0CAN081402, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)

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Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)
ML14241A660
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 08/28/2014
From: Jeremy G. Browning
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN081402, EA-12-049
Download: ML14241A660 (20)
v • d • e


Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Site Vice President Arkansas Nuclear One 0CAN081402 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEEs)

(Order Number EA-12-049)

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

REFERENCES:

1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated March 12, 2012 (0CNA031206) (ML12056A045)
2. Entergy letter to NRC, Overall Integrated Plan (OIP) in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 28, 2013 (0CAN021302) (ML13063A151)
3. Entergy letter to NRC, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated August 28, 2013 (0CAN081302)
4. Entergy letter to NRC, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 27, 2014 (0CAN021405)

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc.

(Entergy) which required submission an OIP pursuant to Section IV, Condition C which was provided by Reference 2.

0CAN081402 Page 2 of 2 Reference 1 also requires submission of a status report at six-month intervals following submittal of the OIP. References 3 and 4 provided the first and second six-month status reports, respectively. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Stephenie Pyle at 479.858.4704.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2014.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/nbm

Attachment:

Arkansas Nuclear One Units 1 and 2 Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs 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.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Mr. John Hughey MS 13-C5 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 0CAN081402 Arkansas Nuclear One (ANO) Units 1 and 2 (ANO-1 and ANO-2) Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEEs)

Attachment to 0CAN081402 Page 1 of 17 ANO-1 and ANO-2 Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs 1 Introduction Entergy Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) for ANO-1 and ANO-2 (Reference 1), documenting the diverse and flexible strategies (FLEX) in response to Reference 2. The OIP was updated and submitted with the First Six-Month Status Report (Reference 3). This enclosure provides an update of milestone accomplishments since submittal of the last status report (Reference 8), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31, 2014, and are current as of July 31, 2014:

  • Second Six-Month Status Report February 2014
  • Modifications Evaluation - January 2014
  • Third Six-Month Status Report Complete with submission of this document in August 2014 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Target Revised Target Activity Milestone Completion Completion Status Date* Date Submit OIP February 2013 Complete Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Not Started Update 5 August-2015 Not Started September Perform Staffing Analysis Started 2014

Attachment to 0CAN081402 Page 2 of 17 Target Revised Target Activity Milestone Completion Completion Status Date* Date Modifications Modifications Evaluation June 2013 Complete Engineering and June 2013 -

Started Implementation October 2015 ANO-1 Implementation February 2015 Not Started Outage ANO-2 Implementation October 2015 Not Started Outage On-site FLEX Equipment Purchase June 2014 Started October 2014 Procure November 2014 Not Started August 2015 Off-site FLEX Equipment Develop Strategies with November 2013 Started November 2014 Regional Response Center Install Off-site Delivery Station October 2014 Complete (if necessary)

Procedures Pressurized Water Reactor Completed Owners Group issues Nuclear June 2013 Issued System Steam Supply May 2013 (NSSS)-specific guidelines Create ANO FLEX Strategy November 2014 Started Guide Create Maintenance November 2014 Not Started Procedures Training Develop Training Plan June 2014 Started December 2014 Implement Training November 2014 Started August 2015 Validation ANO-1 walk-throughs or demonstration(s) - including all FLEX equipment points of connect/tie-in for Phase 2 March 2015 Not Started and 3

Attachment to 0CAN081402 Page 3 of 17 Target Revised Target Activity Milestone Completion Completion Status Date* Date ANO-2 walk-throughs or demonstration(s) - including all FLEX equipment points of October 2015 Not Started connect/tie-in for Phase 2 and 3 Submit Completion Report February 2016 Not Started Note: *Target Completion Date is the last submitted date from either the OIP or previous six month status reports.

4 Changes to Compliance Method In the continuing design development phase of the FLEX project at ANO, changes have been identified to the compliance strategies as described in the original OIP.

