1CAN041401, Request for Implementation Date Relief in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)

Request for Implementation Date Relief in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees)

ML14098A114
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/08/2014
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN041401, EA-12-049
Download: ML14098A114 (8)

Text

1CAN041401April 7, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

SUBJECT:

Request for Implementation Date Relief in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (BDBEEs)(NRC Order EA-12-049)Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. NRC Order Number EA-12-049,Order to Modify Licenses with Regard toRequirements for Mitigation Strategies for BDBEEs , datedMarch 12, 2012 (0CNA031206) (ML12056A045)2. Entergy letter to NRC,Overall Integrated Plan (OIP) in Response toMarch 12, 2012, Commission Order to Modify Licenses with Regard toRequirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated February 28, 2013 (0CAN021302) (ML13063A151)3. Entergy letter to NRC,First Six-Month Status Report in Response toMarch 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049), dated August 28, 2013 (0CAN081302) (ML13241A414)

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 directed Entergy to develop, implement,and maintain guidance and strategies to maintain or restore core cooling, containment, andspent fuel pool cooling capabilities in the event of a BDBEE.Reference 1 required submissionof an OIP pursuant to Section IV, Condition C which was originally submitted via Reference 2.Reference 3 provided Entergy's OIP updates for Arkansas Nuclear One, Unit 1 (ANO-1) andUnit 2 (ANO-2). Reference 3 identified the completion dates for ANO-1 and ANO-2 asFebruary 2015, andOctober 2015, respectively.Section IV of NRC Order EA-12-049 (Reference 1) states that licensees proposing to deviatefrom requirements contained in NRC Order EA-12-049 may request that the Director, Office ofEntergy Operations, Inc.

1448 S.R. 333Russellville, AR 72802Tel 479-858-3110Jeremy G. BrowningSite Vice PresidentArkansas Nuclear One 1CAN041401 Page 2 of 2Nuclear Reactor Regulation (NRR), relax those requirements. In accordance with Section IV ofNRC Order EA-12-049, Entergy is requesting that the Director, Office of NRR, relax therequirement for completion of full implementation for ANO-1 as prescribed in Section IV.A.2 ofNRC Order EA-12-049 to the startup of ANO-2 from refueling outage 2R24 currently scheduledfor October 2015.This letter contains new regulatory commitments which are identified in Attachment 2. If youhave any questions regarding this request, please contact Stephenie Pyle at 479.858.4704.I declare under penalty of perjury that the foregoing is true and correct; executed onApril 7, 2014.

