0CAN081402, Third 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)

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Third 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)
ML14241A660
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 08/28/2014
From: Browning J G
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN081402, EA-12-049
Download: ML14241A660 (20)
v • d • e


Text

0CAN081402

August 28, 2014

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT:

Third 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, 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)
4. Entergy letter to NRC, Second 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 February 27, 2014 (0CAN021405)

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.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

Tel 479-858-3110 Jeremy G. Browning Site Vice President A rkansas Nuclear One

0CAN081402 Page 2 of 2 Reference 1 also requires submission of a status report at six-month intervals following submittal of the OIP. References 3 and 4 provided the first and second six-month status

reports, respectively. The purpose of this letter is to provide the third six-month status

report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress

made in implementing the requirements of Re ference 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, 2014.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING

JGB/nbm

Attachment:

Arkansas Nuclear One Units 1 and 2 Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with

Regard to Requirements for Mitigation Strategies for 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. John Hughey

MS 13-C5 One White Flint North

11555 Rockville Pike

Rockville, MD 20852

Attachment to 0CAN081402 Arkansas Nuclear One (ANO) Units 1 and 2 (ANO-1 and ANO-2) Third 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 0CAN081402

Page 1 of 17 ANO-1 and ANO-2 Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BDBEEs 1 Introduction Entergy Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) for ANO-1 and 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 8), 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 January 31, 2014, and are current as of July 31, 2014: Second Six-Month Status Report - February 2014 Modifications Evaluation - January 2014 Third Six-Month Status Report - Complete with submission of this document in August 2014 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 Not Started Update 5 August-2015 Not Started Perform Staffing Analysis September 2014 Started Attachment to 0CAN081402

Page 2 of 17 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 Not Started ANO-2 Implementation Outage October 2015 Not Started On-site FLEX Equipment Purchase June 2014 Started October 2014 Procure November 2014Not Started August 2015 Off-site FLEX Equipment Develop Strategies with Regional Response Center November 2013Started November 2014 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 Completed Issued May 2013 Create ANO FLEX Strategy Guide November 2014Started Create Maintenance Procedures November 2014Not Started Training Develop Training Plan June 2014 Started December 2014 Implement Training November 2014Started August 2015 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 Attachment to 0CAN081402

Page 3 of 17 Milestone Target Completion Date* Activity Status Revised Target Completion Date 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 Note: *Target Completion Date is the last submitted date from either the OIP or previous six month status reports. 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at ANO, changes have been identified to the compliance strategies as described in the original OIP. The use of a portable FLEX reactor coolant system (RCS) makeup pump during Phase 2 for ANO-2 has been changed. The current strategy is to use an ANO-2 charging pump as the injection source to meet the FLEX RCS inventory control

requirements for ANO-2 after the ANO-1 RCS cooldown is complete (Interim Safety

Evaluation (ISE) Open Item 3.2.1.D and Audit Questions (AQ) ANO-035, ANO-046, ANO-106 and ANO-107). The NRC staff concluded "-.that the licensee provided

sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will meet t he requirements of Order EA 12-049 at ANO-1 and ANO-2." (Reference 7). ANO-2 cooldown and depressurization strategy would be implemented within two hours of the ELAP event in accordance with WCAP-17601-P and as assumed in the

specific ANO-2 site analysis (ISE Confirmatory Item 3.2.1.B, and AQ ANO-014, ANO-015, ANO-018, ANO-021, ANO-025, ANO-035, ANO-049, ANO-051, ANO-075, ANO-077, ANO-078, and ANO-085) (Reference 9). Entergy is submitting the following alternative to NEI 12-06 which is necessary to support the ANO-1 and ANO-2 strategies. The final analysis is expected by the end of the year 2015. The ANO-1 and ANO-2 strategy for FLEX requires use of ANO-1's

Borated Water Storage Tank (BWST) and/or ANO-2's Refueling Water Tank (RWT).

These tanks are not required for safe shutdown and so were not previously

evaluated for tornado winds and tornado missiles in the current licensing basis. An

evaluation was performed to determine if the tanks are "robust" (per the definition in Appendix A of NEI 12-06) for tornado and tornado missiles for use in the ANO FLEX

strategy. NEI 12-06 defines robust as: "

Robust (designs): the design of an SSC either meets the current plant design basis for the applicable external hazards or has been shown by analysis or test to meet or exceed the current design basis."

When evaluated against current tornado wind and missile design basis for the site, the

ANO-1's BWST and ANO-2's RWT tanks do not meet the NEI definition of "robust".