  • The use of a portable FLEX reactor coolant system (RCS) makeup pump during Phase 2 for ANO-2 has been changed. The current strategy is to use an ANO-2 charging pump as the injection source to meet the FLEX RCS inventory control requirements for ANO-2 after the ANO-1 RCS cooldown is complete (Interim Safety Evaluation (ISE) Open Item 3.2.1.D and Audit Questions (AQ) ANO-035, ANO-046, ANO-106 and ANO-107). The NRC staff concluded .that the licensee provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will meet the requirements of Order EA 12-049 at ANO-1 and ANO-2. (Reference 7).
  • ANO-2 cooldown and depressurization strategy would be implemented within two hours of the ELAP event in accordance with WCAP-17601-P and as assumed in the specific ANO-2 site analysis (ISE Confirmatory Item 3.2.1.B, and AQ ANO-014, ANO-015, ANO-018, ANO-021, ANO-025, ANO-035, ANO-049, ANO-051, ANO-075, ANO-077, ANO-078, and ANO-085) (Reference 9).
  • Entergy is submitting the following alternative to NEI 12-06 which is necessary to support the ANO-1 and ANO-2 strategies. The final analysis is expected by the end of the year 2015. The ANO-1 and ANO-2 strategy for FLEX requires use of ANO-1s Borated Water Storage Tank (BWST) and/or ANO-2s Refueling Water Tank (RWT).

These tanks are not required for safe shutdown and so were not previously evaluated for tornado winds and tornado missiles in the current licensing basis. An evaluation was performed to determine if the tanks are robust (per the definition in Appendix A of NEI 12-06) for tornado and tornado missiles for use in the ANO FLEX strategy. NEI 12-06 defines robust as: Robust (designs): the design of an SSC either meets the current plant design basis for the applicable external hazards or has been shown by analysis or test to meet or exceed the current design basis. When evaluated against current tornado wind and missile design basis for the site, the ANO-1s BWST and ANO-2s RWT tanks do not meet the NEI definition of robust.

Attachment to 0CAN081402 Page 4 of 17 For the current licensing basis, ANO-1s BWST and ANO-2s RWT are the normal sources for large inventory additions to their respective RCS or spent fuel pool.

They are located between the two units and they are partially protected by the reactor and turbine buildings. Each of the tanks has sufficient capacity to support the FLEX strategy for both units.

The tornado resistant design of the ANO units was completed prior to the issuance of Regulatory Guide (RG) 1.76, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, (ANO-1 Safety Analysis Report (SAR) Section 5.1.5 and ANO-2 SAR Section 3.3.2.1). The current design assumptions used for both units are conservative relative to the criteria of RG 1.76 Revision 1. When applying the conservative criteria of the current design basis of the site to ANO-1s BWST and ANO-2s RWT, the tanks do not meet the NEI definition of robust.

As an alternative to the NEI 12-06 definition of robust, i.e., the use of current plant design basis, Entergy is requesting approval of the use of RG 1.76 Revision 1 as the criteria for robust with respect to tornado winds and missiles for the use of ANO-1s BWST and ANO-2s RWT for support of ANO FLEX strategies.

The preliminary evaluation indicates that, relative to RG 1.76 Revision 1, both tanks may be considered robust for tornados and tornado missiles and the ANO-1 and ANO-2 FLEX strategies may consider the tanks provide a robust source of borated water. Prior to crediting the tanks for compliance with EA-12-049, Entergy plans to complete a detailed evaluation to confirm and document the robust status of ANO-1s BWST and ANO-2s RWT relative to tornado and tornado missiles consistent with RG 1.76 Revision 1.

This evaluation is being used only for meeting NRC Order EA-12-049 and does not alter the current design bases of ANO-1s BWST and ANO-2s RWT. Nor does the use of RG 1.76 Revision 1 for this evaluation indicate any intent by ANO to alter the sites current design or licensing basis.

  • The ANO-1 and ANO-2 strategy for FLEX requires use of the Q condensate storage tank (QCST). Using the same approach as the one described above for the ANO-1 BWST and ANO-2 RWT, Entergy is currently pursuing applying RG 1.76 Revision 1 to the QCST to qualify additional water supply through a finite element analysis. In a similar way as described above, this represents an alternative to NEI 12-06 definition of robust.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Entergy expects to comply with the order implementation date for ANO-2; however, as part of a separate submittal (Reference 5) Entergy requested an extension for ANO-1 for no later than startup of ANO-2 from refueling outage 2R24 currently scheduled for October 2015. The request was submitted to support the RCS inventory control strategy associated with the alternate power connection for the charging pump. This request for relief/relaxation for ANO-1 was approved by the NRC via Reference 6.

