1CAN121202, Response to Request for Additional Information, Request for Extension of Enforcement Discretion
| ML12349A318 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/13/2012 |
| From: | Schwarz C Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 1CAN121202 | |
| Download: ML12349A318 (19) | |
Text
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 1CAN121202 December 13, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Response to Request for Additional Information Request for Extension of Enforcement Discretion Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51
References:
- 1. Entergy letter dated August 23, 2012, Request for Extension of Enforcement Discretion, Arkansas Nuclear One - Unit 1 (1CAN081202)
- 2. NRC email dated November 5, 2012, RAI Regarding the Revision of the Regulatory Commitment Relating to the Submittal of 10 CFR 50.48(c) LAR (TAC No. ME9429) (ML12310A462)
- 3. Staff Requirements Memorandum SECY-12-0031, Enforcement Alternatives for Sites that Indicate Additional Time Required to Submit Their License Amendment Requests to Transition to 10 CFR 50.48(c) National Fire Protection Association Standard 805, dated February 24, 2012 (ML12025A349)
- 4. Entergy letter dated November 15, 2012, Request for Extension of Enforcement Discretion, Arkansas Nuclear One - Unit 1 (1CAN111204)
- 5. NRC email dated December 6, 2012, RAI Associated with ANO-1 NFPA 805 Enforcement Discretion Extension Request (TAC No. ME9429)
Dear Sir or Madam:
By letter dated August 23, 2012 (Reference 1), Entergy Operations, Inc. (Entergy) requested an extension to enforcement discretion related to fire protection issues associated with Renewed Facility Operating License No. DPR-51 for Arkansas Nuclear One, Unit 1 (ANO-1). The original enforcement discretion was based, in part, on submittal of an ANO-1 request to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a),
10 CFR 50.48(c), and the guidance in Regulatory Guide 1.205, Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, no later
1CAN121202 Page 2 of 3 than August 31, 2012. Due to circumstances described in the Reference 1 letter, Entergy has requested an extension of enforcement discretion related to fire protection issues for ANO-1 based, in part, on submitting the aforementioned ANO-1 License Amendment Request (LAR) implementing 10 CFR 50.48(c) prior to August 31, 2013. However, Enclosure 1 of this letter extends this request to January 31, 2014. Per the enforcement discretion policy, once the request is submitted and accepted, the enforcement discretion would then continue until the NRC dispositions the LAR.
The NRC notified Entergy on November 5, 2012 (Reference 2), of a request for additional information (RAI) necessary to support approval of Entergys request for an extension of enforcement discretion. Entergy responded to this request via letter dated November 15, 2012 (Reference 4).
The NRC notified Entergy on December 6, 2012 (Reference 5), of a request for additional information (RAI) necessary to support approval of Entergys request for an extension of enforcement discretion. Enclosure 1 contains Entergys response to the RAI.
Entergy requests the NRC issue a Confirmatory Order approving the requested enforcement discretion extension for ANO-1 as permitted by Reference 3.
This letter contains no new commitments; however the commitment date provided in the August 23, 2012, letter is superseded as reflected in Enclosures 1 and 2. Should you have any questions concerning this letter, 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 December 13, 2012.
Sincerely, ORIGINAL SIGNED BY JAIME H. MCCOY FOR CHRISTOPHER J. SCHWARZ CJS/dbb
Enclosure:
- 1. Response to RAI Associated with ANO-1 NFPA 805 Enforcement Discretion Extension Request
- 2. List of Regulatory Commitments
1CAN121202 Page 3 of 3 cc: Mr. Elmo E. Collins 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: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Enclosure 1 to 1CAN121202 Response to RAI Associated with ANO-1 NFPA 805 Enforcement Discretion Extension Request to 1CAN121202 Page 1 of 3 Response to RAI Associated with ANO-1 NFPA 805 Enforcement Discretion Extension Request By email dated December 6, 2012, the NRC notified Entergy Operations, Inc. (Entergy) of a request for additional information (RAI) related to Entergys August 23, 2012, request for an extension of enforcement discretion for fire protection issues for Arkansas Nuclear One, Unit 1 (ANO-1). The questions and responses associated with the RAI are provided below.
