2CAN011102, Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend Type a Test Frequency to 15 Years

Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend Type a Test Frequency to 15 Years

ML110180087
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/17/2011
From:	Schwarz C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN011102
Download: ML110180087 (42)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 2CAN011102 January 17, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter dated June 17, 2010, License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years (2CAN061003)

2. NRC email dated November 23, 2010, Request for Additional Information (RAI) on License Amendment Request dated June 17, 2010, Technical Specification Change to Extend the Type A Test Frequency to 15 years - REVISION 1 (TAC No. ME4090)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS) via Reference 1. Specifically, the change would allow for the extension of the ten-year frequency of the ANO-2 Type A or Integrated Leak Rate Test (ILRT) required by TS 6.5.16 to 15 years on a permanent basis. In Reference 2, the NRC requested additional information (RAI) with regard to the Entergy request. The NRC requested the additional information to be submitted within 60 days.

In Reference 1, Entergy provided the most recent Type B and Type C test results and their comparison with the allowable leakage rates. RAI 2.1 (b) requested a summary of the performance results of these tests that would support the maximum and minimum Pathway Leakage values. In developing the response to the RAI, it was determined that the information that was provided in Reference 1, while conservative, was not correct. The maximum and minimum leakage values from Reference 1 and the corrected values are presented below.

The details are provided in the response to the RAI.

2CAN011102 Page 2 of 3 2R19 As-Found Minimum From Reference 1 Corrected 8,168 standard cubic centimeters per minute (sccm) 7,847 sccm As-Left Maximum 17,561 sccm 17,466 sccm 2R20 As-Found Minimum 9,373 sccm 9,372 sccm As-Left 18,810 sccm 18,162 sccm The combined Type B and Type C leakage acceptance criterion remains 103,894 sccm and did not change. This error has been discussed with the NRR Project Manager and is being addressed in the ANO corrective action program.

It should be noted that Reference 2 contained an RAI to discuss how the Type B and C test intervals were implemented in the current testing program and how they would be implemented using NEI 94-01, Revision 2-A (RAI 2.1(d)). Based on discussions with the NRC Project Manger, it was determined that Entergy was not required to respond to that particular RAI. Therefore that RAI is not listed in the attachment nor is a response provided.

The attachment to this letter provides the requested information.

There are no new commitments in this letter.

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 January 17, 2011.

Sincerely, Original signed by Christopher J. Schwarz CJS/rwc

Attachment:

Request for Additional Information

2CAN011102 Page 3 of 3 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 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

Attachment to 2CAN011102 Request for Additional Information

Attachment to 2CAN011102 Page 1 of 38 REQUEST FOR ADDITIONAL INFORMATION 1.1 Since degradation of bellows is a source for potential leakage, the staff requests the licensee to please identify any bellows used on penetrations through containment pressure retaining boundaries, and if present, provide information on their location, inspection, testing and operating experience with regard to detection of leakage.

Arkansas Nuclear One, Unit 2 (ANO-2) does not employ bellows on penetrations through containment pressure retaining boundaries.

1.2 The staff notes that the licensees stated intent, as indicated throughout the LAR (see sections 1.0, 2.0 and 4.0), is to implement a containment leakage rate testing program in accordance with the guidelines contained in NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated October 2008.

However, in page 5 of the LAR the licensee states the following:

The proposed change replaces the reference to RG 1.163 with a reference to NEI 94-01; however, the proposed TS change is worded to indicate that the Appendix J Testing Program must be in accordance with NRC-reviewed and accepted guidelines (i.e., NEI 94-01), with the specific version of those guidelines specified in the Appendix J Testing Program Plan. These proposed TS changes are consistent with the regulatory requirement to include the implementation document used to develop the performance-based leakage testing program, by general reference, in the plant TS, and assures that only NRC-reviewed and accepted guidance is used to develop the program. In addition, these changes will allow the use of later NRC-accepted versions of NEI 94-01 without the unnecessary burden of processing a license amendment.

The above is not consistent with the intent of the LAR nor does it reflect that any changes to the containment Type A testing program that are not in accordance with the guidance provided with NEI-94-01, Rev 2-A would require NRC approval before implementation.. The staff requests that the licensee revise or clarify the statement made in page 5 of the LAR.

Upon further review, Entergy agrees that the paragraph in question is not consistent with the rest of the LAR nor its intent to implement a containment leakage rate testing program in accordance with the guidelines contained in NEI 94-01, Revision 2-A. This paragraph should be deleted and no further NRC consideration be given to it. The deletion of this paragraph does not alter the remaining portions of the LAR.

Attachment to 2CAN011102 Page 2 of 38 2.1. In order for the NRC staff to assess the proper and effective implementation of the Type B and Type C local leak rate testing program, the licensee is requested to provide:

(a) A table of all containment pressure boundary components at ANO-2 that are subject to the Type B and Type C testing, under the Containment Leakage Rate Testing Program, with the current test frequency and the approximate dates (or refueling outage) of the last test and the next scheduled test.

Table 2.1-1 of this attachment provides the requested information.

(b) Provide a summary of performance results for Type B and Type C testing that would support the maximum and minimum Pathway Leakage values detailed in section 4.2 of the LAR.

The Type B and Type C performance results from the last two ANO-2 refueling outages (2R19 and 2R20) are provided in Table 2.1-2. 2R19 occurred in the Spring of 2008 and 2R20 occurred in the Fall of 2009.

(c) A summary table of LLRT results of those containment penetrations (including their test schedule intervals) that have not demonstrated acceptable performance history in accordance with the Containment Leakage Rate Program and a discussion of the causes and corrective actions taken.

Table 2.1-3 of this attachment provides a summary of the containment penetrations that did not demonstrate acceptable performance during 2R19 and 2R20.

(d) A discussion of whether there have been any refueling outages since the last Type A test in which the combined leakage from Type B and Type C tests did not meet the acceptance criteria. Please provide a discussion of the results, cause(s), and corrective actions taken.

The as-found combined leakage from Type B and Type C tests are evaluated by summation of the limiting pathway leak rate measurement of each penetration. This pathway is the smaller of the inboard and outboard leak rate measurement. This summation determines the as-found Type B and Type C leak rate on a minimum path basis. There has been no outage since the last Type A test (conducted in November 2000) in which the combined as-found minimum path leak rate from Type B and Type C tests exceeded acceptance criteria specified in ANO-2 Technical Specifications (0.6 La).

Attachment to 2CAN011102 Page 3 of 38 2.2 Please provide a summarized Table containing the previous ANO-2 ILRT Type A tests data, including the completion dates of the last two tests, actual as-found results data as well as the allowable TS acceptance criterion values for those tests that confirm that the containment structure leakage is acceptable.

Table 2.2-1 provides the results of the ILRT Type A tests.

TABLE 2.2-1 ILRT Type A Test Results Calculated Leakage Rate Completion Date Mass Point Calculation 95% Upper Confidence Level May 31, 1981 0.028% / day 0.033% / day (Note 1)

May 1, 1985 0.022% / day 0.023% / day (Note 1)

April 22, 1988 0.028% / day 0.032% / day (Note 1)

April 9, 1991 0.0197% / day 0.0229% / day (Note 1)

March 17, 1994 0.0517% / day 0.0553% / day (Note 1)

November 30, 2000 0.049% /day 0.056% /day (Note 2)

Note 1: Percent of containment air weight per day at Pa (54 psig).

Note 2: Percent of containment air weight per day at Structural Integrity Test pressure (68 psig).

ILRT Acceptance Criteria is 0.075% /day (ANO-2 Technical Specification 6.5.16).

