0CAN021502, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)

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Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)
ML15056A137
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 02/24/2015
From: Jeremy G. Browning
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN021502, EA-12-049
Download: ML15056A137 (16)
v • d • e


Text

0CAN021502 February 24, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Fourth 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. 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)
3. Entergy letter to NRC, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs, dated August 28, 2014 (0CAN081402) (ML14241A660)

Dear Sir or Madam:

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

(Entergy) which required submission an OIP pursuant to Section IV, Condition C, which was provided by Reference 2.

Reference 1 also requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provided the third six-month status report. The purpose of this letter is to provide the fourth 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.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Site Vice President Arkansas Nuclear One

0CAN021502 Page 2 of 2 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 24, 2015.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/nbm

Attachment:

Arkansas Nuclear One Units 1 and 2 Fourth 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) 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: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Mr. Peter Bamford MS O13F15M One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 0CAN021502 Arkansas Nuclear One Units 1 and 2 (ANO-1 and ANO-2) Fourth 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 0CAN021502 Page 1 of 13 Arkansas Nuclear One Units 1 and 2 (ANO-1 and ANO-2) Fourth 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)

1.

Introduction Entergy Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) for Arkansas Nuclear One, Unit 1 (ANO-1) and Unit 2 (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 7), 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 1, 2014, and are current as of January 31, 2015:

Third Six-Month Status Report August 2014 Perform Staffing Assessment - September 2014 Develop Strategies with National SAFER Response Center - November 2014 Install Off-site Delivery Station - October 2014 Fourth Six-Month Status Report Complete with submission of this document in February 2015

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.

Milestone Target Completion Date*

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

Attachment to 0CAN021502 Page 2 of 13 Milestone Target Completion Date*

Activity Status Revised Target Completion Date Modifications Modifications Evaluation June 2013 Complete Engineering and Implementation June 2013 -

October 2015 Started ANO-1 Implementation Outage February 2015 Started October 2015 ANO-2 Implementation Outage October 2015 Started On-site FLEX Equipment Purchase October 2014 Started September 2015 Procure August 2015 Started September 2015 Off-site FLEX Equipment Develop Strategies with National SAFER Response Center November 2014 Complete Install Off-site Delivery Station (if necessary)

October 2014 Complete Procedures Pressurized Water Reactor Owners Group issues Nuclear System Steam Supply (NSSS)-specific guidelines June 2013 Complete Issued May 2013 Create ANO FLEX Strategy Guide November 2014 Started October 2015 Create Maintenance Procedures November 2014 Started October 2015 Training Develop Training Plan December 2014 Started August 2015 Implement Training August 2015 Started Validation ANO-1 walk-throughs or demonstration(s)

- including all FLEX equipment points of connect/tie-in for Phase 2 and 3 March 2015 Not Started ANO-2 walk-throughs or demonstration(s)

- including all FLEX equipment points of connect/tie-in for Phase 2 and 3 October 2015 Not Started Submit Completion Report February 2016 Not Started

  • Target Completion Date is the last submitted date from either the overall integrated plan or previous six month status reports.

Attachment to 0CAN021502 Page 3 of 13

4.

Changes to Compliance Method There are no additional changes to the compliance method as documented in the OIP (Reference 1).

5.

Need for Relief/Relaxation and Basis for the Relief/Relaxation Entergy expects to comply with the order implementation date for ANO-2. As part of a separate submittal (Reference 4), Entergy requested an extension for ANO-1 for no later than startup of ANO-2 from refueling outage 2R24 currently scheduled for fall 2015. The request was submitted to support the Reactor Coolant System (RCS) inventory control strategy associated with the alternate power connection for the Charging Pump. The request included two commitments. This request for relief/relaxation for ANO-1 with the two commitments was approved by the NRC via Reference 5. Subsequent to approval by the NRC of the relief/relaxation associated with the two commitments, Entergy determined that ANO-1 implementation of NRC Order EA-12-049 prior to implementation at ANO-2 was a less optimal action than a coordinated ANO-1 and ANO-2 implementation. As part of an additional separate submittal (Reference 8), Entergy has withdrawn the two commitments in the submittal of Reference 4. Based on the Reference 8 submittal, the ANO-1 full order compliance date is startup from 2R24 (fall 2015). The justification for this commitment withdrawal was provided in Reference 8.