Attachment to 0CAN081402 Page 5 of 17 6 Open Items from OIP and Interim Staff Evaluation (ISE)

The following tables provide a summary and status of any open items documented in the OIP and any open items or confirmatory items documented in the ISE (Reference 10).

Also provided is a listing of Audit Questions and the status of each item.

OIP Open Items Status There were no open items documented in the ANO OIP. N/A ISE Open Items Status 3.2.1.D The NRC staff has reviewed the ANO approach that This item is uses the ANO-2 charging pump to supply makeup addressed by to the ANO-1 RCS for inventory control but has not updated AQ concluded that this approach is acceptable. The ANO-035, staff has identified a number of concerns that need ANO-046, to be addressed regarding the proposed RCS ANO-106, and inventory control strategy. Therefore, this open item ANO-107 tracks completion of the development of an responses acceptable integrated RCS makeup strategy that spreadsheet on the meets the requirements of Order EA-12-049. ePortal.

3.2.1.8.B For ANO-1 and ANO-2, verify resolution of the This item is generic concern associated with the modeling of the addressed by timing and uniformity of the mixing of a liquid boric updated AQ acid solution injected into the RCS under natural ANO-041 response circulation conditions potentially involving two-phase spreadsheet on the flow. ePortal.

ISE Confirmatory Items Status 3.1.1.2.A Confirm whether there is a need for a power source This item is to move or deploy the FLEX equipment (e.g., to addressed on open the door from a storage location). updated Audit Question (AQ) response spreadsheet on the ePortal.

3.1.1.4.A Confirm that the local staging area for the Regional In progress. This Response Center (RRC) equipment has been item to be identified and a description of the methods to be addressed on used to deliver the equipment to the site has been updated AQ provided. response spreadsheet on the ePortal when the information is available.

Attachment to 0CAN081402 Page 6 of 17 ISE Confirmatory Items Status 3.1.3.1.A Confirm that the axis of separation and distance This item is between the portable equipment storage buildings addressed by provides assurance that a single tornado will not updated AQ impact both buildings. ANO-002 response spreadsheet on the ePortal.

3.2.1.A Confirm that the Atmospheric Dump Valves and This item is associated piping at both units are sufficiently addressed by robust and will remain functional during and updated AQ following a seismic event. ANO-109 response spreadsheet on the ePortal.

3.2.1.B Confirm that the ANO-2 cooldown analysis supports This item is the delay in the cooldown to eight hours following addressed by the ELAP. updated AQ-014, 015, 018, 021, 025,035, 049, 051, 075, 077, 078, and 085 responses spreadsheet on the ePortal.

3.2.1.C Confirm that the evaluation of the emergency This item is feedwater (EFW) turbine exhaust piping for addressed by robustness is completed with acceptable results. updated AQ 109 response spreadsheet on the ePortal.

3.2.1.1.A Confirm that reliance on the RELAP5/MOD2-B&W In progress.

code in the ELAP analysis for ANO-1 is limited to This item to be the flow conditions prior to boiler-condenser cooling addressed by initiation.

update to AQ ANO-015 response spreadsheet on the ePortal when the information is available.

3.2.1.1.B Confirm that the use of CENTS in the ELAP This item is analysis is limited to the flow conditions prior to addressed by reflux boiling initiation. updated AQ-015 response spreadsheet on the ePortal.

3.2.1.2.A For ANO-1 confirm that the strategy is effective in NRC Confirmatory keeping the RCS temperatures within the limits of Action

Attachment to 0CAN081402 Page 7 of 17 ISE Confirmatory Items Status the seal design temperatures, and supports the leakage rate (two gallons per minute (gpm)/seal) used in the ELAP analysis.

3.2.1.2.B For ANO-1, confirm adequate justification for NRC Confirmatory (including seal leakage testing data) the use of two Action gpm/seal in the ELAP analysis.

3.2.1.3.A Verify the ELAP analysis assumption that decay This item is heat is per ANS [American Nuclear Society] 5.1- addressed for ANO-1979 + 2 sigma, or equivalent. 2 by updated AQ ANO-019 response spreadsheet on the ePortal.

