0CAN041001, Generic Letter 2004-02 Supplemental Information

Generic Letter 2004-02 Supplemental Information

ML100980614
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/08/2010
From:	David Bice Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN041001, GL-04-002
Download: ML100980614 (5)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One 0CAN041001 April 8, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Generic Letter 2004-02 Supplemental Information Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Reference:

1. Entergy letter dated September 24, 2009 (0CAN090901), Generic Letter (GL) 2004-02 Final Supplemental Response Request for Additional Information

2. NRC letter dated May 21, 2009 (0CNA050905), Request for Additional Information Regarding Supplemental Response to GL 2004-02

3. Entergy letter dated September 15, 2008 (0CAN090801), GL 2004-02 Final Supplemental Response

Dear Sir or Madam:

By letter dated September 24, 2009 (Reference 1), Entergy Operations, Inc. (Entergy) submitted responses to requests for additional information (RAIs) requested in NRC correspondence dated May 21, 2009 (Reference 2) concerning the final supplemental response for Arkansas Nuclear One (ANO) dated September 15, 2008 (Reference 3). As described in Section 3.h of Reference 3, the application of WCAP-16568-P, Jet Impingement Testing to determine Zone-of-Influence (ZOI) for Design Basis Accident-Qualified/Acceptable Coatings, was credited for both ANO-1 and ANO-2 epoxy and inorganic zinc primer coatings. Based on preliminary information from Westinghouse regarding subsequent testing at Wyle Labs, the use of WCAP-16568-P for inorganic zinc primer is expected to no longer be acceptable.

The current methodology associated with credit for a 5D primer coating ZOI needs to be replaced by specific tracking of qualified primer-only coatings that could potentially be impacted by an increased ZOI sphere from a primary system piping break. Primer-only qualified coating location and surface area data for the steam generator cavities, which are the areas potentially impacted by the increased primer ZOI, is not currently available.

Inspections will be conducted in the on-going refueling outage for ANO-1 (Spring 2010) and the next refueling outage for ANO-2 (Spring 2011) to establish these totals. The primer-only

0CAN041001 Page 2 of 3 qualified coatings total volume is needed as input for the debris generation calculation revision. This inspection is anticipated to confirm the ANO-1 debris currently credited is conservatively bounding. The ANO-2 primer-only qualified coatings debris inspection total will not be available until the Spring 2011 refueling outage. In order to address this condition prior to the end of 2010, the ANO-2 debris generation calculation will be reanalyzed using a primer coating debris that is projected to be conservatively bounding considering the ANO-1 results. This calculation will be confirmed to be conservative during the next ANO-2 refueling outage (Spring 2011).

Entergy plans to evaluate the impact of the qualified primer coating ZOI change using the engineering change process, which should address any needed changes to the ANO painting specification as well as the ANO Coatings Program documents. Changes to these documents, if required, are expected to be described in an updated NRC correspondence addressing the impacts of revised coating ZOIs to previously submitted information regarding GL 2004-02 compliance.

Entergy is committed to timely and efficient resolution of the coating ZOI issue. Numerous calculations and related design bases documents are affected. A revision to the debris generation calculation is required for each unit, which affects several related documents.

The revised analysis will comply with previously reviewed and approved methods, either per Nuclear Energy Institute 04-07 or accepted ANO RAI responses, or the proposed changes will be discussed with the NRC staff for acceptability prior to their use. Entergy plans to complete any needed modifications before the end of refueling outage 1R24 for ANO-1 (currently scheduled to begin March 2013) and refueling outage 2R22 ANO-2 (currently scheduled to begin September 2012). Entergy will submit a letter to the NRC by September 30, 2010, reflecting changes to previously submitted information in ANOs supplemental response and RAIs due to the updated debris ZOIs and will inform the NRC of any changes made to these plans.

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

Sincerely, DBB/nbm

0CAN041001 Page 3 of 3 cc: Mr. Elmo 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

Attachment to 0CAN041001 List of Regulatory Commitments

Attachment to 0CAN041001 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 SCHEDULED (Check One) COMPLETION COMMITMENT DATE ONE-TIME CONTINUING ACTION COMPLIANCE (If Required)

Coating inspections will be conducted in X Spring 2010 the on-going refueling outage for ANO-1.

Coating inspections will be conducted in X Spring 2011 the next refueling outage for ANO-2.

In order to address this condition prior to X Sept. 30, 2010 the end of 2010, the ANO-2 debris generation calculation will be reanalyzed using a primer coating debris that is projected to be conservatively bounding considering the ANO-1 results.

The ANO-2 debris generation X Spring 2011 calculation will be confirmed to be conservative during the next ANO-2 refueling outage.

The revised analysis will comply with X Sept. 30, 2010 previously reviewed and approved methods, either per Nuclear Energy Institute 04-07 or accepted ANO RAI responses, or the proposed changes will be discussed with the NRC staff for acceptability prior to their use. Entergy will submit a letter to the NRC reflecting changes to previously submitted information in ANOs supplemental response and RAIs due to the updated debris ZOIs and will inform the NRC of any changes made to these plans.

Entergy plans to complete any needed X Spring 2013 modifications before the end of refueling outage 1R24 for ANO-1.

Entergy plans to complete any needed X Fall 2012 modifications before the end of refueling outage 2R22 ANO-2.