ML20028F121

Responds to 821208 Draft Safety Evaluation of Util 820701 Submittal Re App R Compliance.Meeting Requested in Order to Allow Opportunity to Appeal NRC Position Requiring Source Range Monitor as Part of Alternate Shutdown Means

ML20028F121
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/28/1982
From:	John Marshall ARKANSAS POWER & LIGHT CO.
To:	Clark R, Stolz J Office of Nuclear Reactor Regulation
References
0CAN128215, CAN128215, NUDOCS 8301310167
Download: ML20028F121 (3)

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE box 551 LITTLE ROCK. ARKANSAS 72203 $01) 3714000 December 28, 1982 OCAN128215 Director of Nuclear Reactor Regulation ATTN: Mr. J. F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555 Director of Nuclear Reactor Regulation ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Draft Safety Evaluation of Appendix R Compliance Submittal Gentlemen:

Please refer to your letter of December 8, 1982, (0CNA128208) transmitting l the Draft Safety Evaluation of our July 1, 1982, Appendix R compliance submittal.

. As a result of meetings held between Mr. M. McGarry, III, representing the I Nuclear Utility Fire Protection Group, and Mr. R. Vollmer of the NRC, the latest of which was held on December 17, 1982, we have been informed that our submittal of November 11, 1982, (0CAN118210) will be considered in the current 10CFR50.48 exemption request review and will not need to be l resubmitted under a separate 10CFR50.12 exemption request. It follows, I

therefore, the results of your review of the November 11, 1982, submittal will be incorporated into the text of a " final" Safety Evaluation and the tolling provision of 10CFR50.48 will remain in effect until formal issuance

, of that " final" document.

OO 8301310167 821228 PDR ADOCK 05000 F

MEMDEF4 MtOOLE SOUTH UTILITIES SYSTEM

Mr. J. F. Stolz Mr. Robert Clark December 28, 1982 With this understanding, we have the following response.

(1) We request a meeting be held in order to allow AP&L to appeal the NRC position which requires a source range monitor as part of the alternate shutdown means described in Appendix A of our July 1, 1982, Appendix R submittal. Also, at this meeting we will appeal the Staff's position that partial sprinkler system coverage does nut comply with Appendix R.

Your December 8, 1982, letter stated the appeal meeting must be requested and held within 3 weeks from the date of your letter, i.e., by December 29, 1982. However, when we requested such a meeting on December 15, 1982, our Project Managers (ANO-1 and ANO-2) informed us a meeting could not be held within that time.

By telephone conversation with our AN0-2 Project Manager on December 23, 1982, the meeting was scheduled for January 12, 1983.

This schedule is acceptable to us. We believe these telephone conversations properly document our attempts to arrange for a meeting within the required schedule and also preserve our right to have that meeting post December 29, 1982.

(2) We request our November 11, 1982, letter (OCAN118219) be reviewed to satisfy actions (2) and (3) as discussed in your December 8 letter and as presented above.

(3) We request an exemption be granted for ANO-1 not being capable of achieving cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with loss of off-site power. As stated in our October 5, 1982, letter (9CAN198203) to you, this cannot be accomplished because of the additional time (approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />) required to cool and depressurize the reactor coolant system without auxiliary pressurizer spray.

Pressurizer spray is taken from the discharge of the reactor coolant pumps which are not operational without off-site power.

However, for all initial conditions for which ANO-1 can achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without a fire, it can also accomplish the same with a fire. We do not believe it is the intent of Appendix R to challenge the design basis of an operating plant for those cases where the consequences of a fire are not relevant.

If the staff decides this exemption request should not be granted, then this item will be included as a subject for discussion at the appeals meeting requested in item (1) of this letter.

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Mr. J. F. Stolz Mr. Robert Clark December 28, 1982 e

If our understanding of the handling of our November 11, 1982,- letter is in error, and it is not the intention of the NRC to review that information {

prior to issuance of a " final" Safety Evaluation, then it is necessary for us, at this time, to request an appeals meeting to discuss all items described above in items (1) and (3), as well as all exemptions considered for denial as specified in your December 8, 1982, draft Safety Evaluation submittal.

Very truly yours, John R. Marshall Manager, Licensing JRH: LVP: sc i

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