2.3 In regards to the ANO-2 Containment Inservice Inspection Plan (CISI), an extension to a 15-year ILRT interval would span at least four ISI inspection periods. Please provide a schedule, with approximate dates (or refueling outage) of the next general visual examinations to be performed in order to satisfy the requirements of NEI 94-01 Rev. 2-A, section 9.2.3.2.

The 30th Year Containment inspection for ANO-2 was conducted during June 2010. No recordable indications were observed during the general exterior inspection of the containment structure. Based on the data that was collected during the 2010 30th Year Containment IWL inspection, the conclusion was reached that no new abnormal degradation of the post tensioning system has occurred with regard to the ANO-2 containment structure.

Attachment to 2CAN011102 Page 4 of 38 The 35th Year inspection is currently scheduled to be performed in March 2014 and the 40th Year inspection is scheduled for the Fall of 2018.

A visual examination of the interior of the ANO-2 containment (i.e., the liner) is performed once each ISI period. This equates to three exams during the 10-year interval. No unacceptable indications have been identified to date.

2.4 Consistent with NRC Information Notice 2004-09, Corrosion of Steel Containment and Containment Liner, discuss the operating experience and evaluation results, if any, of the potential for, or presence of corrosive conditions at the junction of the metal liner and interior concrete floor, including the potential for stagnant water behind a degraded floor seal area that may promote pitting corrosion.

The 1992 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, Table IWE-2500-1, Examination Category E-D, Item E5.30, requires that 100% of the moisture barrier be examined each interval.

ANO-2 is committed to conducting this examination each inspection period.

In January 1999, the moisture barrier seal was removed, cleaned and inspected.

Several areas at the junction of the metal liner and interior concrete floor were found to have rust with some localized pitting / degradation. The metal liner was found to have sufficient thickness and was recoated using approved Service Level I coating specification. A new moisture barrier was installed after the final acceptance of the Service Level I coating. Several areas outside of the metal liner interior concrete floor interface were also found to have rust. Based on these results, a random sampling was performed to ensure that the findings were not structurally significant.

It was noted during the walkdowns that some of the premolded material below the Primary Wall gap, normally found below the gap sealant, was missing in some cases.

Boroscope probes revealed no structural degradation. Therefore, the sealant was replaced along with a suitable backup rod / material to prevent the sealant from moving out of position.

No significant liner plate pitting or degradation was noted as a result of this random sampling. It was determined that the liner plate degraded areas could be left as-found once the coating, gap sealant, etc. was re-applied. All the reported liner plate thicknesses were within a few thousandths of the required 1/4 thickness.

During the Fall of 2000 (2R14) inspection of the moisture barrier, no degradation was found.

During 2R17 (Spring of 2005), a total of 87 areas were identified as defects during the IWE VT-3 examination. There were 79 tear areas, four damaged areas, three wear areas and one other area which was a piece of wire that was stuck into the caulk. All of these areas were repaired and reinspected. No corrosion was noted during the examination in any of the defect areas.

Attachment to 2CAN011102 Page 5 of 38 The moisture barrier was again inspected during 2R18 (Fall of 2006). Seven areas were identified as defects during this inspection. These defects were repaired and reinspected.

In the Spring of 2008 (2R19), the moisture barrier was inspected. During this inspection three damage areas were identified. These areas penetrated completely through the moisture barrier caulk membrane. There was no evidence of water in the vicinity or penetrating to the substrate below the damaged barrier.

In the last refueling outage in the fall of 2010 (2R20), no evidence of defects was identified in the moisture barrier.

2.5 In response to Condition 4 in Section 4.1 of the NRC SE for topical report NEI 94-01, Revision 2-A, the ANO-2 response in Item 4 of the Table on page 5 of 14 of the LAR states that, The design change process will address any testing requirements for this potential and any future containment structure modifications.

(a) Describe how the above statement addresses the requirements of Condition 4 of Section 4.1 and as discussed in Section 3.1.4 of the NRC safety evaluation for NEI 94-01, Revision 2-A, with regard to major and minor containment repairs and modifications.

The design change process at Entergy is governed by an Entergy fleet procedure. The two purposes for this procedure are as follows:

1. This procedure is a part of the Entergy Nuclear standard process for Engineering Changes (ECs), from EC development through closure. This procedure shall be used in conjunction with other procedures governing the Plant Configuration Change Process.

2. This procedure is the single process governing an Engineering Change, including changes to plant related structures, systems, and components (SSCs).

The design change procedure requires that an Impact Screening be performed for engineering changes requiring modifications to plant SSCs. An Impact Screening is defined as a list of engineering considerations to determine engineering programs, engineering disciplines or departmental impact and required input. The Impact Screening provides a disciplined and consistent approach for determining the interfaces associated with an engineering change and/or other pertinent discipline design considerations. The Impact Screening is performed to determine program impact and to determine external department impact considerations during engineering change development. An attachment to the procedure is the Impact Screening Summary which contains questions on the subject of engineering disciplines, maintenance, process or programs, and programs and components that are to be reviewed for impacts based on the scope of the proposed modification. As part of this attachment

Attachment to 2CAN011102 Page 6 of 38 are specific questions pertaining to the ASME Containment In-Service Inspection (CISI) Program, ASME Appendix J (Primary Containment Leak Rate Testing) Program, and ASME Section XI Repair/Replacement Program.

Therefore, when performing the Impact Screening, the screener is prompted for potential impacts to these programs based on the scope of the proposed modification and the applicable program owner is subsequently consulted for further required actions including testing requirements by that program.

The design change procedure also requires, as part of the process, that a Process Applicability Determination (PAD) in accordance with another Entergy fleet procedure be performed for engineering changes requiring modifications and/or evaluations where no installation is required, accept as-is configurations or optional alternative configurations. The purpose of the PAD is to determine:

1. Which plant licensing basis documents (LBDs) and processes are affected by a proposed activity and must be revised to reflect the activity,

2. The appropriate regulatory review (i.e., 10 CFR 50.59) or industry code review that is required for implementing a proposed activity, and

3. Whether an activity requires review in a 10 CFR 50.59 evaluation. Based on the results of the evaluation the proposed modification or activity may require prior NRC approval.

In summary, based on the above discussion, the design change process at Entergy, utilizing the Impact Screening, PAD, and 10 CFR 50.59 Evaluation as required by established company procedures, ensures that the requirements of Condition 4 of Section 4.1 and as discussed in Section 3.1.4 of the NRC safety evaluation for NEI 94-01, Revision 2-A with regard to major and minor containment repairs and modifications would be met.

(b) Address why it is appropriate to make reference to a design change process, which is not subject to NRC review, in an application for a licensing action.

As described above, the design change process utilized by Entergy ensures that, if required, the NRC review of any proposed modifications is obtained prior to the installation of the modification.

(c) Clarify whether the repair/replacement program, which includes associated post modification testing for the ANO-2 containment structure, is performed as part of the CISI program in accordance with 10 CFR 50.55a(g)(4) or as part of the station design change process.

The ANO-2 ASME Section XI Repair / Replacement Program provides the requirements for performing repair / replacement activities to Class MC components and component supports and Class CC concrete containments as required by 10 CFR 50.55a. The design change process is separate from this

Attachment to 2CAN011102 Page 7 of 38 program; however it is used to facilitate / implement the requirements of the Repair/Replacement Program.