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 (Reference 6). 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 OIP.

N/A ISE Open Items Status 3.2.1.D The NRC Staff has reviewed the ANO approach that uses the ANO-2 charging pump to supply makeup to the ANO-1 RCS for inventory control but has not concluded that this approach is acceptable. The Staff has identified a number of concerns that need to be addressed regarding the proposed RCS inventory control strategy.

Therefore, this open item tracks completion of the development of an acceptable integrated RCS makeup strategy that meets the requirements of Order EA-12-049.

This item is addressed by audit question (AQ)

ANO-035, ANO-046, ANO-106 and ANO-107 responses on the AQ spreadsheet on the ePortal.

Attachment to 0CAN021502 Page 4 of 13 ISE Open Items Status 3.2.1.8.B For ANO-1 and ANO-2 verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.

This item is addressed by updated AQ ANO-041 response on the AQ spreadsheet on the ePortal.

ISE Confirmatory Items Status 3.1.1.2.A Confirm whether there is a need for a power source to move or deploy the FLEX equipment (e.g., to open the door from a storage location).

This item is addressed on the AQ response spreadsheet on the ePortal.

3.1.1.4.A Confirm that the local staging area for Regional Response Center equipment has been identified and a description of the methods to be used to deliver the equipment to the site has been provided.

This item is addressed on updated AQ response spreadsheet.

3.1.3.1.A Confirm that the axis of separation and distance between the portable equipment storage buildings provides assurance that a single tornado will not impact both buildings.

This item is addressed by AQ ANO-002 response on the AQ spreadsheet on the ePortal.

3.2.1.A Confirm that the Atmospheric Dump Valves and associated piping at both units are sufficiently robust and will remain functional during and following a seismic event.

This item is addressed by updated AQ ANO-109 response on the AQ spreadsheet on the ePortal.

3.2.1.B Confirm that the ANO-2 cooldown analysis supports the delay in the cooldown to eight hours following the extended loss of all power (ELAP).

This item is addressed by AQ ANO-014, 015, 018, 021, 025, 035, 049, 051, 075, 077, 078, and 085 responses on the AQ spreadsheet on the ePortal.

3.2.1.C Confirm that the evaluation of the emergency feedwater (EFW) turbine exhaust piping for robustness is completed with acceptable results.

This item is addressed by AQ ANO-109 response on the AQ spreadsheet on the ePortal.

Attachment to 0CAN021502 Page 5 of 13 ISE Confirmatory Items Status 3.2.1.1.A Confirm that reliance on the RELAP5/MOD2-B&W code in the ELAP analysis for ANO-1 is limited to the flow conditions prior to boiler-condenser cooling initiation.

This item is addressed by update to AQ ANO-015 response on the AQ spreadsheet on the ePortal.

3.2.1.1.B Confirm that the use of CENTS in the ELAP analysis is limited to the flow conditions prior to reflux boiling initiation.

This item is addressed by AQ ANO-015 response on the AQ spreadsheet on the ePortal.

3.2.1.2.A For ANO-1 confirm that the strategy is effective in keeping the RCS temperatures within the limits of the seal design temperatures, and supports the leakage rate (two gallons per minute (gpm)/seal) used in the ELAP analysis.

To be confirmed at NRC audit.

3.2.1.2.B For ANO-1, confirm adequate justification for (including seal leakage testing data) the use of two gpm/seal in the ELAP analysis.

To be confirmed at NRC audit.

3.2.1.3.A Verify the ELAP analysis assumption that decay heat is per ANS [American Nuclear Society] 5.1-1979 + 2 sigma, or equivalent.

