0CAN021405, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

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Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)
ML14059A229
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 02/27/2014
From: Jeremy G. Browning
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN021405, EA-12-049
Download: ML14059A229 (12)


Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Site Vice President Arkansas Nuclear One 0CAN021405 February 27, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEEs)

(Order Number EA-12-049)

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

REFERENCES:

1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated March 12, 2012 (0CNA031206) (ML12056A045)
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, Revision 0, dated August 29, 2012 (ML12229A174)
3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12221A205)
4. Entergy letter to NRC, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated October 26, 2012 (0CAN101203) (ML12305A372)
5. Entergy letter to NRC, Overall Integrated Plan (OIP) in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 28, 2013 (0CAN021302) (ML13063A151)

0CAN021405 Page 2 of 3

6. Entergy letter to NRC, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated August 28, 2013 (0CAN081302)

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc.

(Entergy). Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a BDBEE.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an OIP pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3). Reference 4 provided the initial status report regarding mitigation strategies, and Reference 5 provided the OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first six-month status report. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Stephenie Pyle at 479.858.4704.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 27, 2014.

Sincerely, Original Signed by Jeremy G. Browning JGB/nbm

Attachment:

Arkansas Nuclear One Units 1 and 2 Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs

0CAN021405 Page 3 of 3 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Alan Wang MS O-88B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Mr. Michael Orenak MS O-8G9A One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 0CAN021405 Arkansas Nuclear One (ANO) Units 1 and 2 (ANO-1 and ANO-2) Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEEs)

Attachment to 0CAN021405 Page 1 of 8 ANO-1 and ANO-2 Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs 1 Introduction Entergy Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) for ANO-1 and ANO-2 (Reference 1), documenting the diverse and flexible strategies (FLEX) in response to Reference 2. The OIP was updated and submitted with the First Six-Month Status Report (Reference 3). This enclosure provides an update of milestone accomplishments since submittal of the last status report (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since August 28, 2013, and are current as of January 31, 2014:

  • First Six-Month Status Report August 2013
  • Second Six-Month Status Report Complete with submission of this document in February 2014
  • Modifications Evaluation - January 2014 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The milestone target completion date for Perform Staffing Analysis has been changed to September 2014, via NRC correspondence (Reference 4). This new milestone target completion date does not impact the Order implementation date.

Target Revised Target Activity Milestone Completion Completion Status Date Date Submit OIP February 2013 Complete Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Not Started Update 4 February 2015 Not Started Update 5 August-2015 Not Started Perform Staffing Analysis December 2013 Started September 2014 Modifications

Attachment to 0CAN021405 Page 2 of 8 Target Revised Target Activity Milestone Completion Completion Status Date Date Modifications Evaluation June 2013 Complete June 2013 -

Engineering and Implementation Started October 2015 ANO-1 Implementation Outage February 2015 Not Started ANO-2 Implementation Outage October 2015 Not Started On-site FLEX Equipment Purchase June 2014 Not Started Procure November 2014 Not Started Off-site FLEX Equipment Develop Strategies with Regional November 2013 Started Response Center Install Off-site Delivery Station (if October 2014 Not Started necessary)

Procedures Pressurized Water Reactor Completed Owners Group issues Nuclear June 2013 Issued System Steam Supply May 2013 (NSSS)-specific guidelines Create ANO FLEX Strategy Guide November 2014 Started Create Maintenance Procedures November 2014 Not Started Training Develop Training Plan June 2014 Not Started Implement Training November 2014 Not Started Validation ANO-1 walk-throughs or demonstration(s) - including all November 2014 Not Started March 2015*

FLEX equipment points of connect/tie-in for Phase 2 and 3 ANO-2 walk-throughs or demonstration(s) - including all October 2015 Not Started FLEX equipment points of connect/tie-in for Phase 2 and 3 Submit Completion Report February 2016 Not Started Note: Target Completion Date is the last submitted date from either the overall integrated plan or previous six month status reports.

    • Refueling outage was moved from late 2014 to early 2015

Attachment to 0CAN021405 Page 3 of 8 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at ANO, changes have been identified to the compliance strategies as described in the original OIP.

  • As stated in the revised ANO FLEX OIP (Reference 3, Enclosure 2), the current ANO-2 Phase 2 reactor coolant system (RCS) makeup strategy is to use a portable FLEX RCS makeup pump. An alternate strategy is under consideration to use the ANO-2 charging pumps to makeup to the ANO-2 RCS after the ANO-1 cooldown is complete. This is the subject of current dialogue with the NRC Staff, so a final decision is in the process of being made.
  • As part of the First Six-Month Status Report (Reference 3), the following change to compliance method was included:

o ANO-1 RCS inventory control is planned to be provided by re-energizing an ANO-2 charging pump from the portable diesel generator and cross-connection of the charging pump to ANO-1 high pressure injection. Entergy intends to continue with the modifications to support this strategy.

This strategy is considered an alternate method of compliance because it does not utilize a portable pump per the guidelines of Section 3.2.2(13) of Nuclear Energy Institute (NEI) 12-06. The justification for this alternative method is provided below:

This strategy for ANO-1 meets the requirement of Order EA-12-049 (Reference 2) because it is an alternate method of meeting NEI 12-06. The order states, The initial phase requires the use of installed equipment and resources to maintain or restore core cooling. The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources from off site.

