2CAN038910, Discusses NRC Re Denial of Request for Partial Exemption to 10CFR50.62 requirement.C-E Owner Group Has Reconsidered Alternate Design Options to Satisfy Requirement & Scheduled Followup Meeting to End Reevaluation Effort
| ML20247Q262 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear, Waterford, San Onofre, 05000000 |
| Issue date: | 03/29/1989 |
| From: | James D ARKANSAS POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2CAN038910, 2CAN38910, NUDOCS 8904070092 | |
| Download: ML20247Q262 (2) | |
Text
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i ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK ARKANSAS 72203 (501)3774000 March 29, 1989 2CAN038910 Document Control Desk Mail Station P1-137 Washington, DC 20555 ATTN: Mr. Jose A. Calvo, Director Project Director, Region IV Division of Reactor Projects III, IV, V and Special Projects l
SUBJECT:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 NRC Denial of AN0-2 Request for Partial Exemption to 10CFR50.62 Requirement
Dear Mr. Calvo:
The Arkansas Power & Light Company (AP&L) has received and reviewed your correspondence of February 16,1989(2CNA028903) which denied our request for partial exemption from the requirements of 10CFR50.62 for Arkansas Nuclear One, Unit 2 (AN0-2).
On February 27, 1989, AP&L along with Combustion Engineering Inc. (CE),
Louisiana Power & Light Company, and the Southern California Edison Company met with the NRC Staff to discuss the safety implications associated with I
full compliance with the Anticipated Transients Without Scram (ATWS) rule for these four CE digital plants. During that meeting, other design approaches besides the options presented in the exemption request were j
briefly discussed and the Staff indicated that they held to the position that the ATWS rule requirements could be satisfied with a design solution
)
l less complicated and costly than that presented in the exemption request.
l The CE Owner's Group (i.e., a duplicate emergency feedwater actuation system (CE0G) believes that the design proposed in the i
is the only design approach that will fully comply with the ATWS rule.
However, in order to be consistent with our mutual desire to resolve the ATWS issue on these plants, the CE0G agreed to reconsider alternate design options in order to document whether or not any lesser design could sufficiently satisfy the requirements of paragraph (c)(1) of the ATWS rule.
This reconsideration may enable the CE0G and the NRC Staff to negotiate a closure of the issue. Currently, a follow-up meeting between the CE0G and the NRC Staff is being pursued for April, 1989 to discuss the conclusions.of j
the reevaluation effort.
O 8904o70092 890329
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PDR ADOCK 05000368 P
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2CAN038910 March 29, 1989 AP&L's response to your previously referenced correspondence, with respect to schedule, cannot be submitted until after the April meeting.
Your correspondence also indicated that our schedule should reflect an implementation no later than our next refueling outage.
The next ANO-2 refueling outage'(2R7) is presently scheduled for September of 1989. While our previous correspondence of February 2,1989 committed to install our Diverse Scram System (DSS) and Diverse Turbine Trip (DTT) during 2R7, the installation of any design option.for diverse actuation of emergency feedwater cannot be accomplished within such a timeframe.
The actual lead time requirement is a function of the a..;plexity of the design solution that is finally determined to be-required to. satisfy compliance with the rule.
Our correspondence of November 3, 1989 (2CAN118801) did incorrectly identify 2R7 as the third refueling outage following the final ATWS rule.
Further l
review correctly identified 2R6, which ended in the Spring of 1988 as the third refueling outage following the final rule. This confusion resulted in a failure on our part to submit a request for schedulor extension, although through discussions and meetings which occurred during the evolution of the diversity issue, AP&L kept the staff informed of the status of ATWS 1
implementation as it applied to AN0-2. An extension to the implementation schedule would have been necessary due to the status of the CE0G and NRC dialogue regarding generic diversity requirements for ANO-2, San Onofre Units 2 & 3 and Waterford, Unit 3.
The CEOG submitted CEN-315 " Summary of the Diversity Between the Reactor Trip System and the Auxiliary Feedwater System for CE Plants" in September, 1985.
The Staff responded with their evaluation of CEN-315 in August, 1986. The CE0G submitted CEN-349
" Response to the NRC's Evaluation of CEN-315 for San Onofre Nuclear Generating Station Units 2 & 3, Arkansas Nuclear One, Unit 2, and Waterford j
Steam Electric Station Unit 3" in December, 1986 and the Staff responded with "NRC Evaluation of CEN-315 and CEN-349 in a letter to Southern California Edison in January, 1988. This last correspondence contained the Staff guidance for submitting exemption requests to the requirements of the ATWS rule. Our November 3, 1988 correspondence, previously referenced, 1
transmitted the AN0-2 exemption request to the Staff.
Since a final position on the specific requirements for ATWS rule compliance as it applies to the diversity requirement for emergency feedwater actuation on AN0-2 is not yet achieved, a third refueling outage implementation of ATWS design
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modifications on AN0-2 was not possible.
1 In support of the CE0G initiative, AP&L has been an active participant in the design option reevaluation effort to affect a resolution.of the ATWS issue on ANO-2. We will continue to pursue this item in a good faith manner with both the NRC Staff and the CE0G.
Very truly y rs,
. pft" ale E J mes Superfiq r, Licensing i
DEJ:MWT:de
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