This item is addressed by AQ ANO-019 response on the AQ spreadsheet on the ePortal.

3.2.1.4.A For ANO-1 confirm the revision to WCAP-17601 used and also confirm whether there are any deviations taken from the assumptions presented in Nuclear Energy Institute (NEI) 12-06, Section 3.2.

This item is addressed by AQ ANO-075 response on the AQ spreadsheet on the ePortal.

3.2.1.8.A Confirm the acceptability of the ANO-2 shutdown margin results after accounting for the delay in the cooldown to eight hours following an ELAP.

This item is addressed by AQ ANO-078 response on the AQ spreadsheet on the ePortal.

3.2.1.9.A Confirm the adequacy of the RCS injection strategy considering the analysis in licensee calculation CN-SEE-II-13-2 as it relates to the delay in the ANO-2 cooldown to eight hours following an ELAP.

This item is addressed by AQ ANO-051 and ANO-077 responses on the AQ spreadsheet on the ePortal.

Attachment to 0CAN021502 Page 6 of 13 ISE Confirmatory Items Status 3.2.1.9.B Confirm the final specific times for connection and use of the portable National SAFER Response Center pumps.

In progress. This item to be addressed by update to AQ ANO-035 response on the AQ spreadsheet on the ePortal when information is available.

3.2.3.A Confirm acceptable results of the ANO-2 containment ELAP analysis after it is completed.

This item is addressed by updated AQ ANO-032 response on the AQ spreadsheet on the ePortal.

3.2.4.2.A Confirm acceptable results of the ANO main control room heat-up calculation after it is performed.

This item is addressed by updated AQ ANO-061 response on the AQ spreadsheet on the ePortal.

3.2.4.2.B Confirm the adequacy of ANO-2 battery room ventilation for extreme temperature protection when the design development is completed.

This item is addressed by updated AQ ANO-125 response on the AQ spreadsheet on the ePortal.

3.2.4.2.C Confirm the adequacy of calculations for extreme temperature protection regarding ANO-2 turbine-driven EFW pump room and electrical equipment rooms when the design development is completed.

This item is addressed by updated AQ ANO-060 response on the AQ spreadsheet on the ePortal.

3.2.4.4.A Confirm that upgrades to the site's communications systems have been completed as planned.

To be confirmed at NRC audit.

3.2.4.7.A Confirm that a final strategy for use of the mobile boration unit is developed.

This item is in progress, and when information becomes available is planned to be addressed by AQ ANO-044 response on the AQ spreadsheet on the ePortal.

3.2.4.10.A For ANO-2 confirm that an acceptable load shedding strategy is developed.

This item is addressed by AQ ANO-128 response on the AQ spreadsheet on the ePortal.

Attachment to 0CAN021502 Page 7 of 13 ISE Confirmatory Items Status 3.2.4.10.B For ANO-2 confirm that an acceptable direct current (DC) load profile is developed.

This item is addressed by updated AQ ANO-070 response on the AQ spreadsheet on the ePortal.

3.2.4.10.C For ANO-2 confirm that an acceptable basis for the minimum DC bus voltage is determined.

This item is addressed by updated AQ ANO-072 response on the AQ spreadsheet on the ePortal.

3.3.2.A Confirm that acceptable strategies and their bases are developed and maintained in an overall program document, as described in NEI 12-06, Section 11.8, items 1 and 3.

This item is addressed on the AQ response spreadsheet on the ePortal.

3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.

This item is addressed on the AQ response spreadsheet on the ePortal.