- 1) The completion dates for the modifications to resolve the MSO circuit issues do not address this fire protection legacy issue in a timely manner.
Entergy Response Entergys response to RAI Question 1.a in letter dated November 15, 2012 (1CAN111204),
provided a list of modifications previously completed, which eliminated a significant number of operator manual actions (OMAs). The completion dates for remaining modifications supporting the ANO-1 transition to NFPA 805 were provided in Entergys response to RAI Question 1.d and Attachment 2 of the aforementioned November 15, 2012, letter. Most of the design complete dates were established based on completing the modification packages in advance of the refueling outage in which the modification would be installed.
The dates were essentially the drop-dead date for meeting refueling outage planning requirements and did not reflect the potential that many of the packages would likely complete in advance of these dates.
As a result, Entergy has modified Attachment 2 of the November 15, 2012, letter and included the revised version as Attachment 1 of this enclosure. The revised dates associated with the completion of design modification packages are based on the importance of the modification. The importance was determined using the ranking of the modification provided in Attachment 1 (Table S-1) of the November 15, 2012, letter (high, medium, low). The rankings are associated with the number of fire areas impacted and whether the condition is associated with Information Notice (IN) 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire.
The preliminary schedule (based on importance) was then developed considering the following:
The general number of operator actions associated with the modifications Whether the modification required unit shutdown for implementation For shutdown modifications, the safety train scheduled for maintenance during a given refueling outage ANO, Unit 2 (ANO-2) NFPA 805 modification support (ANO-2 transition to NFPA-805 precedes ANO-1 transition)
Support of the ANO-2 NFPA 805 audit (anticipated in late 2nd quarter 2013),
followed by support of the ANO-1 NFPA 805 audit (~6 months following submittal/acceptance of the ANO-1 License Amendment Request (LAR))
Response to ANO-1 and ANO-2 NFPA 805 RAIs Other significant/important modifications unrelated to NFPA 805 The complexity of the design to 1CAN121202 Page 2 of 3 In light of the above, a calendar quarter based timeline-type schedule is included in Attachment 2 of this letter which includes major ANO-2 NFPA 805 items that have a significant impact on ANO-1 resources. Based on the information provided in the attachments to this letter, NFPA 805 related modification design and installation is expected to proceed in a safe and efficient manner.
Not depicted in the attached schedules are the details associated with each NFPA 805 modification that can be partially implemented/installed non-outage. Scheduling non-outage partial installations is not possible until the design packages are complete and then, based on the date the package is completed, a determination of the next available non-outage work-week window for which the specific train or component is open for maintenance can be performed. The controls placed on such scheduling are intended to ensure maintenance and modifications are performed in a manner that minimizes the overall risk to plant safety.
Entergy fully recognizes the safety significance and importance of completing all NFPA 805 related modifications as soon as practical. Based on the above, Entergy believes the current schedule and the safety-conscience scheduling process employed will ensure reasonable progress in support of final transition to NFPA 805, irrespective of the date in which the ANO-1 NFPA 805 LAR is submitted for NRC review and approval.
- 2) The proposed LAR completion schedule identifies potential unforeseen circumstances that should be considered as certain activities when scheduling their new commitment date.
Entergy Response Entergys response to RAI Question 1.e of the aforementioned November 15, 2012, letter provided a list of potential circumstances that could delay final development and submittal of the ANO-1 NFPA 805 LAR. Based on the listing, Entergy proposed a revised LAR submittal date of August 31, 2013, and subsequently, a request to extend the ANO-1 enforcement discretion for fire protection issues accordingly. After further consideration, Entergy has determined that the proposed submittal date is highly aggressive and cannot be reasonably assured, especially if several of the noted circumstances are realized. For completeness, the previous listing of potential circumstances provided to the NRC in the November 15, 2012, letter is included below, with the exception of the line item associated with conflicts created by final submittal of the ANO-2 NFPA 805 LAR. Note, however, that development of the ANO-2 LAR has delayed progress related to the ANO-1 LAR.
