2CAN091002, Request for Additional Information Technical Specification Changes and Analyses Relating to Use of Alternative Source Term

Request for Additional Information Technical Specification Changes and Analyses Relating to Use of Alternative Source Term

ML102590567
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/16/2010
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN091002
Download: ML102590567 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4619 Dale E. James Acting Vice President, Operations Arkansas Nuclear One 2CAN091002 September 16, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Request for Additional Information Technical Specification Changes and Analyses Relating to Use of Alternative Source Term Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter to the NRC, dated March 31, 2010, License Amendment Request Technical Specification Changes and Analyses Relating to Use of Alternative Source Term (2CAN031001)

2. Email from Kaly Kalyanam (NRC) to Robert W. Clark (Entergy), dated May 5, 2010, Transmission of the Acceptance Review Result to Licensee and Request for Supplemental Information (TAC No. ME3678)

3. Email from Kaly Kalyanam (NRC) to Robert W. Clark (Entergy), dated May 25, 2010, Request for Additional Information on the AST LAR -

ME3678

4. Entergy letter to the NRC, dated June 23, 2010, License Amendment Request Technical Specification Changes and Analyses Relating to Use of Alternative Source Term - Supplemental Information (2CAN061004)

5. Entergy letter to the NRC, dated June 24, 2010, Request For Additional Information Technical Specification Changes and Analyses Relating to Use of Alternative Source Term (2CAN061002)

6. Email from Kaly Kalyanam (NRC) to David B. Bice (Entergy), dated July 15, 2010, Request for Additional Information on the ANO-2 LAR to implement AST - ME3678

2CAN091002 Page 2 of 3 REFERENCES (continued):

7. Entergy letter to the NRC, dated August 9, 2010, Request For Additional Information Technical Specification Changes and Analyses Relating to Use of Alternative Source Term (2CAN081001)

8. Email from Kaly Kalyanam (NRC) to David B. Bice (Entergy), dated August 19, 2010, Request for Additional Information Regarding Technical Specification Changes and Analyses Relating to Use of Alternate Source Term (TAC No. ME3678)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) submitted a request to change the Technical Specifications for Arkansas Nuclear One, Unit 2 in support of the use of alternative source terms associated with accident offsite and control room dose consequences (Reference 1). Supplemental information was submitted to the NRC via References 4, 5, and 7 above.

During continued review of the material provided in Reference 1, the NRC determined that further information was required to complete the Staffs evaluation of the request (Reference 8).

Attached to this submittal is the Reference 8 Request for Additional Information (RAI) along with Entergys response.

This letter contains no new commitments.

If you have any questions or require additional information, please contact David Bice at 479-858-4710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 16, 2010.

Sincerely, DEJ/dbb

Attachment:

Response to Request for Additional Information Related to the Use of Alternative Source Term (AST)

2CAN091002 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-8 B1 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 2CAN091002 Response to Request for Additional Information Related to the Use of Alternative Source Term (AST)

Attachment to 2CAN091002 Page 1 of 3 Response to Request for Additional Information Related to the Use of Alternative Source Term (AST)

1. Assumption 4 on page 12 of Attachment 3 to the March 31, 2010, license amendment request (Agency Documents and Management System (ADAMS)

Accession No. ML100910241) states that the stability index for the 1995 through 1999 meteorological data file was calculated using the methods discussed in Regulatory Guide (RG) 1.23, Onsite Meteorological Programs. RG 1.23 presents two methods, one based on the standard deviation of horizontal wind direction fluctuation () and the other based on temperature change with height (-T).

Please discuss the time periods and criteria used to determine when each method was used.

Meteorological data was taken at 1-hour intervals for a period of five years. The stability class/category of all meteorological data was determined using the vertical temperature difference method (T) of Section C.2.2 and Table 1 of RG 1.23.

2. Attachment 3 provides a series of figures showing the position of each postulated release location with respect to key plant structures and the control room intakes.

The figures are very informative, but they do not appear to be drawn to scale.

Please provide one scaled aerial-view drawing from which distance and direction inputs can be reasonably approximated. Indicate true north and provide the scale of the figure. Highlight all postulated sources and receptors and outline the location of the control room envelope.

The following page contains a scaled overhead view of applicable release points in relation to key plant structures and the control room intakes. Distances between release points and the nearest control room intake are also approximated. Note that the illustrated distance between the Fuel Handling Area Ventilation (FHAV) exhaust and the Penetration Room Ventilation System (PRVS) exhaust with respect to the nearest control room intake are conservative, given at control room intake level; however, these systems actually exhaust more than 83 feet above the Auxiliary Building roof.

As requested, the illustration displays the direction of true north and postulated release points are circled. In addition, the control room envelope is also outlined.

Attachment to 2CAN091002 Page 2 of 3 Ref. Line 4 Ref. Line 5.9 N Room 2155 ANO-2 Openings Turbine Bldg.

Ref. Line J2 ANO-2 ADVs Ref. Line H2 ANO-2 MSSVs Ref. Line G2 ANO-2 ANO-2 PRVS Containment Exhaust 260 Ref. Line E2 225 194 ANO-2 FHAVS Exhaust &

Containment ANO-2 Control Room ANO-2 Aux. Bldg.

ANO-1 Aux. Bldg. ANO-1 Control Room 184 41 10-1/2 NOTE:

ANO-1 Release point circled in red.

Containment Control room intakes (receptors) are shaded.

All release points and the Control Room air intake are at approximate level of Aux Bldg Roof.

ANO-1 0 10 20 30 40 50 100 Turbine Bldg.

SCALE (feet)

Attachment to 2CAN091002 Page 3 of 3

3. It appears that the containment release height value given in Table 1.8.1-2 of Attachment 3 is with respect to the auxiliary building, whereas, heights for the other release points are with respect to plant grade. Please revise Table 1.8.1-2 to use plant grade as the single reference elevation when calculating the heights of release for all postulated release points.

Response: Table 1.8.1-2 of Attachment 3 has been revised as requested.

Table 1.8.1-2 Release-Receptor Combination Parameters (Basis: Plant Design Drawings)

Release Receptor Direction with Distance Release Point Receptor Point Height Height respect to (m)

(m) (m) true north ADV N CR Intake 30.56 28.62 79.77 346 ADV S CR Intake 30.56 28.65 92.22 348 MSSV N CR Intake 30.66 28.62 69.23 347 MSSV S CR Intake 30.66 28.65 81.73 349 Steam Pipe N CR Intake 21.74 28.62 82.69 350 Steam Pipe S CR Intake 21.74 28.65 95.27 351 Fuel Handling N CR Intake 54.53 28.62 56.50 332 Area Fuel Handling S CR Intake 54.53 28.65 68.01 337 Area PRVS Exhaust N CR Intake 55.63 28.62 59.50 341 PRVS Exhaust S CR Intake 55.63 28.65 71.70 345 Containment(1) N CR Intake 29.41 28.62 56.50 331 Containment(1) S CR Intake 29.41 28.65 67.91 335 (1) Containment assumed to be a diffuse area source with an initial vertical diffusion coefficient of 4.22 meters based on a containment height of 83 feet above the auxiliary building. The diffuse area width (containment diameter) is 123.5 feet for an initial horizontal diffusion coefficient of 6.27 meters.