For ANO In progress. This item to be addressed by update to AQ ANO-019 response spreadsheet on the ePortal when the information is available.

3.2.1.4.A For ANO-1, confirm the revision to WCAP-17601 This item is used and also confirm whether there are any addressed by deviations taken from the assumptions presented in updated AQ NEI 12-06, Section 3.2. ANO-075 response spreadsheet on the ePortal.

3.2.1.8.A Confirm the acceptability of the ANO-2 shutdown This item is margin results after accounting for the delay in the addressed by cooldown to eight hours following an ELAP. updated AQ ANO-078 response spreadsheet on the ePortal.

3.2.1.9.A Confirm the adequacy of the RCS injection strategy This item is considering the analysis in licensee calculation addressed by CN-SEE-II-13-2 as it relates to the delay in the updated AQ ANO-2 cooldown to eight hours following an ELAP. ANO-051 and ANO-077 responses spreadsheet on the ePortal.

3.2.1.9.B Confirm the final specific times for connection and In progress. This use of the portable RRC pumps. item to be addressed by update to AQ

Attachment to 0CAN081402 Page 8 of 17 ISE Confirmatory Items Status ANO-035 response spreadsheet on the ePortal when the information is available.

3.2.3.A Confirm acceptable results of the ANO-2, This item is containment ELAP analysis after it is completed. addressed by updated AQ ANO-032 response spreadsheet on the ePortal.

3.2.4.2.A Confirm acceptable results of the ANO-2, Main This item is Control Room heat-up calculation after it is addressed by performed. updated AQ ANO-061 response spreadsheet on the ePortal.

3.2.4.2.B Confirm the adequacy of ANO-2 battery room This item is ventilation for extreme temperature protection when addressed by the design development is completed. updated AQ ANO-125 response spreadsheet on the ePortal.

3.2.4.2.C Confirm the adequacy of calculations for extreme This item is temperature protection regarding ANO-2, turbine- addressed by driven EFW pump room and electrical equipment updated AQ rooms when the design development is completed. ANO-060 response spreadsheet on the ePortal.

3.2.4.4.A Confirm that upgrades to the site's communications NRC Confirmatory systems have been completed as planned. Action 3.2.4.7.A Confirm that a final strategy for use of the mobile This item is boration unit is developed. addressed by updated AQ ANO-044 response spreadsheet on the ePortal.

3.2.4.10.A For ANO-2, confirm that an acceptable load This item is shedding strategy is developed. addressed by updated AQ ANO-128 response spreadsheet on the ePortal.

3.2.4.10.B For ANO-2, confirm that an acceptable dc load This item is

Attachment to 0CAN081402 Page 9 of 17 ISE Confirmatory Items Status profile is developed. addressed by updated AQ ANO-070 response spreadsheet on the ePortal.

3.2.4.10.C For ANO-2, confirm that an acceptable basis for the This item is minimum dc bus voltage is determined. addressed by updated AQ ANO-072 response spreadsheet on the ePortal.

3.3.2.A Confirm that acceptable strategies and their bases This item is are developed and maintained in an overall program addressed on document, as described in NEI 12-06, Section 11.8, updated AQ items 1 and 3. response spreadsheet on the ePortal.

3.4.A Confirm that the licensee has fully addressed This item is considerations (2) through (10) of NEI 12-06, addressed on Section 12.2, Minimum Capability of Off-Site updated AQ Resources, which requires each site to establish a response means to ensure the necessary resources will be spreadsheet on the available from off-site. ePortal.

Audit Completion or Status Questions Target Date ANO-001 Closed*

Updated response available on the ePortal (ISE ANO-002 Confirmatory Item 3.1.3.1.A)

ANO-003 Closed*

ANO-004 Closed*

ANO-006 Closed*

ANO-010 Closed*

ANO-011 Updated response available on the ePortal ANO-012 Closed*

ANO-013 Closed*

Updated response available on the ePortal (ISE ANO-014 Confirmatory Item 3.2.1.B)

ANO-015 Updated response available on the ePortal (ISE

Attachment to 0CAN081402 Page 10 of 17 Audit Completion or Status Questions Target Date Confirmatory Item 3.2.1.B)