- Spring 2013 ANO-1 refueling outage
- New NRC concerns or industry issues associated with NFPA 805 submittals
- Preparation for NFPA 805 audit of ANO-2, which is expected to occur in the 2nd quarter 2013 following the ANO-1 refueling outage
- Resources needed to support potential ANO-2 NFPA 805 related NRC RAIs (both acceptance review RAIs and audit related RAIs)
- Other significant emergent site issues that could require support from the ANO NFPA 805 resource team to 1CAN121202 Page 3 of 3 The spring 2013 ANO-1 refueling outage requires significant engineering resources pre-outage, during the outage, and for about 1-2 months following the outage to implement and close associated modification packages. Although not currently scheduled, the ANO-2 NFPA 805 audit is anticipated late in the 2nd quarter of 2013, just after outage related engineering resources become available. These two items alone create a significant challenge to meeting an August 31, 2013, LAR submittal date. Should all of the remaining items be realized over this same period or immediately thereafter, a substantial impact to final LAR development could occur. Therefore, giving proper respect to the aggregate of these potential circumstances, Entergy proposes to revise the ANO-1 NFPA 805 LAR submittal date to January 31, 2014. Entergys request for an extension of enforcement discretion for ANO-1 fire protection issues would likewise be extended to support this commitment. Per the enforcement discretion policy, once the LAR is submitted and accepted, the enforcement discretion would then continue until the NRC dispositions the LAR. Nevertheless, Entergy will continue to progress toward completion of the ANO-1 LAR as efficiently as practical. As a result, Enclosure 2 of Entergys August 23, 2012, letter, which contained the commitment for submittal of the ANO-1 NFPA 805 LAR by August 31, 2013, is modified by Enclosure 2 of this letter, committing to a new due date of January 31, 2014.
The total risk associated with the current plant will be addressed by the continuing compensatory measures currently applied for the existing Appendix R open items. In general, the reduced number of feasible operator manual actions (due to plant modifications completed since 2005), and the on-going mixture of roving and continuous fire watches will be maintained until the proposed modifications are implemented to remove the need for these interim compensatory measures. The primary contributor to the overall plant risk is Fire Area G, where the Alternate Shutdown measures for Appendix R are concentrated. Existing plant procedures for post-fire safe shutdown focus on this area. Operations personnel are currently trained and able to promptly respond to any postulated fire in this critical area, now well defined by the NFPA 805 risk analysis.
Attachments
- 1. ANO-1 NFPA 805 Modifications Design and Installation Schedule
- 2. ANO-1 NFPA 805 Modifications Timeline
Attachment 1 ANO-1 NFPA 805 Modifications Design and Installation Schedule
, Attachment 1 1CAN121202 Page 1 of 3 ANO-1 NFPA 805 Modifications Design and Installation Schedule The conceptual design stage includes a study of controlled drawings and physical walk-downs to ensure the modification is feasible.
With respect to the NFPA 805 transition project, this stage includes probabilistic risk assessment (PRA) engineer involvement to ensure conceptual designs meet the PRA-intended function. Following this stage, a detailed engineering study is performed, which provides a comprehensive description of the proposed design approach and a detailed technical scope evaluation of the project. The engineering study also provides definitive design and installation cost information as well as schedule information. The goal is to produce a document that clearly identifies the design scope, cost, and schedule. The final design phase follows these stages through completion of the detailed modification package. PRA engineer review and approval is required prior to final approval of the overall design modification package.
