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| | issue date = 04/30/2014 | | | issue date = 04/30/2014 |
| | title = Revised Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force (NTTF) Recommendation 2.3, Flooding | | | title = Revised Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force (NTTF) Recommendation 2.3, Flooding |
| | author name = Browning J G | | | author name = Browning J |
| | author affiliation = Entergy Operations, Inc | | | author affiliation = Entergy Operations, Inc |
| | addressee name = | | | addressee name = |
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MONTHYEAR2CAN012401, U.S. Additional Protocol2024-01-17017 January 2024 U.S. Additional Protocol 2CAN012403, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42024-01-11011 January 2024 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN012401, Registration of Cask Use2024-01-10010 January 2024 Registration of Cask Use 1CAN122301, Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037)2023-12-14014 December 2023 Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037) 2CAN112302, Submittal of Amendment 31 to Safety Analysis Report2023-11-16016 November 2023 Submittal of Amendment 31 to Safety Analysis Report 0CAN102303, Registration of Cask Use2023-10-24024 October 2023 Registration of Cask Use 0CAN102302, (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 32023-10-11011 October 2023 (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 3 0CAN102301, Evacuation Time Estimate (ETE) Study2023-10-0404 October 2023 Evacuation Time Estimate (ETE) Study 1CAN092301, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-09-21021 September 2023 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN092302, Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002)2023-09-14014 September 2023 Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002) 2CAN092301, Reply to a Notice of Violation2023-09-0808 September 2023 Reply to a Notice of Violation 0CAN092301, Emergency Plan Implementing Procedure Revision2023-09-0505 September 2023 Emergency Plan Implementing Procedure Revision 0CAN082301, Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 03412023-08-17017 August 2023 Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341 2CAN082301, Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29)2023-08-10010 August 2023 Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29) 0CAN072301, Registration of Cask Use2023-07-18018 July 2023 Registration of Cask Use 1CAN062304, Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2023-06-29029 June 2023 Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 0CAN062301, Status of Actions to Return to Compliance2023-06-26026 June 2023 Status of Actions to Return to Compliance 0CAN062302, Submittal of Revision 22 of the ANO Fire Hazards Analysis2023-06-20020 June 2023 Submittal of Revision 22 of the ANO Fire Hazards Analysis 1CAN062301, Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037)2023-06-0808 June 2023 Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037) 0CAN052303, Annual 10 CFR 50.46 Report for Calendar Year 20222023-05-24024 May 2023 Annual 10 CFR 50.46 Report for Calendar Year 2022 0CAN052302, Emergency Plan Rev. 482023-05-11011 May 2023 Emergency Plan Rev. 48 0CAN052301, Units 1 and 2 - Annual Radiological Environmental Operating Report for 20222023-05-0909 May 2023 Units 1 and 2 - Annual Radiological Environmental Operating Report for 2022 2CAN052301, Cycle 30 Core Operating Limits Report (COLR)2023-05-0303 May 2023 Cycle 30 Core Operating Limits Report (COLR) 0CAN042302, Annual Occupational Radiation Exposure Report for 20222023-04-27027 April 2023 Annual Occupational Radiation Exposure Report for 2022 0CAN042301, Radioactive Effluent Release Report for 20222023-04-14014 April 2023 Radioactive Effluent Release Report for 2022 2CAN042301, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-04-0505 April 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 1CAN032301, License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure2023-03-30030 March 2023 License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure 2CAN032303, Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032304, Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032305, 03 Post Examination Analysis2023-03-23023 March 2023 03 Post Examination Analysis 1CAN032302, Inspection Summary Report for the Thirtieth Refueling Outage (1R30)2023-03-20020 March 2023 Inspection Summary Report for the Thirtieth Refueling Outage (1R30) 1CAN012301, Responses to Request for Additional Information for Request for Relief ANO1-ISI-0352023-01-30030 January 2023 Responses to Request for Additional Information for Request for Relief ANO1-ISI-035 2CAN012303, U.S. Additional Protocol2023-01-23023 January 2023 U.S. Additional Protocol 2CAN012302, Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-01-20020 January 2023 Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 1CAN122201, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42022-12-22022 December 2022 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN122202, Registration