ML13241A415

First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13241A415
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/28/2013
From:	Jeremy G. Browning Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, OCAN081303
Download: ML13241A415 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President, Operations Arkansas Nuclear One 0CAN081303 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation, dated March 12, 2012 (0CNA031207) (ML12054A679)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable SFP Instrumentation, Revision 0, dated August 29, 2012 (ML12221A339)

3. Nuclear Energy Institute (NEI) 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable SFP Instrumentation, Revision 1, dated August 2012 (ML12240A307)

4. Entergy letter to NRC, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation (Order Number EA-12-051), dated October 26, 2012 (0CAN101204)

(ML12305A274)

5. Entergy letter to NRC, Overall Integrated Plan (OIP) in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable SFP Instrumentation (Order Number EA-12-051), dated February 28, 2013 (0CAN021303)

(ML13063A015)

0CAN081303 Page 2 of 3

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 install reliable SFP level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

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 12-02, Revision 1 (Reference 3). Reference 4 provided the initial status report regarding SFP instrumentation, 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. The purpose of this letter is to provide the first 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 August 28, 2013.

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

Attachment:

Arkansas Nuclear One Units 1 and 2 First Six Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable SFP Instrumentation

0CAN081303 Page 3 of 3 cc: Mr. Steven A. Reynolds Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam One White Flint North MS O-8 B1 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Jessica A. Kratchman One White Flint North MS 9-D2 11555 Rockville Pike Rockville, MD 20852

Attachment to 0CAN081303 Arkansas Nuclear One (ANO) Units 1 and 2 (ANO-1 and ANO-2) First Six Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation

Attachment to 0CAN081302 Page 1 of 3 ANO-1 and ANO-2 First Six Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable SFP Instrumentation Introduction Entergy Operations, Inc. developed an overall integrated plan (OIP) provided via Reference 1 for ANO-1 and ANO-2, documenting the requirements to install reliable spent fuel pool instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference 1) and are current as of July 31, 2013.

• Although not part of the original milestone schedule, NRC requests for additional information (RAIs) were received June 26, 2013 (Reference 3) and responded to on July 25, 2013 (Reference 4). The responses to the RAIs were added to the milestone schedule. The addition of this milestone and target completion date does not impact the Order implementation date.

Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

Revised Target Completion Activity Target Milestone Date Status Completion Date ANO-1 Reliable SFPI October 2013 In Progress Design Modification Package Developed/Issued ANO-1 Reliable SFPI 1R25 Fall 2014 Pending 1R25 Early Installed Refueling Outage 2015 Refueling Outage (see Note)

ANO-2 Reliable SFPI July 2014 Pending Design Modification Package Developed/Issued ANO-2 Reliable SFPI 2R24 Fall 2015 Pending Installed Refueling Outage NRC RAIs (Received Submitted Not Applicable July 25, 2013 June 26, 2013)

Attachment to 0CAN081302 Page 2 of 3 Note: The ANO-1 Refueling Outage 1R25 (second refueling outage after submittal of the OIP) original schedule date of Fall 2014 has slipped to early 2015 due to the 1R24 (Spring 2013) stator drop event recovery and outage extension.

Changes to Compliance Method There are no significant changes to the compliance method as documented in the OIP (Reference 1). OIP changes and/or updates based on current design and implementation plans are considered minor in nature and are summarized as follows:

• Reference OIP Section 2 (Schedule). ANO-1 compliance / implementation /

target completion date has slipped as noted in the above Milestone Schedule Status. This is a change of the physical date only while maintaining the required implementation association with the second refueling outage after submittal of the OIP.

• Reference OIP Section 6 (Instrument Channel Design Criteria), Section 7 (Arrangement), and Attachments 1 and 2 (SFPI Simplified Approximate Locations and Cable Routing). These sections state that in the SFP area, cables shall be routed in rigid metal conduit. As already identified in the RAI response (Reference 4), this is updated to protective metal raceway to open up the generic use of raceway (versus conduit) to allow use of wire/tube tracks with convenient removable covers to better facilitate installation.

Need for Relief/Relaxation and Basis for the Relief/Relaxation ANO expects to comply with the order implementation date and no relief/relaxation is required at this time.

Open Items from OIP and Draft Safety Evaluation None Potential Draft Safety Evaluation (SE) Impacts The NRC has not issued a draft SE for either unit; therefore, there are no potential impacts to the draft SE identified at this time.

Attachment to 0CAN081302 Page 3 of 3 References

1. OIP in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 28, 2013 (0CAN021303) (ML13063A015)

2. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (0CNA031207)

(ML12054A679)

3. RAI for the OIP in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation (Order Number EA-12-051), dated June 26, 2013, (0CNA061308) (ML13156A313)

4. Response to RAI for the OIP in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation, dated July 25, 2013 (0CAN071301) (ML13207A269)