Sincerely,Original signed by Jeremy G. Browning JGB/nbmAttachments: 1. Arkansas Nuclear One, Unit 1 (ANO-1) NRC OrderEA-12-049 Implementation Date Relief2. 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 to1CAN041401Arkansas Nuclear One, Unit 1 (ANO-1) NRC Order EA-12-049Implementation Date Relief to 1CAN041401 Page 1 of 3ANO-1 NRC Order EA-12-049 Implementation Date ReliefRelaxation Request:Pursuant to the procedure specified in Section IV of NRC Order EA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (BDBEEs) (Reference 1), Entergy Operations,Inc. (Entergy) hereby submits a request for schedule relaxation from the Orderrequirements for completion of full implementation for ANO-1 for no later than startup ofANO-2 from refueling outage 2R24 currently scheduled for October 2015.Order Requirement from Which Relaxation is Requested:NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation of theOrder requirements either no later than two refueling cycles after submittal of theOverall Integrated Plan (OIP), as required by Condition C.I.a, or December 31, 2016,whichever comes first. In accordance with the requirements of the Order, Entergysubmitted an update to the OIP which stated ANO-1 would complete all requiredmodifications by February 2015 (scheduled startup from 1R25 - second refueling cyclefor ANO-1 after submittal of the original OIP) (References 2 and 3). NRC OrderEA-12-049 requires the development, implementation, and maintenance of guidanceand strategies to maintain or restore core cooling, containment, and spent fuel poolcooling capabilities in the event of a BDBEE.As described in the OIP update (Reference 3) ANO-1 plans to utilize ANO-2 chargingpumps, powered from a portable diesel generator (PDG), as part of the Phase 2 Diverseand Flexible Coping Strategies (FLEX). In order to complete all modifications forANO-1, design changes to both of the diverse safety-related switchgear (480-Volt (V)load centers) on ANO-2 are required. Typically, to reduce risk, safety-relatedswitchgear is removed from service on an alternating outage basis. With the ANO-2outage schedule offset from ANO-1, the modification to the second ANO-2safety-related switchgear would normally occur during ANO-2 refueling outage 2R24that is scheduled for completion in October 2015. Based on the ANO-2 refuelingschedule, Entergy is requesting relaxation for the final switchgear modification scheduleto support ANO-1. The relaxation for ANO-1 would extend the currently requiredFebruary 2015 date until startup of ANO-2 from refueling outage 2R24 currentlyscheduled for October 2015.Justification for Relaxation Request:The ANO-1 FLEX strategy relies on re-powering one of the three ANO-2 chargingpumps (2P-36A, 2P-36B, or 2P-36C) for borated water makeup to the ANO-1 reactorcoolant system to support cooldown and depressurization following an extended loss ofalternating current power (ELAP). The ANO-2 electrical modifications that are requiredto support the ANO-1 FLEX strategy are "direct" connections for a PDG through theANO-2 2B5 and 2B6 480V load centers (separate safety-related trains). to 1CAN041401 Page 2 of 3To provide a primary connection point, modification to the 2B6 load center is plannedduring the upcoming ANO-2 2R23 refueling outage. The 2B6 load center providespower to the 2P-36B and 2P-36C (swing) charging pumps. The 2B6 load center canalso power the 2B5 load center through existing cross-tie breakers. The 2B5 loadcenter provides power to the 2P-36A and 2P-36C (swing) charging pumps. As a result,any of the three ANO-2 charging pumps are capable of being powered via the 2B6 loadcenter to support the ANO-1 FLEX strategy. The same type of modification is plannedfor ANO-2 load center 2B5 to provide a second connection point allowing powering of equipment from a PDG.Portions of the ANO-2 load center 2B5 modification are planned to be installed byANO-1 refueling outage 1R25, including installation of the connection for the FLEX PDGto the cables and routing of the cables in the plant. The remaining work consists of thefinal connection to the ANO-2 2B5 load center which is planned for ANO-2 refuelingoutage 2R24. As an interim measure, instructions will be in place by startup from theANO-1 refueling outage 1R25 for connecting a PDG to the 2B5 load center should theANO-2 2B6 load center not be capable of being powered for some unforeseen reasonduring an ELAP (action may not meet the required timeline). The final modificationdesign on the ANO-2 2B5 load center is similar to the one being installed on 2B6(primary connection point) to minimize possibilities of human performance errors and tosupport the conservatively established timelines.The relaxation request is acceptable for the following reasons: For the approximate period of eight months between original date and therelaxation date, the ANO-2 switchgear modifications supporting the ANO-1 FLEXstrategy will already be in place for 2B6 load center which allows powering anyone of the three ANO-2 charging pumps from a PDG. Additionally, the otheraspects of compliance with NRC Order EA-12-049 will be complete by 1R25(e.g., FLEX Support Guidelines, training, equipment staged, and modificationsinstalled). As discussed above, until the redundant 2B5 load center is modified,connection instructions to the 2B5 load center for powering it from a PDG will beavailable to minimize the risk associated with having only a single "quick"connection point (2B6 load center) available. To modify both of the 2B5 and 2B6 load centers in 2R23 would incur risk to bothof the safety-related load centers in a single outage. From an integrated riskperspective this is not typically done. While minor maintenance may beperformed on both trains of safety-related equipment in a refueling outage, therisk mitigation plan for each outage has a specific train emphasis for majormaintenance and modifications. The refueling outage 2R23 for ANO-2 isfocused on green train equipment (2B6) maintenance, and the refueling outage2R24 for ANO-2 is focused on red train equipment (2B5) maintenance. There iscurrently a planned bus outage scheduled on the 2B5 load center in the 2R24outage. To reduce outage risk it is prudent to separate these modifications andperform the 2B5 modifications in 2R24. to 1CAN041401 Page 3 of 3 Additional risk would be introduced from the extensive schedule changesrequired to insert the 2B5 modifications into ANO-2 refueling outage 2R23. Theinsertion of the 2B5 modifications into 2R23 affects the scheduling of red traintesting as well as numerous motor operated valve tests. At this stage in the2R23 scheduling process, this amount of rescheduling flux introduces the risk ofimproperly mitigating the comprehensive risk of multiple equipment scheduleinteractions. With a 2B5 bus outage already scheduled in 2R24, it is prudent toavoid this 2R23 schedule flux risk by performing the 2B5 modifications in 2R24.

==

Conclusion:==

In summary, the 2B5 load center modification to provide diverse electrical connections iscurrently the only aspect of the ANO-1 FLEX strategy that will not be in full compliancewith Reference 1 by the ordered schedule date of February 2015. As a result, fullcompliance with the mitigation strategies required by Reference 1 and described inReference 3 for ANO-1 will be delayed until startup from 2R24 currently scheduled forOctober 2015 (ANO-2 full compliance date). Relief/relaxation from the NRC OrderEA-12-049 IV.A.2 requirements is therefore, requested for ANO-1.

References:

1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard toRequirements for Mitigation Strategies for BDBEEs, dated March 12, 2012(0CNA031206) (ML12056A045)2. Entergy letter to NRC,OIP in Response to March 12, 2012, Commission Order toModify 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, First Six-Month Status Report in Response toMarch 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for BDBEEs (Order Number EA-12-049),dated August 28, 2013 (0CAN081302) (ML13241A414) to1CAN041401List of Regulatory Commitments to 1CAN041401 Page 1 of 1List of Regulatory CommitmentsThe following table identifies those actions committed to by Entergy Operations, Inc. in thisdocument. Any other statements in this submittal are provided for information purposes andare not considered to be regulatory commitments.COMMITMENT TYPE(Check One)

SCHEDULEDCOMPLETIONDATE(If Required)

ONE-TIMEACTIONCONTINUINGCOMPLIANCEAs an interim measure, instructions will bein place by startup from the ArkansasNuclear One (ANO), Unit-1 refueling outage 1R25 for connecting a portablediesel generator to the 2B5 load centershould the ANO-2 2B6 load center not becapable of being powered for someunforeseen reason during an extended loss of alternating current power.

XPrior to ANO-1 Startup from 1R25 (February 2015)The 2B5 load center modification will bethe only aspect of the ANO-1 Diverse andFlexible Coping Strategies (FLEX) thatwill not be in full compliance with NRCOrder EA-12-049 by the ordered scheduledate of February 2015. Additionally, theother aspects of compliance with NRCOrder EA-12-049 will be complete by1R25 (e.g., FLEX Support Guidelines, training, equipment staged, andmodifications installed).

XPrior to ANO-1 Startup from 1R25 (February 2015)