of Cask Use2022-12-21021 December 2022 Registration of Cask Use 0CAN122201, Reply to a Notice of Violation; EA-22-0992022-12-0808 December 2022 Reply to a Notice of Violation; EA-22-099 0CAN112201, Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002)2022-11-10010 November 2022 Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002) 1CAN102202, Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2022-10-31031 October 2022 Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 1CAN102203, Cycle 31 Core Operating Limits Report2022-10-24024 October 2022 Cycle 31 Core Operating Limits Report 1CAN102201, Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-10-13013 October 2022 Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations 0CAN092201, Supplement to License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements2022-09-29029 September 2022 Supplement to License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements 1CAN092201, Supplement to Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period2022-09-0808 September 2022 Supplement to Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period 0CAN082201, License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements2022-08-30030 August 2022 License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements 1CAN082201, Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period2022-08-24024 August 2022 Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period 2CAN072201, Response to Request for Additional Information Requests for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, Second and Third Periods2022-07-20020 July 2022 Response to Request for Additional Information Requests for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, Second and Third Periods 0CAN072201, Registration of Cask Use2022-07-14014 July 2022 Registration of Cask Use 0CAN062202, Registration of Cask Use2022-06-0909 June 2022 Registration of Cask Use 1CAN062201, Response to the Request for Additional Information Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-06-0202 June 2022 Response to the Request for Additional Information Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations 1CAN052201, Request for Relief Related to American Society of Mechanical Engineers (ASME) Code Case N-729-6 Augmented Examination Requirements ANO1-ISI-0352022-05-31031 May 2022 Request for Relief Related to American Society of Mechanical Engineers (ASME) Code Case N-729-6 Augmented Examination Requirements ANO1-ISI-035 2024-01-17
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0CAN041410April 30, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852
SUBJECT:
Revised Response to NRC 10 CFR 50.54(f) Request for Information RegardingNear-Term Task Force (NTTF) Recommendation 2.3, FloodingArkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368License Nos. DPR-51 and NPF-6
REFERENCES:
- 1. NRC Letter to Entergy,Request for Information Pursuant to10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of theNTTF Review of Insights from the Fukushima Dai-ichi Accident
,March 12, 2012 (ML12053A340) (0CNA031208)2. Entergy Letters to NRC,Flooding Walkdown Report - Entergy'sResponse to NRC Request for Information Pursuant to 10 CFR 50.54(f)Regarding the Flooding Aspects of Recommendation 2.3 of the NTTFReview of Insights from the Fukushima Dai-ichi Accident , datedNovember 27, 2012, (ML12334A008 and ML12334A006) (1CAN111202 and 2CAN111202)3. NRC Letter to Entergy,Request for Additional Information (RAI)Associated with NTTF Recommendation 2.3, Flooding Walkdowns , datedDecember 23, 2013 (ML13325A891) (0CNA121304)4. Entergy Letter to NRC,Update to Response to NRC 10 CFR 50.54(f)Request for Information Regarding NTTF Recommendation 2.3, Flooding- Review of Available Physical Margin (APM) Assessments, datedJanuary 31, 2014 (ML14031A183) (0CAN011404)
Dear Sir or Madam:
On March 12, 2012, the NRC staff issued Reference 1 requesting information pursuant toTitle 10 of the Code of Federal Regulations 50.54(f) which contains specific RequestedInformation associated with NTTF Recommendation 2.3 for Flooding. By Reference 2, EntergyOperations, Inc. (Entergy) initially submitted the Flooding Walkdown Reports for ArkansasNuclear One (ANO).Entergy Operations, Inc.
1448 S.R. 333Russellville, AR 72802Tel 479-858-3110Jeremy G. BrowningSite Vice PresidentArkansas Nuclear One 0CAN041410 Page 2 of 2The NRC issued RAIs concerning APM by Reference 3. By Reference 4 Entergy committed torespond to the APM RAIs and provide revised Flooding Walkdown Reports by April 30, 2014.The flooding walkdowns have been completed; however, additional time is needed to compilethe results and finalize the reports; therefore, Entergy will provide the revised FloodingWalkdown Reports by May 15, 2014. In accordance with Entergy's commitment managementprocedure, the NRR Project Manager was notified of the delay on April 29, 2014. Attachment 1provides responses to the APM RAIs.This letter contains a new regulatory commitment which is identified in Attachment 2. Shouldyou 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 onApril 30, 2014.