Conceptual Engineering Final Design Modification Description Installation Design Study Package (based on ANO-1 LAR Table S-1 numbering) Complete Complete Complete Complete S1-1 Additional Auxiliary Feedwater (AFW) source to Complete 03/01/2013 07/01/2015 1R26 / 1R27 Steam Generators S1-2 thru S1-6 Provide redundant DC control power to Switchgear A-1, A-2, A-3, H-1 and H-2 and Complete 10/25/2013 07/01/2014 1R26 / 1R27 re-route some cabling S1-7 and S1-8 4160V AC breaker circuit modification to prevent Complete 10/25/2013 07/01/2014 1R26 / 1R27 spurious operation of A-309 and A-409 S1-9 Incipient Fire Detection for Control Room Panel C20 Complete 09/06/2013 12/15/2013 1R25 / 1R26 S1-10 Air Operated Valve (AOV) CV-1052 (Quench Tank Drain)
Complete 08/16/2013 03/01/2015 1R26 circuit modification to preclude spurious operation S1-11 Motor Operated Valve (MOV) CV-1053 (Quench Tank Complete 08/16/2013 07/01/2015 1R27 Drain) circuit modification to preclude spurious operation S1-12 MOV CV-1221 (Letdown Isolation) circuit modification to Complete 07/01/2013 12/15/2013 1R25 preclude spurious operation
, Attachment 1 1CAN121202 Page 2 of 3 Conceptual Engineering Final Design Modification Description Installation Design Study Package (based on ANO-1 LAR Table S-1 numbering) Complete Complete Complete Complete S1-13 MOV CV-1405 (Emergency Core Cooling Reactor Building Sump Suction) circuit modification to preclude Complete 07/01/2013 12/15/2013 1R25 spurious operation S1-14 MOV CV-1406 (Emergency Core Cooling Reactor Building Sump Suction) circuit modification to preclude Complete 07/01/2013 12/15/2013 1R25 spurious operation S1-15 MOV CV-3643 (Service Water Auxiliary Cooling Water Complete 07/01/2013 12/15/2013 1R25 Supply) circuit modification to preclude spurious operation S1-16 AOV CV-4400 (Reactor Building Sump Drain) circuit Complete 08/16/2013 03/01/2015 1R26 modification to preclude spurious operation S1-17 MOV CV-4446 (Reactor Building Sump Drain) circuit Complete 08/16/2013 07/01/2015 1R27 modification to preclude spurious operation S1-18 MOV CV-5611 (Reactor Building Firewater Supply) circuit Complete 08/16/2013 12/01/2014 1R26 modification to preclude spurious operation S1-19 MOV CV-5612 (Reactor Building Firewater Supply) circuit Complete 08/16/2013 07/01/2015 1R27 modification to preclude spurious operation S1-20 thru S1-23 AOVs CV-7401, CV-7402, CV-7403, and CV-7404 (Reactor Building Purge Isolations)
Complete 08/16/2013 03/01/2015 1R26 / 1R27 circuit modifications to preclude spurious operations S1-24 thru S1-26 Circuit re-routes for Service Water Pump P-4A, Emergency Feedwater Pump P-7B, Complete 12/20/2013 07/01/2015 1R27 and Primary Makeup Pump P-36A to reduce risk of circuit failure in specific areas S1-27 thru S1-30 Service Water sluice gate valves SG-1, SG-2, SG-3, and SG-4 modifications to prevent Complete 03/15/2013 12/15/2013 1R25 spurious closure
, Attachment 1 1CAN121202 Page 3 of 3 Conceptual Engineering Final Design Modification Description Installation Design Study Package (based on ANO-1 LAR Table S-1 numbering) Complete Complete Complete Complete S1-31 Fire Barrier Upgrades Complete 09/23/2013 07/01/2015 1R26 S1-32 NFPA 50A Non-Compliance Corrections (related to Complete 02/14/2013 04/01/2014 12/15/2014 Hydrogen Gas Bottle Storage Room)
S1-33 NFPA 10 Non-Compliance Corrections (related to fire Complete 01/25/2013 04/01/2014 12/15/2014 extinguishers)
S1-34 NFPA 30 Oil Storage Tank Ventilation Air Duct Relocation Complete 09/27/2013 04/01/2014 12/15/2014 (related to Dirty and Clean Lube Oil Tank Room)
S1-35 MOVs CV-1050, CV-1410, and CV-1404 (Decay Heat Removal Suction Isolations) modification for NRC Complete 08/30/2013 07/01/2015 1R26 / 1R27 Information Notice (IN) 92-18 issues (associated with non-power operations)
Refueling outage 1R25 (red train outage) is scheduled for the fall of 2014 Refueling outage 1R26 (green train outage) is scheduled for the spring of 2016 Refueling outage 1R27 (red train outage) is scheduled for the fall of 2017
Attachment 2 ANO-1 NFPA 805 Modifications Timeline
, Attachment 3 1CAN121202 Page 1 of 5 ANO-1 NFPA 805 Modifications Timeline The following table provides a schedule view on a calendar quarter basis. Calendar quarters containing no information are used as contingency windows supporting unforeseen circumstances that could delay completion of modification preparations as currently scheduled.