Attachment to 2CAN011102 Page 8 of 38 TABLE 2.1-1 ANO-2 COMPONENT PRESSURE BOUNDARY COMPONENTS SUBJECT TO TYPE B AND TYPE C TESTING Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-6 Out 2SV-8231-2 RX Bldg HVAC Hydrogen 9/6/2009 2R23 Spring 2014 3R (54 months)

(H2) Purge Inlet In 2CV-8233-1 RX Bldg HVAC H2 Purge 10/4/2006 2R21 Spring 2011 3R (54 months)

Inlet Out Blind Flange RX Bldg HVAC H2 Purge & 9/20/2009 2R23 Spring 2014 3R (54 months)

Containment Air Monitoring (CAM) Return Out 2SV-8280 RX Bldg HVAC H2 Purge & 9/20/2009 2R23 Spring 2014 3R (54 months)

CAM Return Out 2HPA-2 RX Bldg HVAC H2 Purge & 9/20/2009 2R23 Spring 2014 3R (54 months)

CAM Return Out 2SV-8271-2 RX Bldg HVAC H2 Purge 9/7/2009 2R23 Spring 2014 3R (54 months)

Outlet In 2SV-8273-1 RX Bldg HVAC H2 Purge 9/7/2009 2R23 Spring 2014 3R (54 months)

Outlet Out 2SV-8278-1 RX Bldg HVAC H2 Purge & 9/7/2009 2R23 Spring 2014 3R (54 months)

CAM Supply Out Blind Flange RX Bldg HVAC H2 Purge & 9/7/2009 2R23 Spring 2014 3R (54 months)

CAM Supply Out 2HPA-1 RX Bldg HVAC H2 Purge & 9/7/2009 2R23 Spring 2014 3R (54 months)

CAM Supply Out Closed Loop RX Bldg HVAC H2 Analyzer 1/31/2006 1/31/2011 60 Months 2C-128A

Attachment to 2CAN011102 Page 9 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-8 Out 2SV-5843-2 Pressurizer (Pzr) & Reactor 9/4/2009 2R23 Spring 2014 3R (54 months)

Coolant System (RCS)

Sample In 2SV-5833-1 Pzr & RCS Sample 9/4/2009 2R23 Spring 2014 3R (54 months) 2P-9 Out 2CV-6207-2 Nitrogen (N2) Supply to 9/29/2006 2R21 Spring 2011 3R (54 months)

Safety Injection (SI) Tanks In 2N2-18 N2 Supply to SI Tanks 3/21/2008 2R22 Fall 2012 3R (54 months) 2P-14 Out 2CV-4823-2 Chemical & Volume Control 9/7/2009 2R23 Spring 2014 3R (54 months)

(CVCS) Letdown In 2CV-4821-1 CVCS Letdown 9/18/2009 2R23 Spring 2014 3R (54 months) 2P-18 In 2CV-4846-1 CVCS Reactor Coolant 9/6/2009 2R23 Spring 2014 3R (54 months)

Pump (RCP) Seal Water Out 2CV-4847-2 CVCS RCP Seal Water 3/29/2008 2R22 Fall 2012 3R (54 months)

In 2PSV-1801 CVCS RCP Seal Water 3/29/2008 2R22 Fall 2012 3R (54 months) 2P-19 Out 2FP-34 Fuel Pool Refuel Canal 9/8/2009 2R23 Spring 2014 3R (54 months)

Recirculation Line 2P-33 In 2CV-5082 SI Tank Drain 9/26/2006 2R21 Spring 2011 3R (54 months)

Out 2SI-17 SI Tank Drain 9/26/2006 2R21 Spring 2011 3R (54 months)

In 2PSV-5000 SI Tank Drain 9/26/2006 2R21 Spring 2011 3R (54 months)

Out 2SI-5115A SI Tank Drain 9/26/2006 2R21 Spring 2011 3R (54 months)

Attachment to 2CAN011102 Page 10 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-37 Out 2SV-5871-2 Sample Quench Tank Liquid 9/7/2009 2R23 Spring 2014 3R (54 months)

Sample In 2SV-5878-1 Sample Quench Tank Liquid 9/7/2009 2R23 Spring 2014 3R (54 months)

Sample Out 2SV-5876-2 Sample SI Tank Sample 9/29/2006 2R21 Spring 2011 3R (54 months)

In 2SV-5872 Sample SI Tank Sample 9/29/2006 2R21 Spring 2011 3R (54 months)

In 2SV-5873 Sample SI Tank Sample 9/29/2006 2R21 Spring 2011 3R (54 months)

In 2SV-5874 Sample SI Tank Sample 9/29/2006 2R21 Spring 2011 3R (54 months)

In 2SV-5875 Sample SI Tank Sample 9/29/2006 2R21 Spring 2011 3R (54 months) 2P-39 Out 2CV-4690-2 Quench Tank Make-Up 3/27/2008 2R22 Fall 2012 3R (54 months)

In 2CVC-78 Quench Tank Make-Up 9/11/2009 2R23 Spring 2014 3R (54 months) 2P-40 In 2FS-37 Fire Water Supply To RX 3/26/2008 2R22 Fall 2012 3R (54 months)

Building Out 2CV-3200-2 Fire Water Supply To RX 3/24/2008 2R22 Fall 2012 3R (54 months)

Building 2P-41 Out 2CV-6213-2 N2 Addition Low Pressure 9/8/2009 2R23 Spring 2014 3R (54 months)

(LP) N2 Supply In 2N2-1 N2 Addition LP N2 Supply 9/10/2009 2R21 Spring 2011 1R (18 months) 2P-42 Out 2PH-45 Plant Heating Rx Bldg 9/24/2006 2R21 Spring 2011 3R (54 months)

Return In 2PH-44 Plant Heating Rx Bldg 9/24/2006 2R21 Spring 2011 3R (54 months)

Return

Attachment to 2CAN011102 Page 11 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-43 Out 2SA-68 SA Rx Bldg Supply 10/16/2006 2R21 Spring 2011 3R (54 months)

In 2SA-69 SA Rx Bldg Supply 10/16/2006 2R21 Spring 2011 3R (54 months) 2P-46 Out 2BA-217 Breathing Air Rx Bldg 9/15/2009 2R23 Spring 2014 3R (54 months)

Supply In 2BA-216 Breathing Air Rx Bldg 9/15/2009 2R23 Spring 2014 3R (54 months)

Supply 2P-48 Out 2PH-22 Plant Heating Rx Bldg 9/24/2006 2R21 Spring 2011 3R (54 months)

Supply In 2PH-23 Plant Heating Rx Bldg 3/21/2008 2R22 Fall 2012 3R (54 months)

Supply 2P-51 Out 2CV-3852-1 Chill Water Supply To Rx 10/19/2006 2R21 Spring 2011 3R (54 months)

Bldg In 2AC-49 Chill Water Supply To Rx 10/20/2006 2R21 Spring 2011 3R (54 months)

Bldg 2P-52 Out 2CV-5236-1 Component Cooling Water 9/12/2009 2R23 Spring 2014 3R (54 months)

To RCP Coolers In 2PSV-5249 Component Cooling Water 9/12/2009 2R23 Spring 2014 3R (54 months)

To RCP Coolers In 2CCW-38 Component Cooling Water 9/21/2009 2R21 Spring 2011 1R (18 months)

To RCP Coolers 2P-53 In Blind Flange Outage Use 9/19/2009 2R23 Spring 2014 3R (54 months)

Out Blind Flange Outage Use 9/19/2009 2R23 Spring 2014 3R (54 months)

Attachment to 2CAN011102 Page 12 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-58 Out 2SV-8261-2 Rx Bldg HVAC CAM 9/5/2009 2R23 Spring 2014 3R (54 months)

Discharge In 2SV-8259-1 Rx Bldg HVAC CAM 9/3/2009 2R23 Spring 2014 3R (54 months)

Discharge Out 2C-128B Rx Bldg HVAC Hydrogen 9/5/2009 2R23 Spring 2014 3R (54 months)