Audit Questions Status Completion or Target Date ANO-001 Closed* Response available on the ePortal ANO-002 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.1.3.1.A)

ANO-003 Closed* Response available on the ePortal ANO-004 Closed* Response available on the ePortal ANO-006 Closed* Response available on the ePortal ANO-010 Closed* Response available on the ePortal ANO-011 Closed* Response available on the ePortal ANO-012 Closed* Response available on the ePortal ANO-013 Closed* Response available on the ePortal ANO-014 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Attachment to 0CAN021502 Page 8 of 13 Audit Questions Status Completion or Target Date ANO-015 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.1.A)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.1.B)

ANO-018 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

ANO-019 Closed* Response is available on the ePortal (associated with ISE Confirmatory Item 3.2.1.3.A)

ANO-020 Closed* Response available on the ePortal ANO-021 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

ANO-022 Closed* Response available on the ePortal ANO-023 Closed* Response available on the ePortal ANO-024 Closed* Response available on the ePortal ANO-025 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

ANO-026 Closed* Response available on the ePortal ANO-027 Closed* Response available on the ePortal ANO-028 Closed* Response available on the ePortal ANO-029 Closed* Response available on the ePortal ANO-030 Closed* Response available on the ePortal ANO-032 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.3.A)

ANO-034 Updated response available on the ePortal ANO-035 Closed*. Response available on the ePortal (associated with ISE Open Item 3.2.1.D)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

In progress (associated with ISE Confirmatory Item 3.2.1.9.B)

April 2015 ANO-041 Updated response available on the ePortal (associated with ISE Open Item 3.2.1.8.B)

ANO-044 In progress (associated with ISE Confirmatory Item 3.2.4.7.A)

April 2015

Attachment to 0CAN021502 Page 9 of 13 Audit Questions Status Completion or Target Date ANO-045 Closed* Response available on the ePortal ANO-046 Closed* Response available on the ePortal (associated with ISE Open Item 3.2.1.D)

ANO-047 Closed* Response available on the ePortal ANO-049 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

ANO-051 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.9.A ANO-055 Closed* Response available on the ePortal ANO-056 Closed*. Response available on the ePortal ANO-059 Closed* Response available on the ePortal ANO-060 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.2.C)

ANO-061 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.2.A)

ANO-062 Closed* Response available on the ePortal ANO-063 Closed* Response available on the ePortal ANO-064 Closed* Response available on the ePortal ANO-066 Closed* Response available on the ePortal ANO-067 Updated response available on the ePortal ANO-068 Closed* Response available on the ePortal ANO-069 In progress April 2015 ANO-070 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.10.B)

ANO-071 Updated response available on the ePortal ANO-072 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.10.C)

ANO-075 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.4.A)

ANO-076 Closed* Response available on the ePortal

Attachment to 0CAN021502 Page 10 of 13 Audit Questions Status Completion or Target Date ANO-077 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.9.A)

ANO-078 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.8.A)

ANO-080 Updated response available on the ePortal ANO-082 Closed* Response available on the ePortal ANO-084 Closed* Response available on the ePortal ANO-085 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.B)

ANO-086 Closed* Response available on the ePortal ANO-088 Closed* Response available on the ePortal ANO-089 Closed* Response available on the ePortal ANO-090 Closed* Response available on the ePortal ANO-091 Closed* Response available on the ePortal ANO-092 Closed* Response available on the ePortal ANO-094 Closed* Response available on the ePortal ANO-098 Closed* Response available on the ePortal ANO-100 Closed* Response available on the ePortal ANO-104 Closed* Response available on the ePortal ANO-106 In Progress - Updated response available on the ePortal (associated with ISE Open Item 3.2.1.D)

April 2015 ANO-107 Closed* Response available on the ePortal (associated with ISE Open Item 3.2.1.D)

ANO-108 Closed* Response available on the ePortal ANO-109 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.A)

Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.1.C)

ANO-110 In progress.