ANO-1 Activities 2012 3rd Quarter License Amendment Request (LAR)
Conceptual Design for proposed modifications complete 4th Quarter ANO-2 NFPA 805 LAR Submittal 2013 1st Quarter ANO-1 NFPA 805 LAR Development Main Control Room Analysis Detailed Fire Modeling Focused Scope Peer Review Fire Risk Quantification Revised Fire (Probabilistic Risk Assessment) PRA Fire Risk Evaluations Engineering Study (ES) Completed S1 Auxiliary Feedwater source S1-27 thru S1 Service Water Sluice Gate Valves SG-1, SG-2, SG-3, and SG-4 S1 NFPA 50A Code Compliance Hydrogen Gas Bottle Storage S1 NFPA 10 Compliance (Fire Extinguishers) 1R24 Refueling Outage (Green Train)
(Completed Design Change packages required 9 months prior to outage)
, Attachment 3 1CAN121202 Page 2 of 5 ANO-1 Activities 2013 nd 2 Quarter 1R24 Refueling Outage (Green Train) (continued)
ANO-1 NFPA 805 LAR Development Finalize LAR Management Approval ANO-2 LAR NRC Audit (tentative)
NRC Request for Additional Information (RAIs) (tentative) 3rd Quarter ANO-1 NFPA 805 LAR Development Submit LAR ES Completed S1 Control Room Panel C20 Incipient Fire Detection S1 CV-1052 circuit modification S1 CV-1053 circuit modification S1 CV-1221 circuit modification S1 CV-1405 circuit modification S1 CV-1406 circuit modification S1 CV-3643 circuit modification S1 CV-4400 circuit modification S1 CV-4446 circuit modification S1 CV-5611 circuit modification S1 CV-5612 circuit modification S1-20 thru S1 CV-7401, CV-7402, CV-7403, and CV-7404 circuit modification S1 Fire Barrier Upgrades S1 NFPA 30 Code Compliance (Dirty and Clean Lube Oil Tank Room ventilation duct relocation)
S1 CV-1050, CV-1410, CV-1404 IN 92-18 modifications
, Attachment 3 1CAN121202 Page 3 of 5 ANO-1 Activities 2013 4th Quarter ES Completed S1-2 thru S1 DC Control Power S1-7 and S1 A-309 and A-409 4160V AC breaker circuit modification S1-24 thru S1 Circuit re-route for P-4A, P-7B, P-36A Design Complete S1 Control Room Panel C20 Incipient Fire Detection S1 CV-1221 circuit modification S1 CV-1405 circuit modification S1 CV-1406 circuit modification S1 CV-3643 circuit modification S1-27 thru S1 Service Water Sluice Gate Valves SG-1, SG-2, SG-3, and SG-4 2014 st 1 Quarter LAR Audit (tentative)
LAR RAIs (tentative) 2nd Quarter Design Complete S1 NFPA 50A Code Compliance Hydrogen Gas Bottle Storage S1 NFPA 10 Non-Compliance Corrections (Fire Extinguishers)
S1 NFPA 30 Code Compliance (Dirty and Clean Lube Oil Tank Room ventilation duct relocation) 2R23 Refueling Outage (Red Train) 3rd Quarter 2R23 Refueling Outage (Red Train) (continued)
Design Complete S1-2 thru S1 DC Control Power S1-7 & S1 A-309 and A-409 4160V AC breaker circuit modification