(H2) Analyzer Closed Loop Out 2SV-8260-2 Rx Bldg HVAC CAM Supply 9/3/2009 2R23 Spring 2014 3R (54 months)

& Return Out 2SV-8262-2 Rx Bldg HVAC CAM Supply 9/4/2009 2R23 Spring 2014 3R (54 months)

& Return Out 2SV-8263-2 Rx Bldg HVAC CAM Suction 9/4/2009 2R23 Spring 2014 3R (54 months)

In 2SV-8265-1 Rx Bldg HVAC CAM Suction 9/4/2009 2R23 Spring 2014 3R (54 months) 2P-59 Out 2CV-3851-1 Chilled Water Rx Bldg 3/30/2008 2R22 Fall 2012 3R (54 months)

Return In 2PSV-3805 Chilled Water Rx Bldg 3/30/2008 2R22 Fall 2012 3R (54 months)

Return In 2CV-3850-2 Chilled Water Rx Bldg 3/30/2008 2R22 Fall 2012 3R (54 months)

Return

Attachment to 2CAN011102 Page 13 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-60 Out 2CV-5255-1 Component Cooling Water 9/13/2009 2R23 Spring 2014 3R (54 months)

From RCP Coolers In 2CV-5154-2 Component Cooling Water 9/13/2009 2R23 Spring 2014 3R (54 months)

From RCP Coolers In 2PSV-5256 Component Cooling Water 9/13/2009 2R23 Spring 2014 3R (54 months)

From RCP Coolers 2P-61 In Blind Flange Instrument Air (IA) 9/14/2009 2R26 Fall 2018 6R (108 Months)

Integrated Leak Rate Test (ILRT) Sensing Lines Out 2IA-88 IA ILRT Sensing Lines 9/14/2009 2R23 Spring 2014 3R (54 months)

In Blind Flange IA ILRT Sensing Lines 9/14/2009 2R26 Fall 2018 6R (108 Months)

Out 2IA-89 IA ILRT Sensing Lines 9/14/2009 2R23 Spring 2014 3R (54 months) 2P-62 In Blind Flange IA ILRT Pressure 9/14/2009 2R26 Fall 2018 6R (108 Months)

Out Blind Flange IA ILRT Pressure 9/14/2009 2R26 Fall 2018 6R (108 Months) 2P-66 Out 2SV-5633-1 Post Accident Sampling Sys 9/2/2009 2R23 Spring 2014 3R (54 months)

Return & Rx Bldg Sump Suction Out 2SV-5633-2 Post Accident Sampling Sys 9/2/2009 2R23 Spring 2014 3R (54 months)

Return & Rx Bldg Sump Suction

Attachment to 2CAN011102 Page 14 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2P-67 Out 2SV-5634-1 Post Accident Sampling 9/3/2006 2R23 Spring 2014 3R (54 months)

Supply & Rx Bldg Sump Suction Out 2SV-5634-2 Post Accident Sampling 9/3/2006 2R23 Spring 2014 3R (54 months)

Supply & Rx Bldg Sump Suction 2P-68 Out 2CV-2061-2 Containment Sump Drain 9/5/2009 2R21 Spring 2011 1R (18 months)

Out 2PSV-2000 Containment Sump Drain 9/5/2009 2R21 Spring 2011 1R (18 months)

In 2CV-2060-1 Containment Sump Drain 9/19/2009 2R21 Spring 2011 1R (18 months) 2P-69 Out 2CV-2201-2 Boron Mgmt Reactor Drain 3/31/2008 2R21 Spring 2011 3R (54 months)

Tank (RDT) Discharge In 2PSV-2200 Boron Mgmt RDT Discharge 3/31/2008 2R22 Fall 2012 3R (54 months)

In 2CV-2202-1 Boron Mgmt RDT Discharge 10/7/2006 2R23 Spring 2014 3R (54 months) 2V-1 Out 2CV-8284-2 HVAC Containment Bldg 9/21/2009 2R21 Spring 2011 1R (18 Months)

Purge Inlet Out 2CV-8483-1 HVAC Containment Bldg 9/21/2009 2R21 Spring 2011 1R (18 Months)

Purge Inlet 2V-2 Out 2CV-8286-2 HVAC Containment Bldg 9/21/2009 2R21 Spring 2011 1R (18 Months)

Purge Return Out 2CV-8285-1 HVAC Containment Bldg 9/21/2009 2R21 Spring 2011 1R (18 Months)

Purge Return 2C-1 In/Out 2C-1 RX Bldg Access 9/20/2009 2R21 Spring 2011 1R (18 Months)

Equipment Hatch

Attachment to 2CAN011102 Page 15 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2C-2 Out 2C-2 RX Bldg Access 9/18/2009 2R21 Spring 2011 1R (18 Months)

Emergency Escape Hatch Barrel In 2C-2 RX Bldg Access 9/18/2009 2R21 Spring 2011 1R (18 Months)

Emergency Escape Hatch Inner Door Seal Out 2C-2 RX Bldg Access 9/18/2009 2R21 Spring 2011 1R (18 Months)

Emergency Escape Hatch Outer Door Seal 2C-3 In/Out 2C-3 Fuel Transfer System 9/19/2009 2R21 Spring 2011 1R (18 Months)

Fuel Transfer Tube Blind Flange 2C-4 Out 2C-4 RX Bldg Access 9/20/2009 2R21 Spring 2011 1R (18 Months)

Personnel Hatch Barrel In 2C-4 RX Bldg Access 9/8/2010 2R21 Spring 2011 1R (18 Months)

Personnel Hatch Inner Door Seal Out 2C-4 RX Bldg Access 9/8/2010 2R21 Spring 2011 1R (18 Months)

Personnel Hatch Outer Door Seal 2E-1 In/Out 2E-1 Safeguard (SFGRD) 7/27/2006 2R24 Fall 2015 6R (108 Months)

(2WR-26-1)

Electrical Penetration

Attachment to 2CAN011102 Page 16 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2E-4 In/Out 2E-4 SFGRD (2WR-42-1) 7/25/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-5 In/Out 2E-5 SFGRD (2WR-43-3) 7/26/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-6 In/Out 2E-6 SFGRD (2WR-25-1) 7/25/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-7 In/Out 2E-7 SFGRD (2WR-25-3) 7/26/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-8 In/Out 2E-8 SFGRD (2WR-25-5) 7/26/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-9 In/Out 2E-9 SFGRD (2WR-27-1) 7/24/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-10 In/Out 2E-10 SFGRD (2WR-40-1) 7/25/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-11 In/Out 2E-11 SFGRD (2WR-41-1) 7/25/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-14 In/Out 2E-14 SFGRD (2WR-25-7) 7/25/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-22 In/Out 2E-22 NON-SFGRD (2WR-23-1) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-23 In/Out 2E-23 NON-SFGRD (2WR-24-1) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration

Attachment to 2CAN011102 Page 17 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2E-24 In/Out 2E-24 NON-SFGRD (2WR-23-2) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-25 In/Out 2E-25 NON-SFGRD (2WR-26-3) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-27 In/Out 2E-27 NON-SFGRD (2WR-21-1) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-28 In/Out 2E-28 NON-SFGRD (2WR-28-1) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-32 In/Out 2E-32 NON-SFGRD (2WR-27-3) 5/18/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-33 In/Out 2E-33 SFGRD (2WR-42-3) 5/19/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-34 In/Out 2E-34 NON-SFGRD (2WR-43-1) 5/19/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-35 In/Out 2E-35 NON-SFGRD (2WR-43-5) 5/19/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-36 In/Out 2E-36 NON-SFGRD (2WR-21-3) 5/19/2009 2R26 Fall 2018 6R (108 Months)