Sincerely,Original signed by Jeremy G. Browning JGB/nbmAttachments: 1. Responses to APM RAIs for ANO2. List of Regulatory Commitmentscc: Mr. Marc L. DapasRegional AdministratorU. S. Nuclear Regulatory Commission, Region IV1600 East Lamar BoulevardArlington, TX 76011-4511NRC Senior Resident Inspector Arkansas Nuclear OneP.O. Box 310London, AR 72847U. S. Nuclear Regulatory CommissionAttn: Mr. Peter Bamford MS O-8B3One White Flint North11555 Rockville PikeRockville, MD 20852 to0CAN041410Responses to Available Physical Margin (APM) Requests for AdditionalInformation (RAIs) for Arkansas Nuclear One (ANO) to 0CAN041410 Page 1 of 2Responses to APM RAIs for ANORAI 1: Provide confirmation that the process for evaluating APM was reviewed.Entergy Operations, Inc. has completed a review of the process used at ANO-1 and ANO-2 toevaluate APMs.RAI 2: Provide confirmation that the APM process is now or was always consistent withthe guidance in Nuclear Energy Institute (NEI) 12-07 and discussed in this RAI.The original walkdown effort intended to follow the guidance provided in NEI 12-07. For thesubsequent walkdown effort, additional actions have been taken to make the processconsistent with the information provided in this RAI including the definition of small margin.RAI 3: If changes are necessary, a general description of any process changes toestablish this consistency.As stated above, the original walkdown effort intended to follow the guidance provided inNEI 12-07; however, discrepancies were identified in the original walkdown reports. As a resulta subsequent walkdown effort has been performed, and APM is being documented. For thesubsequent walkdown effort, the definition for a small margin was updated to be consistent withthe information provided in this RAI.RAI 4: As a result of the audits and subsequent interactions with industry during publicmeetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors,penetrations, flood gates, etc.) was challenging for some licensees. Generally, licenseeswere expected to use either Approach A or Approach B (described below) to determinethe APM for seals:a) If seal pressure ratings were known, the seal ratings were used to determine APM(similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APMwas documented. No further action was performed if the APM value was greaterthan the pre-established small-margin threshold value. If the APM value wassmall, an assessment of "significant consequences" was performed and theguidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier isassumed to be greater than the pre-established small-margin threshold value ifthe following conditions were met: (1) the APM for the barrier in which the seal islocated is greater than the small-margin threshold value, and there is evidencethat the seals were designed/procured, installed, and controlled as flooding sealsin accordance with the flooding licensing basis. Note that in order to determinethat the seal has been controlled as a flooding seal it was only necessary todetermine that the seal configuration has been governed by the plant's design to 0CAN041410 Page 2 of 2control process since installation. In this case, the APM for the seal could havebeen documented as "not small."As part of the RAI response, state if either Approach A or Approach B was used as partof the initial walkdowns or as part of actions taken in response to this RAI. No additionalactions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either aspart of the walkdowns or as part of actions taken in response to this RAI), then performthe following two actions:Enter the condition into the Corrective Action Program (CAP) (note: it isacceptable to utilize a single CAP entry to capture this issue for multiple seals).CAP disposition of "undetermined" APM values for seals should consider theguidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirmall seals can perform their intended safety function against floods up to thecurrent licensing basis flood height. Disposition may occur as part of theIntegrated Assessment. If an Integrated Assessment is not performed, determinewhether there are significant consequences associated with exceeding thecapacity of the seals and take interim action(s), if necessary, via the CAPprocesses. These actions do not need to be complete prior to the RAI response.Report the APM as "undetermined" and provide the CAP reference in the RAI response.Approach A is being used to determine APM if seal pressure ratings are known; Approach B isbeing used to determine APM for seals if seal pressure ratings are not known. When the sealpressure rating is not known, the APM for these seals is assumed to be greater than thepre-established small-margin threshold value. The conditions described above are being metbecause the APM for the barrier in which the seal is located is greater than the small-marginthreshold value, and the seals were designed, procured, and installed in accordance with theANO licensing basis. The seals are being inspected as part of the walkdowns for signs ofdegradation, and corrective actions are being taken, when required. to0CAN041410List of Regulatory Commitments to 0CAN041410 Page 1 of 1List of Regulatory CommitmentsThe following table identifies those actions committed to by Entergy Operations, Inc. (Entergy)in this document. Any other statements in this submittal are provided for information purposesand are not considered to be regulatory commitments.COMMITMENT TYPE(Check One)
SCHEDULEDCOMPLETIONDATE(If Required)
ONE-TIMEACTIONCONTINUINGCOMPLIANCEProvide revised Flooding Walkdown Reports XMay 15, 2014