In progress - This AQ response spreadsheet on the ePortal to be updated when information is available February 2015 (ISE Confirmatory Item 3.2.1.1.A)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.1.B)

Updated response available on the ePortal (ISE ANO-018 Confirmatory Item 3.2.1.B)

ANO In progress - This AQ response spreadsheet on the ePortal to be updated when February 2015 information is available (ISE Confirmatory Item ANO-019 3.2.1.3.A)

Updated response for ANO-2 available on the ePortal (ISE Confirmatory Item 3.2.1.3.A)

ANO-020 Closed*

Updated response available on the ePortal (ISE ANO-021 Confirmatory Item 3.2.1.B)

ANO-022 Closed*

ANO-023 Closed*

ANO-024 Closed*

Updated response available on the ePortal (ISE ANO-025 Confirmatory Item 3.2.1.B)

ANO-026 Closed*

ANO-027 Closed*

ANO-028 Closed*

ANO-029 Closed*

ANO-030 Closed*

Updated response available on the ePortal (ISE ANO-032 Confirmatory Item 3.2.3.A)

ANO-034 Closed*

Updated response available on the ePortal (ISE Open Item 3.2.1.D)

ANO-035 Updated response available on the ePortal(ISE Confirmatory Item 3.2.1.B)

In progress - This AQ response spreadsheet on the February 2015 ePortal to be updated when information is available

Attachment to 0CAN081402 Page 11 of 17 Audit Completion or Status Questions Target Date (ISE Confirmatory Item 3.2.1.9.B)

ANO In progress - This AQ response spreadsheet on the ePortal to be updated when February 2015 ANO-041 information is available (ISE Open Item 3.2.1.8.B)

ANO Updated response available on the ePortal (ISE Open Item 3.2.1.8.B)

Updated response available on the ePortal (ISE ANO-044 Confirmatory Item 3.2.4.7.A)

ANO-045 Updated response available on the ePortal Updated response available on the ePortal (ISE ANO-046 Open Item 3.2.1.D)

ANO-047 Updated response available on the ePortal Updated response available on the ePortal (ISE ANO-049 Confirmatory Item 3.2.1.B)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-051 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.9.A ANO-055 Closed*

ANO-056 Closed*

ANO-059 Updated response available on the ePortal Updated response available on the ePortal (ISE ANO-060 Confirmatory Item 3.2.4.2.C)

Updated response available on the ePortal (ISE ANO-061 Confirmatory Item 3.2.4.2.A)

ANO-062 Updated response available on the ePortal ANO-063 Updated response available on the ePortal ANO-064 Closed*

ANO-066 Closed*

ANO-067 Updated response available on the ePortal ANO-068 Closed*

ANO-069 Updated response available on the ePortal Updated response available on the ePortal (ISE ANO-070 Confirmatory Item 3.2.4.10.B)

ANO-071 Updated response available on the ePortal

Attachment to 0CAN081402 Page 12 of 17 Audit Completion or Status Questions Target Date Updated response available on the ePortal (ISE ANO-072 Confirmatory Item 3.2.4.10.C)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-075 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.4.A)

ANO-076 Closed Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-077 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.9.A)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-078 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.8.A)

ANO-080 Closed*

ANO-082 Closed*

ANO-084 Closed*

ANO-085 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-086 Closed*

ANO-088 Closed*

ANO-089 Updated response available on the ePortal ANO-090 Updated response available on the ePortal ANO-091 Closed*

ANO-092 Closed*

ANO-094 Updated response available on the ePortal ANO-098 Updated response available on the ePortal ANO-100 Updated response available on the ePortal ANO-104 Closed*

Updated response available on the ePortal (ISE ANO-106 Open Item 3.2.1.D)

ANO-107 Updated response available on the ePortal (ISE Open Item 3.2.1.D)

Attachment to 0CAN081402 Page 13 of 17 Audit Completion or Status Questions Target Date ANO-108 Closed*

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.A)

ANO-109 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.C)

ANO-110 Updated response available on the ePortal ANO-112 Closed*

ANO-113 Updated response available on the ePortal ANO-115 In progress - This AQ response on the ePortal to be February 2015 updated when information is available ANO-116 Closed*