Electrical Penetration 2E-41 In/Out 2E-41 SFGRD (2WR-25-2) 1/8/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-42 In/Out 2E-42 SFGRD (2WR-43-2) 1/7/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration

Attachment to 2CAN011102 Page 18 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2E-43 In/Out 2E-43 SFGRD (2WR-42-2) 1/7/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-44 In/Out 2E-44 SFGRD (2WR-41-2) 1/7/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-45 In/Out 2E-45 SFGRD (2WR-26-2) 9/3/2009 2R21 Spring 2011 1R (18 Months)

Electrical Penetration 2E-50 In/Out 2E-50 SFGRD (2WR-25-6) 1/8/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-51 In/Out 2E-51 SFGRD (2WR-25-4) 1/8/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-53 In/Out 2E-53 SFGRD (2WR-40-2) 1/7/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-54 In/Out 2E-54 SFGRD (2WR-27-2) 1/7/2008 2R25 Spring 2017 6R (108 Months)

Electrical Penetration 2E-55 In/Out 2E-55 NON-SFGRD (2WR-21-4) 3/13/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration 2E-59 In/Out 2E-59 NON-SFGRD (2WR-22-2) 3/2/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration 2E-60 In/Out 2E-60 NON-SFGRD (2WR-22-1) 2/28/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration 2E-61 In/Out 2E-61 NON-SFGRD (2WR-26-4) 2/28/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration

Attachment to 2CAN011102 Page 19 of 38 Pen. No. In / Out Component Component Description Last Test Next Test Due Current Test Board No. Date Date Frequency 2E-63 In/Out 2E-63 NON-SFGRD (2WR-21-2) 3/13/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration 2E-66 In/Out 2E-66 NON-SFGRD (2WR-43-4) 8/18/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-67 In/Out 2E-67 NON-SFGRD (2WR-42-4) 8/17/2006 2R24 Fall 2015 6R (108 Months)

Electrical Penetration 2E-71 In/Out 2E-71 NON-SFGRD (2WR-27-4) 2/28/2005 2R23 Spring 2014 6R (108 Months)

Electrical Penetration

Attachment to 2CAN011102 Page 20 of 38 TABLE 2.1-2 TYPE B AND TYPE C PERFORMANCE RESULTS FROM LAST TWO ANO-2 REFUELING OUTAGES (2R19 AND 2R20)

Pathway Leakage (sccm)

As-Found Minimum As-Left Maximum Penetration 2R19 2R20 2R19 2R20 2P-6 457 117 2942 531 2P-8 52 13 108 108 2P-9 63 63 98 98 2P-14 27 11 361 360 2P-18 310 367 580 580 2P-19 39 30 39 30 2P-33 375 375 745 745 2P-37 117 72 169 118 2P-39 34 52 52 88 2P-40 69 310 610 610 2P-41 129 350 513 400 2P-42 10 10 1200 1200 2P-43 5 5 225 225 2P-46 10 0 28 6 2P-48 40 40 950 950 2P-51 8 8 82 82 2P-52 2440 1580 2720 2980 2P-53 36 6 71 11 2P-58 261 175 367 296

Attachment to 2CAN011102 Page 21 of 38 Pathway Leakage (sccm)

As-Found Minimum As-Left Maximum Penetration 2R19 2R20 2R19 2R20 2P-59 480 365 370 370 2P-60 175 715 460 920 2P-61A 3 44 6 87 2P-61B 21 9 42 17 2P-62 3 0 5 0 2P-66 18 0 151 63 2P-67 4 5 109 111 2P-68 1520 3500 1520 3500 2P-69 248 78 88 88 2V-1 195 3 195 1209 2V-2 2 3 2 2 2C-1 261 290 2020 1190 2C-2 110 3 220 1030 2C-3 4 28 4 28 2C-4 94 430 187 83 2E-1 0 0 0 0 2E-4 0 0 0 0 2E-5 0 0 0 0 2E-6 0 0 0 0 2E-7 0 0 0 0 2E-8 8 8 8 8

Attachment to 2CAN011102 Page 22 of 38 Pathway Leakage (sccm)

As-Found Minimum As-Found Maximum Penetration 2R19 2R20 2R19 2R20 2E-9 1 1 1 1 2E-10 1 1 1 1 2E-11 0 0 0 0 2E-14 1 1 1 1 2E-22 2 0 2 0 2E-23 0 0 0 0 2E-24 6 3 6 3 2E-25 2 2 2 2 2E-27 0 2 0 2 2E-28 5 2 5 2 2E-32 0 1 0 1 2E-33 1 0 1 0 2E-34 0 2 0 2 2E-35 0 3 0 3 2E-36 1 3 1 3 2E-41 0 0 0 0 2E-42 0 0 0 0 2E-43 0 0 0 0 2E-44 0 0 0 0 2E-45 183 272 183 1 2E-50 0 0 0 0

Attachment to 2CAN011102 Page 23 of 38 Pathway Leakage (sccm)

As-Found Minimum As-Found Maximum Penetration 2R19 2R20 2R19 2R20 2E-51 0 0 0 0 2E-53 0 0 0 0 2E-54 0 0 0 0 2E-55 1 1 1 1 2E-59 13 13 13 13 2E-60 0 0 0 0 2E-61 0 0 0 0 2E-63 1 1 1 1 2E-66 0 0 0 0 2E-67 1 1 1 1 2E-71 0 0 0 0 Totals 7847 9372 17466 18162

Attachment to 2CAN011102 Page 24 of 38 TABLE 2.1-3

SUMMARY

OF CONTAINMENT PENETRATIONS THAT DID NOT DEMONSTRATE ACCEPTABLE PERFORMANCE 2R19 Component (Penetration) Test Administrative As-Found Cause / Corrective Action As-Left Interval Limit Leakage Leakage 2CV-2061-2 / 2PSV-2000 18 months 2500 sccm 4700 sccm Debris / Air Purge 370 sccm (Penetration 68 Outboard) 2C-1 18 months 600 sccm 261 sccm Torqued Equipment Hatch Closure 2020 sccm (Equipment Hatch) 2R20 Component (Penetration) Test Administrative As-Found Cause / Corrective Action As-Left Interval Limit Leakage Leakage 2CV-2061-2 / 2PSV-2000 18 months 2500 sccm 6000 sccm Debris / Air Purge 2370 sccm (Penetration 68 Outboard) 2CV-2060-1 60 months 3000 sccm 3500 sccm Debris / Air Purge 3500 sccm (Penetration 68 Inboard) prior to 2R20.

Test interval reduced to 18 months 2N2-1 18 months 1500 sccm Not Insufficient air flow to close check valve. 400 sccm (Penetration 41 Inboard) measureable Changed test procedure to use higher capacity pressurization source.

Attachment to 2CAN011102 Page 25 of 38 Component (Penetration) Test Administrative As-Found Cause / Corrective Action As-Left Interval Limit Leakage Leakage 2CCW-38 60 months 7000 sccm Not Insufficient air flow to close check valve. 2300 sccm (Penetration 52 Inboard) prior to measureable Changed test procedure to use higher 2R20. capacity pressurization source.

Test interval reduced to 18 months 2E-45 18 months 200 sccm 272 sccm Module D repaired with new seals 1 sccm (Electrical Penetration) 2C-1 18 months 600 sccm 290 sccm Torqued Equipment Hatch Closure 1190 sccm (Equipment Hatch)

Attachment to 2CAN011102 Page 26 of 38 3.1 The discussion of PRA quality relies on a Peer Review of the ANO2 Probabilistic Risk Analysis (PRA). For the ANO2 PRA model used to support the application, please (a) Provide a list of findings from the ANO2 PRA peer review relevant to this submittal A full-scope Regulatory Guide (RG) 1.200 peer review for the ANO-2 PRA was performed by Westinghouse Owners Group in 2008 and the final report issued July 30, 2008.