Attachment to 0CAN081402

Page 4 of 17 For the current licensing basis, ANO-1's BWST and ANO-2's RWT are the normal sources for large inventory additions to their respective RCS or spent fuel pool.

They are located between the two units and they are partially protected by the reactor and turbine buildings. Each of the tanks has sufficient capacity to support the FLEX strategy for both units.

The tornado resistant design of the ANO units was completed prior to the issuance of Regulatory Guide (RG) 1.76, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, (ANO-1 Safety Analysis Report (SAR) Section 5.1.5 and ANO-2 SAR Section 3.3.2.1). The current design assumptions used for both units

are conservative relative to the criteria of RG 1.76 Revision 1. When applying the

conservative criteria of the current design basis of the site to ANO-1's BWST and

ANO-2's RWT, the tanks do not meet the NEI definition of "robust".

As an alternative to the NEI 12-06 definition of robust, i.e., the use of current plant design basis, Entergy is requesting approval of the use of RG 1.76 Revision 1 as the

criteria for robust with respect to tornado winds and missiles for the use of ANO-1's BWST and ANO-2's RWT for support of ANO FLEX strategies.

The preliminary evaluation indicates that, relative to RG 1.76 Revision 1, both tanks may be considered robust for tornados and tornado missiles and the ANO-1 and ANO-2 FLEX strategies may consider the tanks provide a robust source of borated

water. Prior to crediting the tanks for compliance with EA-12-049, Entergy plans to

complete a detailed evaluation to confirm and document the "robust" status of

ANO-1's BWST and ANO-2's RWT relative to tornado and tornado missiles

consistent with RG 1.76 Revision 1.

This evaluation is being used only for meeting NRC Order EA-12-049 and does not alter the current design bases of ANO-1's BWST and ANO-2's RWT. Nor does the

use of RG 1.76 Revision 1 for this evaluation indicate any intent by ANO to alter the

sites current design or licensing basis. The ANO-1 and ANO-2 strategy for FLEX requires use of the "Q" condensate storage tank (QCST). Using the same approach as the one described above for the

ANO-1 BWST and ANO-2 RWT, Entergy is currently pursuing applying RG 1.76

Revision 1 to the QCST to qualify additional water supply through a finite element

analysis. In a similar way as described above, this represents an alternative to

NEI 12-06 definition of robust. 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Entergy expects to comply with the order implementation date for ANO-2; however, as part of a separate submittal (Reference 5) Entergy requested an extension for ANO-1 for

no later than startup of ANO-2 from refueling outage 2R24 currently scheduled for

October 2015. The request was submitted to support the RCS inventory control strategy

associated with the alternate power connection for the charging pump. This request for

relief/relaxation for ANO-1 was approved by the NRC via Reference 6.

Attachment to 0CAN081402

Page 5 of 17 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 item s documented in the ISE (Reference 10).

Also provided is 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

updated AQ

ANO-035, ANO-046, ANO-106, and

ANO-107 responses

spreadsheet on the

ePortal. 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

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

updated Audit

Question (AQ)

response spreadsheet on the

ePortal. 3.1.1.4.A Confirm that the local staging area for the Regional Response Center (RRC) equipment has been

identified and a description of the methods to be

used to deliver the equipment to the site has been

provided.

In progress. This item to be

addressed on

updated AQ

response spreadsheet on the

ePortal when the

information is

available.

Attachment to 0CAN081402

Page 6 of 17 ISE Confirmatory Items Status 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

updated AQ

ANO-002 response

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

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 ELAP.

This item is addressed by

updated AQ-014, 015, 018, 021, 025,035, 049, 051, 075, 077, 078, and

085 responses

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

updated AQ 109

response spreadsheet on the

ePortal. 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.

In progress.

This item to be addressed by

update to AQ

ANO-015 response

spreadsheet on the

ePortal when the

information is

available. 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

updated AQ-015

response 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 NRC Confirmatory Action Attachment to 0CAN081402

Page 7 of 17 ISE Confirmatory Items Status the seal design temperatures, and supports the leakage rate (two gallons per minute (gpm)/seal)

used in the ELAP analysis. 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.

NRC Confirmatory Action 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 for ANO-

2 by updated AQ

ANO-019 response

spreadsheet on the

ePortal. For ANO In progress. This item

to be addressed by

update to AQ

ANO-019 response

spreadsheet on the

ePortal when the

information is

available. 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

NEI 12-06, Section 3.2.

This item is addressed by

updated AQ

ANO-075 response

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

updated AQ

ANO-078 response

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

updated AQ

ANO-051 and

ANO-077 responses

spreadsheet on the

ePortal. 3.2.1.9.B Confirm the final specific times for connection and use of the portable RRC pumps.

