ML081890443
| ML081890443 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/12/2008 |
| From: | Wang A NRC/NRR/ADRO/DORL/LPLIV |
| To: | Entergy Operations |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| References | |
| GL-08-001, TAC MD7793, TAC MD7794 | |
| Download: ML081890443 (7) | |
Text
September 12, 2008 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, AND PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7793 and MD7794)
Dear Sir or Madam:
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 8, 2008, and supplemented by letter dated June 30, 2008, Entergy Operations, Inc. (the licensee), submitted 3-month responses to GL 2008-01 for Arkansas Nuclear One, Units 1 and 2 (ANO-1 and ANO-2). The NRC staff assessment of the licensees responses is contained in Enclosure 1.
The NRC staff reviewed the licensees proposed alternative courses of action and the associated basis for acceptance and concluded that, with the exception of the clarifications and associated requests discussed in Enclosure 1, they are acceptable. However, the NRC staff requests additional information as described in Enclosure 1. This letter allows the licensee to implement the proposed alternative courses of action provided the implementation is consistent with the clarifications and associated requests discussed in Enclosure 1.
Vice President Operations If you have any questions regarding this letter, please feel free to contact me at (301) 415-1445.
Sincerely,
/RA/
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosure:
As stated cc w/encl: See next page
Vice President Operations If you have any questions regarding this letter, please feel free to contact me at (301) 415-1445.
Sincerely,
/RA/
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosure:
As stated cc: See next page Distribution:
PUBLIC/NON-SENSITIVE LPL4 R/F RidsAcrs&AcnwMailCenter RidsRgn4MailCenter RidsNrrDci RidsNrrDprPgsb RidsNrrDss RidsNrrDorlLpl4 RidsNrrPMAWang RidsNrrLAGLappert RidsOgcRp ADAMS Accession Number: ML081890443 NRR-106 OFFICE NRR/LPL4/PM NRR/LPL4/LA DPR/PGSB/BC DSS/DD NRR/LPL4/BC NRR/LPL4/PM NAME AWang GLappert MMurphy JWermeil MMarkley AWang DATE 9/5/08 9/2/08 9/9/08 9/4/08 9/11/08 9/12/08 OFFICIAL RECORD COPY
Arkansas Nuclear One (6/19/08) cc:
Senior Vice President Section Chief, Division of Health Entergy Nuclear Operations Radiation Control Section P.O. Box 31995 Arkansas Department of Health and Jackson, MS 39286-1995 Human Services 4815 West Markham Street, Slot 30 Vice President, Oversight Little Rock, AR 72205-3867 Entergy Nuclear Operations P.O. Box 31995 Section Chief, Division of Health Jackson, MS 39286-1995 Emergency Management Section Arkansas Department of Health and Senior Manager, Nuclear Safety Human Services
& Licensing 4815 West Markham Street, Slot 30 Entergy Nuclear Operations Little Rock, AR 72205-3867 P.O. Box 31995 Jackson, MS 39286-1995 Pope County Judge Pope County Courthouse Senior Vice President 100 W. Main Street
& Chief Operating Officer Russellville, AR 72801 Entergy Operations, Inc.
P.O. Box 31995 Senior Resident Inspector Jackson, MS 39286-1995 U.S. Nuclear Regulatory Commission P.O. Box 310 Associate General Counsel London, AR 72847 Entergy Nuclear Operations P.O. Box 31995 Regional Administrator, Region IV Jackson, MS 39286-1995 U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Manager, Licensing Arlington, TX 76011-4125 Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802
NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 DOCKET NOS. 50-313 and 50-368 1.0 Background On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated, that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
2.0 Licensees Proposed Alternative Course of Action By letter dated May 8, 2008, and supplemented in a letter dated June 30, 2008 (Agencywide Document Access and Management System Accession Nos. ML081300376 and ML081910760, respectively), Entergy Operations, Inc. (the licensee), submitted 3-month responses to GL 2008-01 for Arkansas Nuclear One, Units 1 and 2 (ANO-1 and ANO-2).
2.1 ANO-1 In the licensees May 8 response, the licensee committed to (1) perform the vent valve walkdowns and complete the Engineering reviews of the venting methods on the normally accessible portions of the systems by October 11, 2008 and to perform the vent valve walkdowns of the inaccessible portions of the systems during refueling outage 1R21, and (2) to submit the GL 2008-01 requested information by March 26, 2009. It justified the dates by Enclosure 1
stating that (1) the performance of an in-field inspection is not considered to be a necessary part of the ANO-1 evaluations at this point-in-time due to its post-outage vent methodologies, inspections to verify solid water, quarterly surveillance testing, and periodic high pressure injection (HPI) train swaps, and (2) verification of vent valves will require less rigorous reactor building walkdowns of the affected piping systems. The licensee continued that any remaining walkdowns and inspections would be completed during the fall and early winter of the 2008 1R21 refueling outage since some portions of the systems are inaccessible or high dose areas during power operation.
In the licensees June 30 response for ANO-1, the licensee stated that it will provide results of the walk downs and evaluations of the accessible portions of the systems (by) October 11, 2008 and the information gathered during the next refueling outage will be provided by March 10, 2009. Its commitment for March 10, 2009 is Entergy will submit the information requested by GL 2008-01 for ANO-1.
2.2 ANO-2 In the licensees May 8 response, the licensee committed to perform the walkdowns and complete the evaluations of the normally accessible portions of the systems on October 11, 2008 and to perform the walkdowns of the inaccessible portions of the systems during the next refueling outage, 2R20, that is scheduled for the fall of 2009. Entergy will submit the GL 2008-01 requested information by January 28, 2010.
The licensee states the performance of an in-field inspection of the system piping is considered to be a necessary part of the ANO-2 evaluations. Its justifications for the delay until the next refueling outage were similar to those provided for ANO-1.
The licensees June 30 response did not change any of the ANO-2 information.
3.0 NRC Staff Assessment Based on the above-identified information associated with managing gas accumulation, the NRC staff finds that the licensees proposed alternative course of action is acceptable with the exception of the content of the submittals and the submittal dates.
The licensee is not clear regarding the content of the 9-month submittals. A possible interpretation is that certain work will be completed by October 11, 2008, but the information requested by the GL will not be provided until later, or that only certain information, but not all that was requested in the GL and is expected by the NRC staff, will be addressed in the 9-month submittal. As stated in GL 2008-01, the NRC request was that each addressee provide the following information: (a) A description of the results of evaluations that were performed pursuant to the above requested actions. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems; (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for
completing the remaining corrective actions, and the basis for that schedule. Additional information is provided in the GL and in William H. Rulands letter to James H. Riley dated July 8, 2008 (ML081830557).
As stated in Rulands letter, the NRC staff expects all addressees to submit a 9-month response by October 11, 2008 that addresses the information and discussion provided in the GL using the guidance provided by NEI.
The NRC staff requests that the licensee submit the information requested in the GL as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the next refueling outage that starts before October 12, 2008, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following completion of the first refueling outages that initiate after October 11, 2008.
For each of the two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should include: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
Therefore, the NRC staff requests that the licensee submit a 3-month supplemental response to revise the proposed alternative course of action related to the 9-month supplemental responses as discussed above.
The NRC staff noted that the licensees submittals did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suction piping, as well as, whether analysis development is needed to assess gas transport in the subject system piping as a function of system flow. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.