0CAN020701, Supplemental Response to GL 2003-01 Regarding Control Room Habitability

Supplemental Response to GL 2003-01 Regarding Control Room Habitability

ML070610449
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/14/2007
From:	Marlow T Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN020701, GL-03-001
Download: ML070610449 (5)

Text

• gr Entergy Operations, Inc.

1448 SR. 333

~En teray Russellville, AR 72802 Tel 479-858-4601 Thomas A. Marlow Director, Nuclear Safety Assurance oCANO.2o7o ,1 Febrary14,20 07)-

U.S :Nullear 'Regilatory commission Attn. Docduernt Control Desk' .. A.

Washington, DC 20555

SUBJECT:

! Supplemental Response to GL 2003-01 Regarding Control Room Habitability Arkansas Nuclear One, Units 1 and 2 Docket Nos:-50.-313 and 60-368 License Nos.ý DPR-51 and. NPF-6 I , ."

REFERENCES 1 NRC letter date'dJ'une-612, "2003,' Gerneric Letter 2003-01, Control Room Habitability(0CNA060308) "

2 Entergy letter dated August 28, 2003, Response to Generic Letter 2003-01 (0CAN080304) 3 Entergy letter dated June 24, 2004, Proposed OperatingLicense Amendment for Revised ANO-I Control Room HabitabilityAnalysis (1CAN060401) 4 Entergy letter dated May 6, 2006, Withdrawal of Proposed Operating License Amendment for Revised ANO-1 Control Room Habitability Analysis (1 CAN050601) 5 Federal Register Notice datediJanuary 17, 2007, Notice of Availability of Technical Specification Improvement To Modify Requirements Regarding Control Room Envelope Habitability Using the

- ConsolidatedLine Item Improvement Process (FRN Federal Register; VoL 72, No. 10, page 2022)

Dear Sir or Madam:

On-June 12, 2003,-the NRC issued Generic Letter (GL) 2003-01 (Reference 1). Entergy submitted the response to the generic letter for Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (ANO-2) on August 28, 2003 (Reference 2)' As discussed in our response, the ANO-1 and ANO-2 control rooms share a common control room envelope (CRE). Based on CRE testing conducted in 2001, the ANO-1 CRE unfiltered inleakage value was in excess of the analytical dose acceptance limits. Therefore, compensatory measures to reduce doses to the control room operators to within General Design Criterion (GDC) 19 limits were established through the use of potassium iodide in the event of an accident.

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0CAN020701 Page 2 of 3 In Reference 2, Entergy had also committed to submit revised dose calculations to eliminate these compensatory actions for compliance with GDC 19. On June 24, 2004, Entergy submitted a proposed license amendment using the guidance of Regulatory Guide 1.195 to increase the allowed radiological unfiltered in-leakage into the control room (Reference 3). As discussed in our response to the generic letter, Entergy used an approach consistent with the ANO-I's licensing basis for the maximum hypothetical accident. However, based on subsequent discussions with the NRC staff, Entergy withdrew the license amendment and stated that we would pursue alternate means for providing margin to the tested inleakage values for compliance with GDC 19.

Entergy has subsequently elected to pursue an alternate source term (AST) methodology approach to increase the allowed inleakage analytical limits for both units. Even though the control room measured inleakage is within the ANO-2 GDC 19 radiological analysis, additional margin is desirable for future inleakage testing. Entergy is in the process of final contract development for performing the AST analysis. The schedule for completion of the AST analyses is being staggered, with ANO-1 being completed in September 2007, while the ANO-2 analysis will be completed in 2008. Therefore, based on the current schedule for completion of the ANO-1 AST analysis, Entergy is committing to submit a proposed license amendment for ANO-1 using AST methodologies by October 31, 2007.

Additionally in response to GL 2003-01, Entergy committed to submit a proposed license amendment consistent with the NRC approved guidance of Technical Specification Task Force (TSTF)-448 within six months of its availability under the Consolidated Line Item Improvement Process (CLIIP). On January 17, 2007, the NRC issued a notice in the Federal Register (Reference 5) regarding the availability of TSTF-448, Revision 3, as a CLIIP. Therefore, under our current committed schedule, Entergy would be required to submit a license amendment by mid-July, 2007. However, under the new TSTF-448 requirements, a control room envelope which has been discovered to be in noncompliance to its GDC 19 analytical dose acceptance criteria would be required to shutdown the unit within 90 days. To avoid this condition, Entergy will need to defer our commitment and request NRC approval for both the TSTF-448 and the ANO-1 AST based license amendments on a corresponding schedule. Additionally, since the ANO-1 and ANO-2 control rooms share a common envelope, implementation of TSTF-448 for ANO-2 will need to be implemented on the same schedule as ANO-1. Therefore, Entergy will submit license amendment requests for the adoption of TSTF-448 for both ANO units concurrent with the AST license amendment request for ANO-1. Since ANO-2 control room meets its design basis allowable inleakage, the ANO-2 AST license amendment can be processed on a schedule separate from the other proposed license amendments.

Commitments being made for this supplemental response to GL 2003-01 are contained in the attachment to this letter. These revised commitments and schedules were discussed with the NRC staff during a conference call on January 26, 2007. If you have any questions or require additional information, please contact Steve Bennett at 479-858-4626.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on February 14, 2007.

Sincerely, T /b

0CAN020701 Page 3 of 3

Attachment:

List of Regulatory Commitments cc: Dr. Bruce S. Malleft Regional Administrator.

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Ms. Farideh Saba MS 0-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205

Attachment to OCAN020701 List of Regulatory Commitments

a Attachment to OCAN020701 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMPLETION COMMITMENT DATE (If Required)

ONE-TIME CONTINUING ACTION COMPLIANCE Entergy will submit a proposed license amendment X By October for ANO-1 using alternate source term 31, 2007 methodologies to eliminate the existing control room envelope compensatory measures Entergy will submit proposed license amendments X By October for ANO-1 and ANO-2 in accordance with 31, 2007 TSTF-448, Revision 3