0CAN121101, Request for Additional Information for the 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies

Request for Additional Information for the 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies

ML113490433
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/14/2011
From:	Schwarz C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN121101, BL-11-001
Download: ML113490433 (6)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President, Operations Arkansas Nuclear One 0CAN121101 December 14, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Request for Additional Information for the 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

References:

1. NRC letter to Entergy, Request for Additional Information Regarding 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies, dated November 18, 2011 (0CNA111102)

2. Entergy letter to NRC, 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies, dated July 8, 2011 (0CAN071101)

Dear Sir or Madam:

By letter in Reference 1, the NRC issued a request for additional information (RAI) for the 60-day response to NRC Bulletin 2011-01 (Reference 2). The attachment to this submittal provides the RAI responses requested within 30 days.

There are no new commitments contained in this submittal. If you need any additional information, please contact Stephenie Pyle at 479.858.4704.

0CAN121101 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on December 14, 2011.

Sincerely, Original signed by Dale James for C. J. Schwarz CJS/nbm

Attachment:

RAI for the 60-Day Response to NRC Bulletin 2011-01 cc: Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 0CAN121101 Request for Additional Information for the 60-Day Response to NRC Bulletin 2011-01

Attachment to 0CAN121101 Page 1 of 3 Request for Additional Information for the 60-Day Response to NRC Bulletin 2011-01

1. Please describe in detail the maintenance or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

The bulletin requested that each licensee describe in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies, these devices are commonly used for firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product releases.

Response: Maintenance and testing is not currently performed on the monitor nozzles; however, an action to develop a preventative maintenance task has been initiated to include inspection and performance testing of the monitor nozzle in conjunction with the annual testing of the B.5.b portable pump.

2 Please describe in detail how you ensure that a vehicle is available to move the B.5.b portable pump and other B.5.b equipment to the appropriate place when needed.

The bulletin requested that each licensee describe in detail the controls for ensuring equipment needed to execute the mitigating strategies will be available when needed.

A vehicle is typically needed to implement the strategies since the portable pump and other equipment is stored away from target areas.

Response: An onsite procedure contains the instructions for ensuring available tow vehicles for the B.5.b portable pump and trailer. The procedure provides guidance for obtaining any one of nine onsite vehicles equipped with a two-inch receiver hitch. The preferred vehicles are located outside of the protected area with alternate vehicles located inside the protected area.

3. Please identify the minimum inventory frequency for equipment needed for the mitigating strategies not specifically identified in response to the bulletin.

Alternatively, please describe the inventory frequency for firefighter turnout gear, tools, and instruments needed to support the mitigating strategies.

The bulletin requested that each licensee describe in detail the controls for ensuring equipment supporting the mitigating strategies will be available when needed. The equipment listed above is generally needed to implement the mitigating strategies, but not all of these items were clearly included in the licensees response dated July 8, 2011, to the bulletin.

Response: The minimum inventory frequency for equipment, tools, and instruments needed for the mitigating strategies was specifically identified in response to the third item of the 60-day response to the bulletin (Reference 2 in cover letter). In addition, the firefighter turnout gear located inside the protected area is inventoried quarterly while the firefighter turnout gear located outside the damage footprint is inventoried annually.

Attachment to 0CAN121101 Page 2 of 3

4. Please describe in detail the fire brigade training as it relates to all phases of the mitigating strategies.

The bulletin requested that each licensee describe in detail how configuration and guidance management, including training, is assured so that the strategies remain feasible. The safety evaluation documenting the NRC review of the licensees response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026) states that the expectation for fire brigade training (Phase 1, B.1.l) includes accelerant-fed fires and coordinated fire response. The licensees response to the bulletin implies that fire brigade training is limited to pump operations.

Response: The following information was provided in the table in the response to the fourth item of the 60-day response to the bulletin (Reference 2 in cover letter).

Station Personnel Training Periodicity Evaluation Operations Initial training and continuing 3 years Classroom and in-plant training on the pump operation training (non-licensed operators) and procedure/mitigating strategies (licensed operators)

Fire Brigade Initial training and continuing 3 years Computer-based training on pump operation both training classroom and hands-on acknowledgement (operation and evaluation of B.5.b pump staging and operation included biennially in fire brigade training)

The above table listed procedure/mitigating strategies training for licensed operators. As a clarification, non-licensed operators also receive this training.

The fire brigade for each Arkansas Nuclear One unit is comprised of five response members who are predominantly operations personnel (four operators and one security member).

Fire brigade training on flammable liquids and gases (Class B fires) addresses:

Characteristics of Class B fires Creation and use of firefighting foams for controlling Class B fires How fire fighting foam is created and properly applied Construction, parts, and function of the foam system Proper application techniques for using foam to fight a Class B fire In addition to the above, the fire brigade leader training addresses the fire fighting complications and strategies created by accelerants from aircraft crashes on site. The fire brigade leader training also addresses contacting the London Fire Department, establishing a unified command when the fire department arrives, and teaming the offsite firefighting personnel with fire brigade personnel.

Operations training on the mitigating strategies included in an onsite procedure addresses applicable concerns, causes, transient response, and transient mitigation methods.

Attachment to 0CAN121101 Page 3 of 3 Specifically, the training addresses operator actions required to implement the B.5.b mitigating strategies. The procedure also provides the following concerning incident command and control. Command and control of an incident at ANO requiring support from non-ANO resources operate under the National Incident Management System (NIMS) process. In events where large scale damage has occurred at the site, the NIMS process is adhered to. Command and control of firefighting efforts is retained by the onsite Fire Brigade Leader at the scene. The Fire Brigade Leader, in control of firefighting efforts onsite, is incorporated into the NIMS process as offsite response agencies respond to the site. In addition, the onsite Fire Brigade Leader interfaces with the London Fire Department who provides organizational coordination with the other responding mutual aid resources.