The peer review findings that affect Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) values could be relevant to this submittal.

Table 3.1-1 of this attachment provides a list of all findings from the ANO-2 PRA peer review and the column ILRT Relevant illustrates which finding is relevant to this submittal. The column Reason for Not Relevant describes the reason why screened findings and observations (F&Os) are not relevant to this submittal.

(b) Explain how these items were addressed for this application.

Table 3.1-1 also shows the list of findings from the ANO-2 PRA peer review which could be relevant to this submittal and column Finding Disposition shows how the relevant individual findings were evaluated and addressed. There are no open peer review comments that significantly affect the risk results provided in the ILRT analysis.

Attachment to 2CAN011102 Page 27 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant IE-C3-01 IE-C3 Yes Issue: ANO2 explicitly calculated the total reactor The Risk increase calculation for ILRT critical years as total reactor critical hours divided extension application used the initiating event by 8766 hours0.101 days <br />2.435 hours <br />0.0145 weeks <br />0.00334 months <br /> per year and used this to calculate frequencies based on reactor critical hours the Initiating Events Frequencies (IEFs). rather than calendar hours for conservative However, there is no evidence that ANO2 estimation of risk increase adjusted these IEFs to reflect average plant This makes conservatism for risk increase availability. This is, in essence, equivalent to estimation about 10%

assuming that the plant operates at full power all year. ANO2 needs to adjust their initiating event frequencies to account for average plant availability.

IE-C10-01 IE-C10 No No comparison of results to generic data sources A comparison of IE frequencies to the was provided with a discussion and explanation of generic frequencies is primarily a the differences. This is a requirement to meet IE documentation issue. Performance of this C-10 and is important to assessing the validity of review for other sites found only that the the initiating event frequency results. The change was that the Instrument Air initiator ISLOCA IEF needs to be reviewed, compared and needs to account for major system leaks and understood. This IEF value is very low. not just hardware failures. Since the instrument air system is not a major Compare the results to the generic values in contributor to CDF, this change would not NUREG/CR-5750 and NUREG/CR-6928, and impact PSA applications. The ISLOCA provide and explain any significant differences. frequencies mentioned in the finding have been addressed in another finding (IE-C12-

01) and are corrected in the model.

IE-C12-01 IE-C12 Yes Some of the components in the ISLOCA fault tree The ISLOCA mission times were reviewed model appear to have incorrect mission times. and this change has been incorporated in the The Low Pressure Safety Injection (LPSI) Motor model used for PSA Applications.

Operated Valve (MOV), e.g. 2CV5017 rupture, has a mission time of 36 hrs. However, the mission time should probably be 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> because the MOV rupture is not likely to be annunciated in the control room as assumed.

Therefore, it could potentially be in an undetected failed state for an extended period. The same comment may apply to the second check valve. It could be potentially in an undetected failed state for an extended period.

Reconsider and change the mission times for the time the downstream valves can be in an undetected state.

Attachment to 2CAN011102 Page 28 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant IE-D1-01 IE-D1 No Some of the documentation is not adequate to These issues identified for this SR are meet this requirement. The following items should primarily documentation issues and do not be addressed: impact the results of the analysis. Entergy (1) What is the basis for the 80/20 split between will be revising the documentation, at a future reactor trip and turbine trip events? (Assumption date to address these issues. However, it is 8, Section 2.2 and Section 5.1 page 19). not expected that any new information will be (2) Where is the documentation for the small and forthcoming that will significantly change the medium break sizes that are used in the model? frequencies of initiators.

The lower limit for the large LOCA break size has a reference (see Table 2). The information below presents some (3) Appendix C contains calculations for loss of preliminary discussions relating to each feedwater/condensate (T2). Page 48 contains the individual item identified for this SR.

Bayesian update for this event. Recommend explaining how these are used in the PRA model 1) The 80/20 split for Reactor trip vs. turbine and which is used in the base model. The value in trip is based on the data from table D-4 of Table 7 appears to be from the Bayesian update NUREG/CR-5750 and ANO2 trip history.

which is inconsistent with the discussion in 2) The LOCA break sizes are determined in Section 5.3.1. the Accident Sequence calculation and are (4) Table 7: Its not clear where the frequencies not expected to change significantly for T500KV and TST3 come from. This should be 3) The Feedwater/Condensate initiator tree is explained. used strictly for (a)(4) evaluations with (5) The RR file with the quantification information feedwater components out of service. The contains frequencies for the following events that Bayesian data is used for the PRA.

are not in the IE documentation: T3SD, T3SW, 4) T500KV is partial LOSP and is developed TSDCA, TSDCAML, TSDCB, TSDCBML, based on actual LOSP data. TST3 is a TSDCISO, V5+, and VS+ . transformer failure and is based on the (6) Loss of Lake Dardanelle IE - need to hardware failure of the transformer during a document the change from 2E-04/yr to 1E-05/yr - year.

it should be explained how the IE frequency for 5) The V* and VS* initiators are ISLOCA this event was reduced to 1E-05/yr. events that are discussed in the ISLOCA calculation. The remaining events are used Provide documentation for the above six items. for a LPSD model that is not part of the Initiating Event calculation.

6) The Loss of Lake initiator is reduced based on the conservatisms in the design calculation performed.

Attachment to 2CAN011102 Page 29 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant AS-A4-01 AS-A4 No Even though some operator actions required to This is a documentation issue. The operator achieve the identified success criteria are actions are included in the fault tree and are mentioned in portions of the initiating event consistent with the plant design and analyses, these operator actions are not procedures. The actions are primarily consistently identified and documented. Entergy discussed in the system notebooks rather should explicitly identify all operator actions than the accident sequence.

needed to achieve the success criteria for each of the key safety functions defined for the modeled initiating events.

AS-A5-01 AS-A5 No There is no reference to the System design, The ANO-2 event trees and fault trees are Emergency Operating Procedures (EOPs), or consistent with the EOPs and AOPs (and abnormal procedures in the accident sequence consistent with industry events). Therefore, notebook. It would be helpful if the EOP or the incorporation of this finding is not abnormal procedure used for each accident expected to change any accident progression sequence was noted. as addressed in the PSA.

Add a table showing the EOPs or abnormal procedures used for each accident sequence.

AS-A10-01 AS-A10 No The operation actions are not specified in either This is a documentation issue. The operator the accident sequence detailed description or the actions are included in the fault tree and are event tree. An example would be a detailed consistent with the plant design and discussion of the once through cooling and the procedures. The actions are primarily operator actions required. discussed in the system notebooks rather than the accident sequence.

Specify the operator actions in either the accident sequence detailed description AS-B1-01 AS-B1 No The special initiators do not address the impact of ANO-2 uses a linked fault tree approach these initiators on the mitigating systems. where the initiating events are placed in the tree with the appropriate system model. A table will be added to the accident sequence report to show how the IE fails both the front line and support systems. This finding will not impact any applications.

Attachment to 2CAN011102 Page 30 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant AS-B2-01 AS-B2 No The dependencies are not addressed in the Dependencies between operator actions are Accident Sequence notebook. This is especially addressed in the HRA report and are not true of operator actions and how the failure of an discussed explicitly in the Accident operator action would affect subsequent operator Sequence. Other dependencies are actions. modeled directly in the fault tree. Therefore, this finding will have no impact on any applications.