ANO-117 Updated response available on the ePortal ANO-118 Closed*

ANO-120 Closed*

ANO-123 Updated response available on the ePortal ANO-125 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.2.B)

ANO-126 Updated response available on the ePortal ANO-127 Updated response available on the ePortal ANO-128 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.10.A)

ANO-129 Updated response available on the ePortal The following additional questions related to ANO Cross-Unit RCS Makeup Strategy were received in January 2014 during the audit process ANO-1 Updated response available on the ePortal ANO-2 Updated response available on the ePortal ANO-3 Closed*

ANO-4 Updated response available on the ePortal ANO-5 Closed*

ANO-6 Updated response available on the ePortal ANO-7 Updated response available on the ePortal ANO-8 Updated response available on the ePortal ANO-9 Updated response available on the ePortal

Attachment to 0CAN081402 Page 14 of 17 Audit Completion or Status Questions Target Date ANO-10 Closed*

ANO-11 Updated response available on the ePortal ANO-12 Closed*

ANO-13 Closed*

ANO-14 Updated response available on the ePortal ANO-15 Updated response available on the ePortal ANO-16 Updated response available on the ePortal

  • Closed indicates that Entergys response is complete.

7 Potential ISE Impacts The following items have been identified which have potential impact to the Interim Staff Evaluation (ISE) except for those identified in Section 6.

1. ISE/TER (Technical Evaluation Report) Section 3.1.2.2, Page 15, the TER states ANO-2 FLEX RCS makeup pump requires primary and secondary connections to the HPSI/charging piping and the refueling water tank (RWT) or borated water storage tank (BWST). The current strategy utilizes an ANO-2 charging pump as the RCS injection source for both units. This strategy eliminates the need for onsite portable RCS makeup pumps, and any connections to the HPSI/charging piping.
2. ISE/TER Section 3.2.1, Page 29, the TER states, the Boric Acid Makeup Tanks (BAMTs), RWT, BWST or the new borated water tank will provide this function. Currently, besides the option to install a new borated water tank, Entergy is also pursuing applying RG 1.76 Revision 1 to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.
3. ISE/TER Section 3.2.1, Page 31, the TER states, and ANO-2 indicate cooldown is currently scheduled to begin at approximately eight hours from event initiation. The ANO-2 cooldown requires confirmation of existing analysis or additional analysis during the ANO-2 detailed design to support the delay in the cooldown to eight hours following the ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.
4. ISE/TER Section 3.2.1, Page 31, item c, the TER states, This analysis requires confirmation or additional analysis during the ANO-2 detailed design to support the delay in the ANO-2 cooldown to two hours following an ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.

Attachment to 0CAN081402 Page 15 of 17

5. ISE/TER Section 3.2.1, Page 31, item d, the TER states, For ANO-2 the suction source will be either the ANO-1 BWST or ANO-2 RWT. The current strategy is to use an ANO-2 charging pump. The suction source is provided from the ANO-2 boric acid makeup tank (BAMT) and then the ANO-2 RWT.
6. ISE/TER Section 3.2.1, Page 35, the TER states, 1 RCS makeup pump (Unless it is decided to use charging pump for ANO-2 RCS makeup). The current strategy is to use an ANO-2 charging pump; therefore, the RCS makeup pump is eliminated.
7. ISE/TER Section 3.2.1.1, Page 39, the TER states, The current ANO-2 cooldown strategy, as detailed in the 6-month update, delays the ANO-2 cooldown until eight hours following an ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.
8. ISE/TER Section 3.2.1.1, Page 40, the TER states, Recommendation 2 - The ANO-2 strategy incorporates cooldown starting at eight hours The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.
9. ISE/TER Section 3.2.1.1, Page 40, the TER states, Recommendation 6 - to support the delay in the ANO-2 cooldown to eight hours following an ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.
10. ISE/TER Section 3.2.1.8, Page 48, the TER states, The analysis requires confirmation or additional analysis during the ANO-2 detailed design to support the delay in the cooldown to eight hours following the ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis.
11. ISE/TER Section 3.2.1.8, Page 51, the TER states, CN-SEE-II-13-2, Revision 1, requires confirmation or additional analysis during the ANO-2 detailed design to support the delay in the ANO-2 cooldown to eight hours following an ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis (CN-SEE-II-13-2, Revision 1).
12. ISE/TER Section 3.2.1.8, Page 52, the TER states, the analysis performed in CN-SEE-II-13-2, Revision 1, requires confirmation or additional analysis during the ANO-2 detailed design to support the delay in the ANO-2 cooldown to eight hours following an ELAP. The current strategy is to begin cooldown at two hours following a reactor trip resulting from a BDBEE consistent with the Westinghouse site-specific analysis (CN-SEE-II-13-2, Revision 1).
13. ISE/TER Section 3.2.1.8, Page 52, the TER states, An alternate strategy is under consideration to use the charging pump to make up to the ANO-2 RCS after ANO-1 cooldown is complete. The use of the charging pumps to make up to the ANO-2 RCS has become the primary strategy.