April 2015

Attachment to 0CAN021502 Page 11 of 13 Audit Questions Status Completion or Target Date ANO-112 Closed* Response available on the ePortal ANO-113 Closed* Response available on the ePortal ANO-115 Updated response available on the ePortal ANO-116 Closed* Response available on the ePortal ANO-117 Closed* Response available on the ePortal ANO-118 Closed* Response available on the ePortal ANO-120 Closed* Response available on the ePortal ANO-123 Closed* Response available on the ePortal ANO-125 Updated response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.2.B)

ANO-126 Closed* Response available on the ePortal ANO-127 Updated response available on the ePortal ANO-128 Closed* Response available on the ePortal (associated with ISE Confirmatory Item 3.2.4.10.A)

ANO-129 Closed* Response available on the ePortal The following additional questions related to ANO Cross-Unit RCS Makeup Strategy were received in January 2014 during the audit process ANO-1 Closed* Response available on the ePortal ANO-2 Closed* Response available on the ePortal ANO-3 Closed* Response available on the ePortal ANO-4 Closed* Response available on the ePortal ANO-5 Closed* Response available on the ePortal ANO-6 Closed* Response available on the ePortal ANO-7 Closed* Response available on the ePortal ANO-8 Closed* Response available on the ePortal ANO-9 Closed* Response available on the ePortal ANO-10 In Progress - Updated response available on the ePortal April 2015 ANO-11 Closed* Response available on the ePortal ANO-12 Closed* Response available on the ePortal ANO-13 Closed* Response available on the ePortal ANO-14 Closed* Response available on the ePortal

Attachment to 0CAN021502 Page 12 of 13 Audit Questions Status Completion or Target Date ANO-15 Closed* Response available on the ePortal ANO-16 Closed* Response available on the ePortal

  • Closed indicates that Entergys response is complete.
7.

Potential ISE Impacts The following items have been identified which have potential impact to the ISE except for those identified in Section 6.

1.

ISE/TER Section 3.2.1, Page 29, the TER states, the Boric Acid Makeup Tanks, Refueling Water Tank, Borated Water Storage Tank or the new borated water tank will provide this function. Currently, there are no plans to install a new borated water tank.

Instead, Entergy is pursuing applying Regulatory Guide (RG) 1.76, Revision 1, to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.

2.

ISE/TER Section 3.2.4.7, Page 66, the TER states, For high wind BDBEEs, a new borated water storage tank, which Currently, Entergy has no plans to install a new borated water tank. Instead, Entergy is pursuing applying RG 1.76, Revision 1, to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.

3.

ISE/TER Section 3.2.4.7, Page 67, the TER states, This 30-minute action to manually align valves in the intake structure will be validated during the procedure development phase and staffing assessment. For a high wind missile event that damages the Qualified Condensate Storage Tank (QCST), performing the valve realignments within 30 minutes for both units has been determined to be non-viable. It has been determined that the manipulation of the valves at the intake structure will take 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 30 minutes. Therefore, to qualify additional QCST inventory to at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, to allow enough time for aligning this new permanently installed crosstie between the Fire Water and the Service Water systems, Entergy is currently pursuing applying RG 1.76, Revision 1, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, to the QCST to qualify additional water through a finite element analysis.

4.

ISE/TER Section 3.2.4.7, Page 68, the TER states, A new borated water tank will be installed for coping with FLEX following high wind BDBEEs. Currently, Entergy has no plans to install a new borated water tank. Instead, Entergy is pursuing applying RG 1.76, Revision 1, to the borated water storage tanks available at the site to qualify additional borated water through a finite element analysis.

Attachment to 0CAN021502 Page 13 of 13

8.

References

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. 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) (ML13241A414)
4. Request for Implementation Date Relief in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs (NRC Order EA-12-049) Arkansas Nuclear One - Unit 1, dated April 8, 2014 (1CAN041401) (ML14098A114)
5. Arkansas Nuclear One, UNIT 1 -Relaxation of the Schedule Requirements for Order EA-12-049 "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, dated May 20, 2014 (ML14114A697)
6. Arkansas Nuclear One, Units 1 and 2 - ISE Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0942 and MF0943),

dated February 25, 2014 (ML14007A459)

7. Third 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, 2014 (0CAN081402) (ML14241A660)
8. Commitment Change Notification for NRC Order EA-12-049 Arkansas Nuclear One -

Unit 1, dated January 16, 2015 (1CAN011504) (ML15016A433)

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