AS-B3-01 AS-B3 No No assumption or statement is made that plant Thus far Entergys review of the systems equipment will perform in the environment for credited for ANO-2 identified no cases which it was designed. There also was no where equipment was assumed to operate in evidence that equipment not specified in the harsh environments beyond design bases Safety Analysis Report (SAR) for accident conditions without justification. However, it is mitigation but still credited in the PRA were noted that additional effort is required to reviewed for environmental affects. ensure that this issue is properly considered and documented .

This could be an assumption that the equipment meets the environmental qualification. Equipment In relation to this application, it can be that is not environmentally qualified need to be concluded that any effect of failing equipment analyzed on the impact they have on the inside containment due to a harsh applicable accident sequence. environment will only serve to increase the risk of LERF. Since the delta risk for the ILRT application is related to the delta between CDF and LERF (CDF-LERF), any issues that might be identified during additional review of this issue would only serve to remove conservatism from the current analysis (i.e.

increase LERF resulting in a smaller delta risk for the ILRT extension).

Therefore, the conclusion of the current ANO-2 ILRT interval extension analysis, will not be affected by any issues relating to this finding.

Attachment to 2CAN011102 Page 31 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant AS-B6-01 AS-B6 Yes This SR was not met because there was no ANO-2 will change the mission time for the discussion of the following: changes in RCPs without cooling to 20 minutes to be environmental conditions, shifting of the consistent with the WCAP. However, Condensate Storage Tanks (CSTs), and operator previous CE reports showed that the RCPs actions. Questions were raised in that ANO2 could operate for 40 minutes to an hour uses 40 minutes as the time that the Reactor without cooling. The WCAP change is based Coolant Pump (RCP) can run without Component on concerns with the Westinghouse RCP Cooling Water (CCW) cooling. The industry seals and a regulatory desire to have a practice (WCAP-16175) uses 20 minutes. This consistent time to restore cooling to the difference should be analyzed and resolved. RCPs. Therefore, the current analysis is believed to be more realistic (although it is not Discuss the following: changes in environmental consistent with current WCAP guidance.)

conditions, shifting of the CSTs, and operator actions.

AS-C2-01 AS-C2 No The documentation does not show that the items This is a documentation finding concerning in this SR have been addressed. the issues addressed above. Therefore, this finding will not impact any applications.

Address all the items in this SR in the assumption section.

SY-A4-01 SY-A4 No ANO2 has a System Notebook Database as part Numerous walkdowns have been performed of their overall PSA documentation system. The in past updates, but have not been System Notebook entries for EFW, SW and the documented. Walkdowns have been AC Power System were reviewed against the list performed for Internal Flooding and Fire of information provided in the SR. There was no PRA. The model will not change as a result specific entry in the reviewed notebooks that of walkdowns. In addition, the documentation address performing plant walkdowns and of the system notebooks will be changed to interviews with system engineers and plant better accommodate documentation of the operators to confirm that the systems analysis walkdowns.

correctly reflects the as-built, asoperated plant Walkdowns will need to be performed in order to support National Fire Protection Association (NFPA) 805 Fire PRA and Flooding initiator. This SR can be accomplished during this process.

SY-A8-01 SY-A8 Yes The EDG air start system is included in the This SR has been addressed in the current component boundary of the EDG for failure rate model. The diesel air start components were and common cause but is still modeled in the fault set to 0 to address the diesel boundary issue.

tree with non-zero probabilities.

Attachment to 2CAN011102 Page 32 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant SY-B8-01 SY-B8 No No documentation of spatial and environmental As stated in the response to SY-A4-01, hazards assessment was found. walkdowns have been performed. Therefore, this is only documentation issue.

Spatial and environmental hazards information was considered in the system model development. In addition, the internal flooding evaluation addressed failures do to spray and flooding of components in the vicinity of the failure.

HR-C2-01 HR-C2 No CC-I was assessed to be met, but there is no Thus far, a preliminary review of LERs has direct evidence that ANO2 evaluated plant- not identified any additional pre-initiator specific or generic operating experience to check human errors that are not currently included for other pre-initiators. Documentation of a review in the current model. A detailed review will of plant specific information or industry Licensee be performed as part of the next model Event Reports (LERs) from other similar plants update, however, it is not expected that this and incorporating this information into the HRA issue has any impact on this application.

assessment is required to receive a CC-II/III rating.

Incorporate an assessment of the plant-specific or generic operating experience information into the HRA assessment.

HR-D3-01 HR-D3 No Not assessed consistent with CC II since the A review of the HRA spreadsheet indicates evaluation does not provide an assessment of the that the analyst has reviewed the referenced quality of the procedures or the quality of the procedures and subsequent processes (man-human-machine interface. machine interface), and has demonstrated an understanding of both to prepared the Provide an assessment of the quality of the "Failure Context" section for each HFE.

procedures and the human-machine interaction. Thus, while the level of "quality" is not If this has been done, provide the documentation. explicitly called out, the review and extraction of information is sufficient to imply that the procedures and interfaces are at an acceptable "quality" level. Therefore, this issue has no impact on this application.

Attachment to 2CAN011102 Page 33 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant HR-D6-01 HR-D6 Yes ANO2 uses the HRA Toolbox for quantifying their The pre-initiator HRA values have been pre-initiator HEPs. For the pre-initiator HEPs, converted from medians to means in the ANO2 basically uses the ASEP approach and updated analysis. This change made little treats the ASEP Basic HEPs as means with the difference in the core damage frequency associated error factors. However, as defined on since the pre-initiator HRAs are not a major page xv of NUREG/CR-4772, the ASEP BHEP contributor to risk. This change is included for values are medians for a log-normal distribution. all model applications.

Thus, the treatment of the BHEP values for the pre-initiators is mathematically incorrect.

HR-G6-01 HR-G6 No This SR requires a check of consistency of the The post-initiator human actions were post-initiator HEP quantification. This requires a reviewed to verify that the values are review of the HFEs and their final HEPs relative to reasonable and consistent based on the time each other to check their reasonableness. There available, the complexity of the decision-is no evidence that this consistency check has making process, and the complexity of the been done. If done this should be documented, if task. If the probability was questionable, the not done this should be completed. spreadsheets were reviewed to determine which element dominated the risk and This can be addressed by adding an explicit changes were made to either correct or process for reviewing the HEPs for internal explain the discrepancies consistency with respect to scenario, context, procedures and timing. Specifically this can evaluate the HEPs with respect to certain expected patterns such as increasing HEPs with decreasing time available, increasing HEPs with increasing stress levels, and increasing HEPs with increasing complexity of the procedures for accomplishing the desired successful outcome. A statement that such an evaluation was performed and, where there were deviations from the expected patterns and either provides a basis for the deviation or what was done to correct it.

HR-G9-01 HR-G9 Yes This requires the use of means values. NUREG- The post-initiator execution errors were 1278 contains median values that do not appear converted from medians to means. However, to be converted to means before being used in the the changes made a very minor impact on the ANO2 PRA. For example, spread sheet used for HEPs. This change is included for all model HRA at ANO2. applications.

Attachment to 2CAN011102 Page 34 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant DA-A1a-01 DA-A1a Yes Boundary developed for EDG starting air was This SR has been addressed in the current outlined in PRA-ES-01-003 included the start air model. The diesel air start components were system inside the component boundary. The set to 0 to address the diesel boundary issue.

CAFTA model had the starting air modeled with Therefore, this finding has been addressed Basic Events (BEs) set greater than zero, for applications.

effectively placing the starting air outside the component boundary. See F&O SY-A8-04 for details.

