. Hamzehee, Chief /RA/ S Dinsmore for/

PRA Licensing Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF SITE AUDIT TO SUPPORT THE REVIEW OF A LICENSE AMENDMENT REQUEST FOR ARKANSAS NUCLEAR ONE, UNIT 2 TO TRANSITION TO THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) STANDARD 805 FIRE PROTECTION LICENSING BASIS (TAC NO. MF0404)

A review team, consisting of U.S. Nuclear Regulatory Commission (NRC) staff and contractors from the Pacific Northwest National Laboratory (PNNL) and Southwest Research Institute (SwRI)/Center for Nuclear Waste Regulatory Analyses (CNWRA) participated in a regulatory audit of the Arkansas Nuclear one unit 2, (ANO2) located in Russellville, AK from July 15 -18 ,

2013. The regulatory audit supports the review of the license amendment request (LAR) dated December 17, 2012, filed by Entergy Operations, Inc. (Entergy) to transition the plants fire protection licensing basis to Title 10 of the Code of Federal Regulations (CFR) 50.48(c), which endorses with exceptions the National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition.

The purpose of the audit was to gain an understanding of the information needed to support the staffs licensing decision regarding the LAR and to develop high quality requests for additional information (RAI), as needed. The information submitted in support of the ANO2 LAR is under final review, and any additional information needed to support the LAR review will be formally requested by the staff in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-101, License Amendment Review Procedures.

CONTACT: Leslie C. Fields, NRR/DRA (301) 415-1186

E. Oesterle 2 The audit team consisted of 11 NRC, 3 PNNL and 3 CNWRA (NRC contractors) staff. provides the schedules of activities during the audit. Enclosure 2 lists NRC staff, PNNL staff, CNWRA staff, and the licensees staff, and contractors who participated in the audit.

The audit team held an entrance meeting on Monday, July 15, 2013, with the licensees staff and contractors. During the remainder of the audit, team members met in smaller groups according to the audit plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13178A325). ANO2 staff provided plant walk-downs focusing on fire protection engineering (FPE), safe shutdown (SSD), fire probabilistic risk assessment (PRA), and fire modeling.

Technical discussions were focused on five major areas: FPE, SSD/circuit analysis (CA), fire PRA, fire modeling, and programmatic review. Enclosure 3 contains a list of documents reviewed by the team. In addition, attendance lists for entrance and exit meetings are provided in Enclosure 4 (ADAMS Accession Nos.: ML14356A180 and ML14356A185). At the conclusion of the audit, the audit team participated in a summary exit meeting with ANO2 staff and management on July 18, 2013. NRC staff expressed its appreciation to the ANO2 staff for providing informative walk-downs and presentations for the regulatory audit team.

Docket No. 50-368 Facility Operating License No.: NPF-6

Enclosures:

As stated

E. Oesterle 2 The audit team consisted of 11 NRC, 3 PNNL and 3 CNWRA (NRC contractors) staff. provides the schedules of activities during the audit. Enclosure 2 lists NRC staff, PNNL staff, CNWRA staff, and the licensees staff, and contractors who participated in the audit.

The audit team held an entrance meeting on Monday, July 15, 2013, with the licensees staff and contractors. During the remainder of the audit, team members met in smaller groups according to the audit plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13178A325). ANO2 staff provided plant walk-downs focusing on fire protection engineering (FPE), safe shutdown (SSD), fire probabilistic risk assessment (PRA), and fire modeling.

Technical discussions were focused on five major areas: FPE, SSD/circuit analysis (CA), fire PRA, fire modeling, and programmatic review. Enclosure 3 contains a list of documents reviewed by the team. In addition, attendance lists for entrance and exit meetings are provided in Enclosure 4 (ADAMS Accession Nos.: ML14356A180 and ML14356A185). At the conclusion of the audit, the audit team participated in a summary exit meeting with ANO2 staff and management on July 18, 2013. NRC staff expressed its appreciation to the ANO2 staff for providing informative walk-downs and presentations for the regulatory audit team.

Docket No. 50-368 Facility Operating License No.: NPF-6

Enclosures:

As stated DISTRIBUTION:

NON-PUBLIC LPL4 rtf Rids NrrDorLpl4-1Resource RidsNrrPMANO2Resource RidsOgcRp Resource RidsNrrDssStsbResource RidsAcrsAcnw_MailCTRResource RidsNrrDorlDprResource RidsRgn4MailCenterResource RidsNrrDraAplaResource RidsNrrDraAfpbResource ADAMS Accession No.: ML14356A172 Entrance List: ML14356A180 Exit List: ML14356A185 Package No.: ML14356A196 OFFICE NRR/DRA/APLA BC: NRR/DRA/AFPB BC: NRR/DRA/APLA NAME LFields AKlein HHamzehee DATE 12/ 22 /2014 12/ 22 /2014 12/ 22 /2014 OFFICAL RECORD COPY

Schedule of Activities Monday, July 15, 2013 8:00 am Audit team members met onsite at the ANO2 Plant established computer connections, and began document reviews 9:30 am Audit entrance meeting Plant overview discussions (plant overview presentations were completed the previous week as teleconferenced-presentations) 10:00 am Started review of fire PRA, fire modeling in support of fire PRA, NFPA 805 Chapter 3, radioactive release, recovery actions, non-power operations (NPO),

safe shutdown (SSD), nuclear safety capability assessment (NSCA) 12:30 pm Badging, review of several proposed walk-down areas by videos and photos to maintain ALARA criteria, continue reviews: fire modeling, radioactive release, SSD, fire PRA, control room abandonment, multiple spurious operations (MSO),

recovery actions, NPO, NSCA, fire protection engineering (FPE).