In progress. This item to be

addressed by

update to AQ Attachment to 0CAN081402

Page 8 of 17 ISE Confirmatory Items Status ANO-035 response spreadsheet on the

ePortal when the

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

spreadsheet on the

ePortal. 3.2.4.2.A Confirm acceptable results of the ANO-2, Main Control Room heat-up calculation after it is

performed.

This item is addressed by

updated AQ

ANO-061 response

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

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

spreadsheet on the

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

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

This item is addressed by

updated AQ

ANO-044 response

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

updated AQ

ANO-128 response

spreadsheet on the

ePortal. 3.2.4.10.B For ANO-2, confirm that an acceptable dc load This item is Attachment to 0CAN081402

Page 9 of 17 ISE Confirmatory Items Status profile is developed. addressed by updated AQ

ANO-070 response

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

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

updated 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

updated AQ

response spreadsheet on the

ePortal.

Audit Questions Status Completion or Target Date ANO-001 Closed*

ANO-002 Updated response available on the ePortal (ISE Confirmatory Item 3.1.3.1.A)

ANO-003 Closed* ANO-004 Closed* ANO-006 Closed* ANO-010 Closed* ANO-011 Updated response available on the ePortal ANO-012 Closed* ANO-013 Closed*

ANO-014 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-015 Updated response available on the ePortal (ISE

Attachment to 0CAN081402

Page 10 of 17 Audit Questions Status Completion or Target Date Confirmatory Item 3.2.1.B)

In progress - This AQ response spreadsheet on the ePortal to be updated when information is available (ISE Confirmatory Item 3.2.1.1.A)

February 2015 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.1.B)

ANO-018 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-019 ANO In progress - This AQ response spreadsheet on the ePortal to be updated when

information is available (ISE Confirmatory Item

3.2.1.3.A)

February 2015 Updated response for ANO-2 available on the ePortal (ISE Confirmatory Item 3.2.1.3.A)

ANO-020 Closed*

ANO-021 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-022 Closed* ANO-023 Closed* ANO-024 Closed*

ANO-025 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-026 Closed* ANO-027 Closed* ANO-028 Closed* ANO-029 Closed* ANO-030 Closed*

ANO-032 Updated response available on the ePortal (ISE Confirmatory Item 3.2.3.A)

ANO-034 Closed*

ANO-035 Updated response available on the ePortal (ISE Open Item 3.2.1.D)

Updated response available on the ePortal(ISE Confirmatory Item 3.2.1.B)

In progress - This AQ response spreadsheet on the ePortal to be updated when information is available February 2015 Attachment to 0CAN081402

Page 11 of 17 Audit Questions Status Completion or Target Date (ISE Confirmatory Item 3.2.1.9.B)

ANO-041 ANO In progress - This AQ response spreadsheet on the ePortal to be updated when

information is available (ISE Open Item 3.2.1.8.B)

February 2015 ANO Updated response available on the ePortal (ISE Open Item 3.2.1.8.B)

ANO-044 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.7.A)

ANO-045 Updated response available on the ePortal ANO-046 Updated response available on the ePortal (ISE Open Item 3.2.1.D)

ANO-047 Updated response available on the ePortal ANO-049 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

ANO-051 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

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

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

ANO-062 Updated response available on the ePortal ANO-063 Updated response available on the ePortal ANO-064 Closed* ANO-066 Closed* ANO-067 Updated response available on the ePortal ANO-068 Closed* ANO-069 Updated response available on the ePortal ANO-070 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.10.B)

ANO-071 Updated response available on the ePortal Attachment to 0CAN081402

Page 12 of 17 Audit Questions Status Completion or Target Date ANO-072 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.10.C)

ANO-075 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.4.A)

ANO-076 Closed ANO-077 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.9.A)

ANO-078 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.B)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.8.A)

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

ANO-086 Closed* ANO-088 Closed* ANO-089 Updated response available on the ePortal ANO-090 Updated response available on the ePortal ANO-091 Closed* ANO-092 Closed* ANO-094 Updated response available on the ePortal ANO-098 Updated response available on the ePortal ANO-100 Updated response available on the ePortal ANO-104 Closed*

ANO-106 Updated response available on the ePortal (ISE Open Item 3.2.1.D)

ANO-107 Updated response available on the ePortal (ISE Open Item 3.2.1.D)

Attachment to 0CAN081402

Page 13 of 17 Audit Questions Status Completion or Target Date ANO-108 Closed*

ANO-109 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.A)

Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.C)

ANO-110 Updated response available on the ePortal ANO-112 Closed* ANO-113 Updated response available on the ePortal ANO-115 In progress - This AQ response on the ePortal to be updated when information is available February 2015 ANO-116 Closed* ANO-117 Updated response available on the ePortal ANO-118 Closed* ANO-120 Closed* ANO-123 Updated response available on the ePortal ANO-125 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.2.B)

ANO-126 Updated response available on the ePortal ANO-127 Updated response available on the ePortal ANO-128 Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.10.A)

ANO-129 Updated 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 Updated response available on the ePortal ANO-2 Updated response available on the ePortal ANO-3 Closed* ANO-4 Updated response available on the ePortal ANO-5 Closed* ANO-6 Updated response available on the ePortal ANO-7 Updated response available on the ePortal ANO-8 Updated response available on the ePortal ANO-9 Updated response available on the ePortal Attachment to 0CAN081402

Page 14 of 17 Audit Questions Status Completion or Target Date ANO-10 Closed* ANO-11 Updated response available on the ePortal ANO-12 Closed* ANO-13 Closed* ANO-14 Updated response available on the ePortal ANO-15 Updated response available on the ePortal ANO-16 Updated response available on the ePortal

  • Closed indicates that Entergy's response is complete. 7 Potential ISE Impacts The following items have been identified which have potential impact to the Interim Staff Evaluation (ISE) except for those identified in Section 6. 1. ISE/TER (Technical Evaluation Report) Section 3.1.2.2, Page 15, the TER states "ANO-2 FLEX RCS makeup pump requires primary and secondary connections

to the HPSI/charging piping and the refueling water tank (RWT) or borated water

storage tank (BWST)." The current strategy utilizes an ANO-2 charging pump as

the RCS injection source for both units. This strategy eliminates the need for

onsite portable RCS makeup pumps, and any connections to the HPSI/charging

piping. 2. ISE/TER Section 3.2.1, Page 29, the TER states, "-the Boric Acid Makeup Tanks (BAMTs), RWT, BWST or the new borated water tank will provide this

function." Currently, besides the option to install a new borated water tank, Entergy is also 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 3.2.1, Page 31, the TER states, "-and ANO-2 indicate cooldown is currently scheduled to begin at approximately eight hours from event initiation. The ANO-2 cooldown requires confirmation of existing analysis or

additional analysis during the ANO-2 detailed design to support the delay in the

cooldown to eight hours following the ELAP." The current strategy is to begin

cooldown at two hours following a reactor trip resulting from a BDBEE consistent

with the Westinghouse site-specific analysis. 4. ISE/TER Section 3.2.1, Page 31, item c, the TER states, "This analysis requires confirmation or additional analysis during the ANO-2 detailed design to support

the delay in the ANO-2 cooldown to two hours following an ELAP." The current

strategy is to begin cooldown at two hours following a reactor trip resulting from a

BDBEE consistent with the Westinghouse site-specific analysis.

Attachment to 0CAN081402

Page 15 of 17

5. ISE/TER Section 3.2.1, Page 31, item d, the TER states, "For ANO-2 the suction source will be either the ANO-1 BWST or ANO-2 RWT." The current strategy is

to use an ANO-2 charging pump. The suction source is provided from the ANO-

2 boric acid makeup tank (BAMT) and then the ANO-2 RWT. 6. ISE/TER Section 3.2.1, Page 35, the TER states, "1 RCS makeup pump (Unless it is decided to use charging pump for ANO-2 RCS makeup)." The current

strategy is to use an ANO-2 charging pump; therefore, the RCS makeup pump is

eliminated. 7. ISE/TER Section 3.2.1.1, Page 39, the TER states, "The current ANO-2 cooldown strategy, as detailed in the 6-month update, delays the ANO-2

cooldown until eight hours following an ELAP." The current strategy is to begin

cooldown at two hours following a reactor trip resulting from a BDBEE consistent

with the Westinghouse site-specific analysis. 8. ISE/TER Section 3.2.1.1, Page 40, the TER states, "Recommendation 2 - The ANO-2 strategy incorporates cooldown starting at eight hours-" The current

strategy is to begin cooldown at two hours following a reactor trip resulting from a