, Attachment 3 1CAN121202 Page 4 of 5 ANO-1 Activities 2014 th 4 Quarter 1R25 Refueling Outage (Red Train) (Modifications Installed)
S1 Control Room Panel C20 Incipient Fire Detection S1 CV-1221 circuit S1 CV-1405 circuit S1 CV-1406 circuit S1 CV-3643 circuit S1-27 thru S1 Service Water Sluice Gate Valves SG-1, SG-2, SG-3, and SG-4 Non-Outage Modifications Completed S1 NFPA 50A Code Compliance Hydrogen Gas Bottle Storage S1 NFPA 10 Non-Compliance Corrections (Fire Extinguishers)
S1 NFPA 30 Code Compliance (Dirty and Clean Lube Oil Tank Room ventilation duct relocation)
Design Complete S1 CV-5611 circuit modification 2015 1st Quarter Design Complete S1 CV-1052 circuit modification S1 CV-4400 circuit modification S1-20 thru S1 CV-7401, CV-7402, CV-7403, and CV-7404 circuit modification nd 2 Quarter 3rd Quarter Design Complete S1-1 Auxiliary Feed Water source S1 CV-1053 circuit modification S1 CV-4446 circuit modification S1 CV-5612 circuit modification S1-24 thru S1 Circuit re-route for P-4A, P-7B, P-36 S1 Fire Barrier Upgrades S1 CV-1050, CV-1410, and CV-1404 IN 92-18 modifications 2R24 Refueling Outage (Green Train) 4th Quarter 2R24 Refueling Outage (Green Train) (continued)
, Attachment 3 1CAN121202 Page 5 of 5 ANO-1 Activities 2016 st 1 Quarter 2nd Quarter 1R26 Refueling Outage (Green Train) (Modification Installation)
S1 Control Room Panel C20 Incipient Fire Detection S1-1 Auxiliary Feed Water source S1-2 thru S1 DC Control Power S1-7 & S1 A-309 and A-409 4160V AC breaker circuits S1 CV-1052 circuit S1 CV-4400 circuit S1 CV-5611 circuit S1-20 thru S1 CV-7401, CV-7402, CV-7403, and CV-7404 circuits S1 Fire Barrier Upgrades S1 CV-1050, CV-1410, CV-1404 IN 92-18 3rd Quarter 4th Quarter 2017 1st Quarter 2R26 Refueling Outage (Red Train) 2nd Quarter 2R26 Refueling Outage (Red Train) (continued) 3rd Quarter 4th Quarter 1R27 Refueling Outage (Red Train) (Modification Installation)
S1-1 Auxiliary Feed Water source S1-2 thru S1 DC Control Power S1-7 & S1 A-309 and A-409 4160V AC breaker circuits S1 CV-1053 circuit S1 CV-4446 circuit S1 CV-5612 circuit S1-20 thru S1 CV-7401, CV-7402, CV-7403, and CV-7404 circuit S1-24 thru S1 Circuit re-route for P-4A, P-7B, P-36A S1 CV-1050, CV-1410, CV-1404 IN 92-18
Enclosure 2 to 1CAN121202 List of Regulatory Commitments to 1CAN121202 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy Operations, Inc. (Entergy) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Check one)
COMMITMENT COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE Entergy will submit the License Amendment Request implementing January 31, 2014 10 CFR 50.48(c) for Arkansas Nuclear One, Unit 1