4:30 pm Licensee wrap up meeting 5:00 pm Adjourn for the day Tuesday, July 16, 2013 8:00 am Preparation for ANO2 plant walk-downs 9:00 am Plant tour briefing, security briefing and badging, dosimetry issuance, pre-job brief for walk-downs 9:30 am Plant walk-down tours were conducted.

1:30 pm Post walk-down discussion and debrief 2:00 pm MCR abandonment presentation 4:30 pm Licensee wrap up meeting 5:00 pm Adjourn for the day Wednesday July 17, 2013 8:00 am Morning breakout sessions 10:00 am Programmatic breakout 12:30 pm Presentation on plant modifications Reviews and breakouts continued from morning sessions 1:00 pm Control room ceiling modification discussion, combined fire modeling/PRA breakout 2:00 pm Discussion with licensee on RAI process 4:30 pm Licensee wrap up meeting 5:00 pm Adjourn for the day ENCLOSURE 1

2 Thursday, July 18, 2013 8:00 am Morning breakout sessions and interviews 8:30 am Review areas: fire modeling, Appendix R evaluation, SSD, defense in depth, safety margin, breaker control, fire PRA 4:15 pm Audit exit meeting 4:30 pm Adjourn

List of Participants U.S. Nuclear Regulatory Commission (NRC) Team

  • Alex Klein NRC Branch Chief
  • Hossein Hamzehee NRC Branch Chief
  • Paul Lain NRC QA
  • Jonathan DeJesus NRC PRA Pacific Northwest National Laboratory (PNNL) Team
  • Karl Bohlander PNNL FPE
  • Garill Coles PNNL FPRA
  • Peter Lowry PNNL FPRA Center for Nuclear Waste Regulatory Analyses (CNWRA) Team
  • Marc Janssen Fire Modeling/Lead
  • Debashis Basu Fire Modeling
  • Robert Fosdick Programmatic/Lead ANO2 Nuclear Plant Team
  • Bill Greeson ANO Management Sponsor
  • Bob Beaird ANO FP Supervisor
  • Richard Nance Entergy NFPA 805 Fleet Project Director
  • Larry Young Consultants Engineering Lead
  • Chris Little Consultants Electrical/Circuit Analysis Safe Shutdown
  • Dennis Barton Consultants Electrical/Circuit Analysis Safe Shutdown
  • Walter Hill Consultants Penetration Seals and Barriers
  • Hayden Collins Consultants Fire Protection
  • Stephen Lynn Consultants Modifications
  • David Robinson Consultants Modifications ENCLOSURE 2

2

  • Vern Kinsey ICE Scheduling
  • Justin Franco Kaly Tech Student Intern
  • Matt Dossett Entergy Fleet FP Eng
  • Sean Hunt Hughes Fire Modeling
  • Justin Williamson Hughes Fire Modeling
  • Lori Potts ICE PRA
  • Jessica Walker Hughes Eng Support
  • Paul Amico Hughes PRA
  • Steve Hardy Hughes PRA
  • Robert Burrell Entergy PRA
  • Usama Farradj ERIN PRA
  • Joe Renner ERIN PRA
  • Kiang Zee ERIN PRA
  • David Brice ANO Licensing Lead
  • Stephenie Pyle ANO Manager Licensing
  • Dana Miller Kaly Tech Licensing support Industry Observers
  • Dan Kearnaghan Browns Ferry
  • Todd Stafford Browns Ferry
  • Michael Lilley Ginna

List of Documents Reviewed

  • ANO-C-FP-07-001, Thermal Analysis of Concrete Embedded Conduit
  • ANO2-FP-09-00013, Control Room Abandonment Study
  • EC494, Justification of Barrier Protection Provided for Concrete Embedded Conduit
  • ER-ANO-2003-0450-000, Review of Cable Procurements to Determine Extent of Non-Thermoset Cables
  • PRA-A2-05-003R0, Fire Scenario Report
  • PRA-A2-05-004, PRA Summary Report
  • PRA-A2-05-011, Evaluation of Development and Timings of HGL Conditions in Selected ANO2 Fire Zones
  • Generic Fire Modeling Treatments Supplements used at ANO2
  • Fire pre-plans, which show fire area/zone boundaries, credited fire protection systems, etc., for the fire zones that were walked down
  • Drawings and photographs of sheet metal plenum space separation above the louvers and glass doors between Unit 1 and Unit 2 control rooms. These drawings and photographs were requested since it was not possible during the walk-downs to look above the false ceiling.
  • Videos and photographs of fire zones 2007-LL and 2014-LL to avoid having to walk down areas in the RCA.
  • EN-DC-207, Maintenance Rule Periodic Assessment
  • EN-AD-103, Document Control and Records Management
  • EN-TQ-125, Fire Brigade Training Program ENCLOSURE 3

2

  • OP-1104.032, Fire Protection Systems
  • EN-DC-127, Control of Hot Work and Ignition Sources
  • EN-DC-143-02 , ENO Procedure, Program and Component Health Report Supplemental Guidance
  • ENO-DC-115, ENO Procedure, Engineering Change Process
  • ENO-DC-128, ENO Procedure, Fire Protection Impact Review
  • HP 2.8, Response to Unusual Radiological Occurrences
  • 0247-07-0005.01, ERIN Report, Fire Risk Quantification and Summary
  • SNC-1, Quality Assurance Topical Report, Version 11.0