BDBEE consistent with the Westinghouse site-specific analysis. 9. ISE/TER Section 3.2.1.1, Page 40, the TER states, "Recommendation 6 - -to support the delay in the ANO-2 cooldown to eight hours following an ELAP." The

current strategy is to begin cooldown at two hours following a reactor trip

resulting from a BDBEE consistent with the Westinghouse site-specific analysis. 10. ISE/TER Section 3.2.1.8, Page 48, the TER states, "The analysis requires confirmation or additional analysis during the ANO-2 detailed design to support

the delay in the cooldown to eight hours following the ELAP." The current

strategy is to begin cooldown at two hours following a reactor trip resulting from a

BDBEE consistent with the Westinghouse site-specific analysis. 11. ISE/TER Section 3.2.1.8, Page 51, the TER states, "CN-SEE-II-13-2, Revision 1, requires confirmation or additional analysis during the ANO-2 detailed design to

support the delay in the ANO-2 cooldown to eight hours following an ELAP." The

current strategy is to begin cooldown at two hours following a reactor trip

resulting from a BDBEE consistent with the Westinghouse site-specific analysis (CN-SEE-II-13-2, Revision 1). 12. ISE/TER Section 3.2.1.8, Page 52, the TER states, "-the analysis performed in CN-SEE-II-13-2, Revision 1, requires confirmation or additional analysis during

the ANO-2 detailed design to support the delay in the ANO-2 cooldown to eight

hours following an ELAP." The current strategy is to begin cooldown at two

hours following a reactor trip resulting from a BDBEE consistent with the

Westinghouse site-specific analysis (CN-SEE-II-13-2, Revision 1). 13. ISE/TER Section 3.2.1.8, Page 52, the TER states, "An alternate strategy is under consideration to use the charging pump to make up to the ANO-2 RCS

after ANO-1 cooldown is complete." The use of the charging pumps to make up

to the ANO-2 RCS has become the primary strategy.

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Page 16 of 17

14. ISE/TER Section 3.2.4.7, Page 65, the TER states, "For ANO-2,-RCS inventory will be added as needed by utilizing a portable FLEX RCS makeup pump." The

current strategy utilizes the ANO-2 charging pumps as the means for RCS

inventory control for both ANO-1 and ANO-2. 15. ISE/TER Section 3.2.4.7, Page 66, the TER states, "For high wind BDBEEs, a new borated water storage tank, which-" Currently, besides the option to install

a new borated water tank, Entergy is also pursuing applying RG 1.76 Revision 1, Design Basis Tornado and Tornado Missiles for Nuclear Power Plants, to the

borated water storage tanks available at the site to qualify additional borated

water through a finite element analysis. 16. 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." To qualify additional

QCST inventory beyond the 30 minutes to allow enough time for aligning this

new permanently installed crosstie between the fire water and the service water, 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. 17. 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, besides the option to install a new borated water tank, Entergy is also pursuing

applying RG 1.76 Revision 1, Design Basis Tornado and Tornado Missiles for

Nuclear Power Plants, to the borated water storage tanks available at the site to

qualify additional borated water through a finite element analysis. 18. ISE/TER Section 3.2.4.7, Pages 68 and 69, the TER states, ".An alternate strategy is under consideration to use the charging pumps to make up to the

ANO-2 RCS after the AN0-1 cooldown is complete." The current strategy utilizes

the ANO-2 charging pumps as the means for RCS inventory control for both

ANO-1 and ANO-2.

8 References The following references support the updates to the OIP described in this enclosure.

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. Entergy letter to NRC, First 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

Attachment to 0CAN081402

Page 17 of 17 (Order Number EA-12-049), dated August 28, 2013 (0CAN081302) (ML13241A414) 4. Entergy letter to NRC, Emergency Preparedness Commitment Changes Related to the March 12, 2012, Information Request, dated October 25, 2013 (0CAN101303) 5. Entergy letter to NRC, 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) (NRC Order EA-12-049) Arkansas Nuclear One - Unit 1 , dated April 8, 2014 (1CAN041401) (ML14098A114)

6. NRC letter, 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) 7. NRC letter, Arkansas Nuclear One, Units 1 and 2 - Update Regarding Audit Activities Associated with Order EA-12-049 (Mitigation Strategies), dated May 28, 2014 (ML14140A514) 8. Entergy letter to NRC, Second 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 (Order Number EA-12-049), dated February 27, 2014 (0CAN021405) (ML14059A229) 9. Westinghouse calculation CN-SEE-II-13-2, Revision 1, Arkansas Nuclear One Unit 2 Reactor Coolant System Inventory, Shutdown Margin, and Modes 5 and 6 Boric Acid Precipitation Control Analyses to Support the Diverse and Flexible

Coping Strategies (FLEX), dated February 19, 2013. 10. NRC letter, Arkansas Nuclear One, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0942 and MF0943), dated February 25, 2014

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