See F&O SY-A8-04 DA-C10-01 DA-C10 Yes CAT I given based on information listed in The data collection is consistent with the Procedure PRA-A2-01-003S05 does not address Maintenance Rule process. The MR process decomposing the component failure mode into does not count these demands and run-sub-elements (or causes) that are fully tested, hours. Therefore, while there may be some then using tests that exercise specific sub- discrepancies in the data counting, these elements in their evaluation. discrepancies are not expected to significantly impact any risk quantifications. Note that May be over-counting demands and run-hours for Bayesian analysis will compensate for these component boundaries that are not tested during discrepancies by averaging the risk closer to evolution. Need to review component boundaries the generic failure rates.

and tests counted in data collection to ensure that one sub-element does not have many more successes than another.

Update procedure CE-P-05.07 with process details that ensure the requirements described in CAT II/III are met.

Attachment to 2CAN011102 Page 35 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant DA-C12-01 DA-C12 No Procedure PRA-A2-01-003S05 addresses System engineers and other plant personnel evaluating maintenance outage as a function of discussions were performed throughout the plant status. CAT I given since there is no data update process. Therefore, although a evidence of INTERVIEW the plant maintenance formal interview with plant operations and and operations staff to generate estimates of maintenance was not documented, the ranges in the unavailable time per maintenance information has been gathered and used in act for components, trains, or systems for which the data update process.

the unavailabilities are significant basis events.

As a suggestion, need to include interviews and shared equipment between ANO1 and ANO2 (i.e.,

air compressors) in procedure PRA-A2 003S05 Need to document interviews in order to meet Category II/III.

Update procedure CE-P-05.07 with process to perform interviews with plant maintenance and operations staff to generate estimates of ranges in the unavailable time per maintenance act for components, trains, or systems for which the unavailabilities are significant basis events.

Document interviews.

IF-A1-01 IF-A1 No At the time of the peer review, the ANO2 IF The ANO-2 Internal Flooding Analysis has analyses had not been completed to the point that been completed. The insights gained from it could be reviewed. Entergy intends to use the the Waterford Peer Review were used to same IF methodology for all three of their PWRs develop the ANO-2 internal flooding analysis.

with the Waterford-3 plant being the lead plant. In addition, the process used for the ANO-2 The Waterford-3 IF analysis had been completed. internal flooding analysis was also used to Entergy requested that the peer review team develop the ANO-1 internal flooding analysis review the IF methodology for Waterford to which has also been peer reviewed. The confirm that the methodology met the standard. ANO-2 analysis has been developed to meet Entergy needs to complete the ANO2 IF analyses the standard requirements.

using the Waterford-3 methodology. Entergy will need to specifically address dual unit issues for The analysis incorporates updated ANO1 and ANO2. walkdowns and quantifies scenarios that were screened out in previous revisions.

Attachment to 2CAN011102 Page 36 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant IF-C2c-01 IF-C2c No Equipment height off floor appears to be not Since the time that the Peer Review was recorded for most of the equipment on the walk performed, the walkdown sheets have down sheets. For example, flood area TB-15-250 updated to document the spatial information walkdown sheet on page 460 only 3 of 26 items relating to the components within the flood listed include a height. zones. These spatial impacts have been included in the flooding walkdown reports Spatial location in the area (for example height off and documented for the ANO-2 analysis.

floor) and any flooding mitigative features (e.g.,

shielding, flood or spray capability ratings) is not recorded for most of the PRA components listed on the walkdown sheets. Therefore, for a particular flood height in a room, it is not clear whether or not a component is affected.

Complete the walkdown sheets.

IF-C3-01 IF-C3 No The walk down sheets identify the components The walkdown sheets for the ANO-2 analysis located inside the flood area. This SR requires have been updated to be more that components in a flood area be identified and comprehensive in the identification of those include whether the component is susceptible to components vulnerable to spray. While most failure by submergence or spray. The walkdown forms are complete in depicting the sheets are formatted to allow recording whether or components susceptibility to spray, some not the component is vulnerable to spray. Only entrys remain blank and are in need of several walkdown sheets have the column filled updating. This lack of completeness in the out for vulnerability to spray. It is not clear documentation does not affect the ILRT whether blanks indicate not susceptible to spray extension application.

or not.

IF-D6-01 IF-D6 No Operator error contributions to flooding are While the need to assess human discussed at a very high level. However, basically induced floods in relation to the the only floods considered were catastrophic application of the generic data is failures. The flood scenario frequencies were important for ensuring that the flood quantified using generic pipe rupture data and plant-specific pipe length. The generic flood frequency is inclusive, the inclusion of frequency sources do not include floods cause by these human induced floods has no human actions during maintenance. While the bearing on the analysis in support of the operator induced floods may be less severe than ILRT extension request.

the catastrophic pipe failure floods, the frequencies will be higher so should be considered explicitly.

Attachment to 2CAN011102 Page 37 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant QU-F4-01 QU-F4 No Selection process for determining important ANO-2 did a full scope sensitivity and assumptions and sources of uncertainty was not uncertainty analysis on the current model. At delineated. the time of the peer review, no process for determining important assumptions existed for the industry. Since the latest EPRI report on sources of uncertainty was published, the ANO-2 sensitivity analyses compare favorably with the issues identified by EPRI.

LE-D1b-01 LE-D1b No There is no evidence of an evaluation of the The LERF analysis meets the requirements impact of the accident progression conditions on of NUREG/CR-6595. This methodology is containment seals, penetrations, etc. The model considered acceptable for model this is based on is related to NUREG/CR-6595 so applications.

consistency with NUREG/CR-6595 meets CC-I, but there is no discussion of the accident progression conditions on these elements.

Provide a discussion or assessment of the accident progression conditions on the containment conditions noted in the SR.

LE-D6-01 LE-D6 Yes Containment isolation is addressed by top event The containment isolation analysis is typically (question) 3. This is based on a calc that is noted not expected to change significantly during not to have been maintained up to date. Since it the periods between model updates.

has not been maintained up-to-date, there is no Additional containment penetrations have not confidence that the analysis represents a realistic been added. Therefore, the model update is assessment; therefore, this does not meet CC II. not expected to increase the failure probability of containment isolation.

The containment isolation calc needs to be updated or demonstrated (confirmed) to be up to date. This should include an assessment of the containment penetrations to provide an assessment of the total number of penetrations required to provide a realistic evaluation of containment isolation reliability.

Attachment to 2CAN011102 Page 38 of 38 Review ILRT Finding No Finding Reason for Not Relevant Finding Disposition Element Relevant LE-E4-01 LE-E4 No Although the majority of the SR requirements in The Level 2 PRA only adds a small number these three top high level requirements are met, of human actions, primarily associated with there is no indication that dependencies between containment isolation. Therefore, any new multiple HFEs have been addressed. HRA combinations that may have dependencies that are not accounted for are The Level 1 assessment completed an evaluation not expected to have a significant impact on of the dependencies between human actions in raising the LERF.

the model. A similar analysis should be completed for the human actions in the Level 2 analyses and between the Level 2 and Level 1 analyses to ensure all HEP dependencies are identified and addressed appropriately.

LE-F1b-01 LE-F1b No There is no documented evidence that ANO2 Upon review of the Waterford-3 LERF compared their LERF results to the results of analysis, the comparison to a similar plant is other similar plants to confirm the reasonableness not expected to identify additional sources of of the results with respect to relative contribution LERF than have previously been identified.

and frequency and ranking of contributors.

MU-B4-01 MU-B4 No There is no reference to a peer review for Procedure EN-DC-151 has been updated to upgrades. require a peer review for changes in PRA methodology as discussed in the AMSE/ANS Procedure EN-DC-151, PSA Maintenance and PRA Standard.

Update, could be revised to include the requirement for a peer review when the PSA is upgraded. It should be noted that a PSA update does not require a peer review. An upgrade could include the following: change in methodology, change in software, or any other change that could be defined as an upgrade.