NEI 12-06 allows for crediting plant installed equipment to meet the guidance as long as there is sufficient diversity. The use of an ANO-2 charging pump for ANO-1 and/or ANO-2 RCS inventory control relies upon portable onsite FLEX equipment. A portable FLEX generator and temporary power cables are required to re-power one of three charging pumps. The charging pumps are robust for all BDBEEs. High pressure hoses are used to make the final connections from the new piping connections to the cross-tie header. Because the use of charging pumps for this function is considered an acceptable alternate method for meeting NEI 12-06, the ANO-1 strategy for RCS Inventory Control meets the requirements of EA-12-049.

The NRC provided sixteen additional questions related to this strategy as part of the Audit Process. These sixteen new Audit Questions are reflected in the Audit Questions table in Section 6 of this report.

Attachment to 0CAN021405 Page 4 of 8 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Entergy expects to comply with the order implementation date for ANO-2; however, relief/relaxation for ANO-1 is expected to be needed to support the RCS inventory control strategy associated with the alternate power connection for the charging pump.

6 Open Items from OIP and Interim Staff Evaluation (ISE)

The following tables provide a summary and status of any open items documented in the OIP and any open items or confirmatory items documented in the ISE. A fourth table includes a listing of Audit Questions and the status of each item.

OIP Open Items Status There were no open items documented in the ANO N/A Overall Integrated Plan.

ISE Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an ISE for ANO; therefore, there are no open items from the ISE identified at this time.

ISE Confirmatory Items Status The NRC has not issued an ISE for ANO; therefore, N/A there are no confirmatory items from the ISE identified at this time.

Audit Questions Status Completion or Target Date ANO-001 Closed ANO-002 Closed ANO-003 Closed ANO-004 Closed ANO-006 Closed ANO-010 Closed ANO-011 Closed ANO-012 Closed ANO-013 Closed ANO-014 In progress February 2015 ANO-015 In progress February 2015 ANO-018 In progress February 2015 ANO-019 In progress August 2014 ANO-020 Closed ANO-021 In progress February 2015

Attachment to 0CAN021405 Page 5 of 8 Audit Questions Status Completion or Target Date ANO-022 Closed ANO-023 Closed ANO-024 Closed ANO-025 In progress February 2015 ANO-026 Closed ANO-027 Closed ANO-028 Closed ANO-029 Closed ANO-030 Closed ANO-032 In progress February 2015 ANO-034 Closed ANO-035 Closed ANO-041 Closed ANO-044 Closed ANO-045 In progress August 2014 ANO-046 Closed ANO-047 In progress August 2014 ANO-049 In progress February 2015 ANO-051 In progress February 2015 ANO-055 Closed ANO-056 Closed ANO-059 Closed ANO-060 Closed ANO-061 Closed ANO-062 Closed ANO-063 In progress August 2014 ANO-064 Closed ANO-066 Closed ANO-067 In progress August 2014 ANO-068 Closed ANO-069 In progress August 2014 ANO-070 Closed ANO-071 Closed ANO-072 Closed ANO-075 In progress February 2015 ANO-076 Closed

Attachment to 0CAN021405 Page 6 of 8 Audit Questions Status Completion or Target Date ANO-077 In progress February 2015 ANO-078 In progress February 2015 ANO-080 Closed ANO-082 Closed ANO-084 Closed ANO-085 In progress February 2015 ANO-086 Closed ANO-088 Closed ANO-089 Closed ANO-090 Closed ANO-091 Closed ANO-092 Closed ANO-094 Closed ANO-098 Closed ANO-100 In progress February 2015 ANO-104 Closed ANO-106 Closed ANO-107 In progress February 2015 ANO-108 Closed ANO-109 In progress August 2014 ANO-110 Closed ANO-112 Closed ANO-113 Closed ANO-115 In progress August 2014 ANO-116 Closed ANO-117 In progress August 2014 ANO-118 Closed ANO-120 Closed ANO-123 Closed ANO-125 In progress February 2015 ANO-126 Closed ANO-127 In progress* February 2015 ANO-128 In progress February 2015 ANO-129 In progress August 2014 The following additional questions related to ANO Cross-Unit RCS Makeup Strategy were received in January 2014 during the audit process

Attachment to 0CAN021405 Page 7 of 8 Audit Questions Status Completion or Target Date ANO-1 In progress February 2014 ANO-2 In progress February 2014 ANO-3 In progress February 2014 ANO-4 In progress February 2014 ANO-5 In progress February 2014 ANO-6 In progress February 2014 ANO-7 In progress February 2014 ANO-8 In progress February 2014 ANO-9 In progress February 2014 ANO-10 In progress February 2014 ANO-11 In progress February 2014 ANO-12 In progress February 2014 ANO-13 In progress February 2014 ANO-14 In progress February 2014 ANO-15 In progress February 2014 ANO-16 In progress February 2014

  • To include supplemental guidance provided in the NEI position paper entitled Shutdown/Refueling Modes.

7 Potential ISE Impacts There are no potential impacts to the ISE identified at this time except for those identified in Section 6.

Attachment to 0CAN021405 Page 8 of 8 8 References The following references support the updates to the OIP described in this enclosure.

1. OIP in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 28, 2013 (0CAN021302) (ML13063A151)
2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated March 12, 2012 (0CNA031206) (ML12056A045)
3. Entergy letter to NRC, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013 (0CAN081302) (ML13241A414)
4. Entergy letter to NRC, Emergency Preparedness Commitment Changes Related to the March 12, 2012, Information Request, dated October 25, 2013 (0CAN101303)