2CAN040802, Unit 2, Request for Extension of Completion Date for Resolution of Generic Letter 2004-02

Unit 2, Request for Extension of Completion Date for Resolution of Generic Letter 2004-02

ML081120128
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/18/2008
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN040802, GL-04-002
Download: ML081120128 (5)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4619 Dale E. James Manager, Licensing 2CAN040802 April 18, 2008 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Request for Extension of Completion Date for Resolution of Generic Letter 2004-02 Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

By letter dated December 21, 2007 (0CNA120703), the NRC approved an extension for actions associated with Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, for Arkansas Nuclear One (ANO). This extension was requested in Entergy correspondence dated November 7, 2007 (0CAN110701).

The NRC correspondence dated December 21, 2007, contained a commitment to complete the fuel and vessel downstream effects analysis and strainer certification/qualification reports prior to the restart of ANO-2 from the spring 2008 refueling outage (2R19). The correspondence also contained a commitment to update the licensing basis within 60 days (i.e., mid-June 2008) of completion of GL 2004-02 actions. In addition, by letter dated February 28, 2008 (0CAN020803), Entergy provided a preliminary supplemental response to GL 2004-02 and committed to provide the final supplemental response within 90 days (i.e., mid-July 2008) of completion of GL 2004-02 actions.

In a telephone conversation with the NRC Staff and the NRC project manager for ANO on April 4, 2008, Entergy described an insulation configuration discovered during 2R19 that affected the ability to complete the analyses to support GL 2004-02 resolution.

During 2R19 additional fibrous insulation was discovered in the ANO-2 containment that had not been previously considered in the GL 2004-02 calculations. Entergy has undertaken aggressive actions to address the condition with the vast majority of the newly identified fibrous insulation being removed, but there were several areas that were

2CAN040802 Page 2 not addressed due to the relatively high radiation fields where they were located. Given extensive scaffold erection was required to remove the fibrous insulation, Entergy took advantage of the accessibility to piping insulated with calcium-silicate and provided multiple banding to substantial portions of this piping, thus reducing the zone-of-influence for this insulation type. These changes to the potential debris mixture required Entergy to repeat some of the previous strainer head loss qualification testing and will require the ANO-2 analyses to be significantly revised. Entergy believes that the actions (plant modifications, etc.) have been completed to place ANO-2 in compliance with the requirements of GL 2004-02; however, Entergy needs additional time to revise the GL 2004-02 analyses in order to update the licensing basis.

In the November 7, 2007, correspondence, Entergy provided the basis for the extension request. The information provided in that submittal upon which the NRCs extension approval was granted remains unchanged by an extension of time to complete the analyses and update the licensing basis. Entergy believes that an additional 60 days beyond the current extension date (i.e., mid-June 2008) will be adequate to revise the necessary calculations/analyses and to update the licensing basis. Therefore, Entergy requests an extension until August 15, 2008, to complete the analyses to support GL 2004-02 resolution and update the ANO-2 licensing basis, and until September 15, 2008, to provide the final supplemental response.

In addition, the extent of condition relating to ANO-1 is being assessed in the site corrective action system and will be appropriately addressed in the ANO-1 calculations and analysis.

New commitments contained in this submittal are summarized in the attachment. If you have any questions or require additional information, please contact me.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 18, 2008.

Sincerely, DEJ/nbm

Attachment:

List of Regulatory Commitments

2CAN040802 Page 3 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Alan B. Wang Mail Stop O-7 D1 Washington, DC 20555-0001

Attachment to 2CAN040802 List of Regulatory Commitments

Attachment to 2CAN040802 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check One) SCHEDULED ONE- COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (If Required)

Complete analyses to support X August 15, 2008 GL 2004-02 resolution and update the ANO-2 licensing basis Provide final supplemental response for X September 15, 2008 ANO-2