Attachment to 0CAN081402 Page 16 of 17

14. ISE/TER Section 3.2.4.7, Page 65, the TER states, For ANO-2,RCS inventory will be added as needed by utilizing a portable FLEX RCS makeup pump. The current strategy utilizes the ANO-2 charging pumps as the means for RCS inventory control for both ANO-1 and ANO-2.
15. ISE/TER Section 3.2.4.7, Page 66, the TER states, For high wind BDBEEs, a new borated water storage tank, which Currently, besides the option to install a new borated water tank, Entergy is also pursuing applying RG 1.76 Revision 1, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.
16. ISE/TER Section 3.2.4.7, Page 67, the TER states, This 30-minute action to manually align valves in the Intake Structure will be validated during the procedure development phase and staffing assessment. To qualify additional QCST inventory beyond the 30 minutes to allow enough time for aligning this new permanently installed crosstie between the fire water and the service water, Entergy is currently pursuing applying RG 1.76 Revision 1, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, to the QCST to qualify additional water through a finite element analysis.
17. ISE/TER Section 3.2.4.7, Page 68, the TER states, A new borated water tank will be installed for coping with FLEX following high wind BDBEEs. Currently, besides the option to install a new borated water tank, Entergy is also pursuing applying RG 1.76 Revision 1, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.
18. ISE/TER Section 3.2.4.7, Pages 68 and 69, the TER states, .An alternate strategy is under consideration to use the charging pumps to make up to the ANO-2 RCS after the AN0-1 cooldown is complete. The current strategy utilizes the ANO-2 charging pumps as the means for RCS inventory control for both ANO-1 and ANO-2.

8 References The following references support the updates to the OIP described in this enclosure.

1. OIP in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 28, 2013 (0CAN021302) (ML13063A151)
2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated March 12, 2012 (0CNA031206) (ML12056A045)
3. Entergy letter to NRC, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Attachment to 0CAN081402 Page 17 of 17 (Order Number EA-12-049), dated August 28, 2013 (0CAN081302)

(ML13241A414)

4. Entergy letter to NRC, Emergency Preparedness Commitment Changes Related to the March 12, 2012, Information Request, dated October 25, 2013 (0CAN101303)
5. Entergy letter to NRC, Request for Implementation Date Relief in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEEs) (NRC Order EA-12-049) Arkansas Nuclear One - Unit 1, dated April 8, 2014 (1CAN041401) (ML14098A114)
6. NRC letter, Arkansas Nuclear One, Unit 1 -Relaxation of the Schedule Requirements for Order EA-12-049 "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, dated May 20, 2014 (ML14114A697)
7. NRC letter, Arkansas Nuclear One, Units 1 and 2 - Update Regarding Audit Activities Associated with Order EA-12-049 (Mitigation Strategies), dated May 28, 2014 (ML14140A514)
8. Entergy letter to NRC, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014 (0CAN021405)

(ML14059A229)

9. Westinghouse calculation CN-SEE-II-13-2, Revision 1, Arkansas Nuclear One Unit 2 Reactor Coolant System Inventory, Shutdown Margin, and Modes 5 and 6 Boric Acid Precipitation Control Analyses to Support the Diverse and Flexible Coping Strategies (FLEX), dated February 19, 2013.
10. NRC letter, Arkansas Nuclear One, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0942 and MF0943), dated February 25, 2014
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