Text

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 (Order Number EA-12-049)
	ML13241A414
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-12-049, OCAN081302
	Download: ML13241A414 (58)
	v • d • e

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President, Operations Arkansas Nuclear One 0CAN081302 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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (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 Beyond-Design-Basis External Events, dated March 12, 2012 (0CNA031206) (ML12056A045)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12221A205)

4. Entergy letter to NRC, Initial 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 October 26, 2012 (0CAN101203)

(ML12305A372)

5. 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 Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (0CAN021302)

(ML13063A151)

0CAN081302 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 develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. 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 12-06, Revision 0 (Reference 3). Reference 4 provided the initial status report regarding mitigation strategies, 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 Enclosure 1 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. In addition, provides a revised OIP that was previously submitted by Reference 5.

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

Enclosures:

1. Arkansas Nuclear One (ANO) Units 1 and 2 First 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

2. Revised ANO FLEX OIP

0CAN081302 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

Enclosure 1 to 0CAN081302 Arkansas Nuclear One (ANO) Units 1 and 2 (ANO-1 and ANO-2) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events to 0CAN081302 Page 1 of 4 ANO-1 and ANO-2 First 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 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. This enclosure 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 None 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.

ANO-1 Implementation Outage The target completion date for the ANO-1 implementation outage was revised to February 2015. This change does not impact the completion of implementation by the date required by the Order.

Validation Walk-throughs or Demonstration(s):

Target completion dates have been added to the milestone schedule for completion of the validation walk-throughs for ANO-1 and ANO-2. These new milestone target dates do not impact the Order implementation date.

Revised Target Activity Target Milestone Completion Status Completion Date Date Submit OIP February 2013 Complete Update 1 August 2013 Complete Update 2 February 2014 Update 3 August 2014 Update 4 February 2015 Update 5 August-2015 Perform Staffing Analysis December 2013 Not Started Modifications to 0CAN081302 Page 2 of 4 Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications Evaluation June 2013 Started June 2013 -

Engineering and Implementation Not Started October 2015 February 2015 ANO-1 Implementation Outage November 2014 Not Started (See Note)

ANO-2 Implementation Outage October 2015 Not Started On-site FLEX Equipment Purchase June 2014 Not Started Procure November 2014 Not Started Off-site FLEX Equipment Develop Strategies with Regional November 2013 Not Started Response Center Install Off-site Delivery Station (if October 2014 Not Started necessary)

Procedures Pressurized Water Reactor Owners Group issues Nuclear Issued June 2013 System Steam Supply May 2013 (NSSS)-specific guidelines Create ANO FLEX Strategy Guide November 2014 Not Started Create Maintenance Procedures November 2014 Not Started Training Develop Training Plan June 2014 Not Started Implement Training November 2014 Not Started Validation ANO-1 walk-throughs or demonstration(s) - including all November 2014 Not Started FLEX equipment points of connect/tie-in for Phase 2 and 3 ANO-2 walk-throughs or demonstration(s) - including all October 2015 Not Started FLEX equipment points of connect/tie-in for Phase 2 and 3 Submit Completion Report February 2016 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.

to 0CAN081302 Page 3 of 4 Changes to Compliance Method In preparation for the design phase of the FLEX project at ANO, changes have been identified to the compliance strategies as described in the original OIP. A revised OIP is provided in Enclosure 2. The significant changes include:

Additional missile shielding is not being added to the qualified condensate storage tank. Instead the turbine-driven emergency feedwater (EFW) pump supply is planned to be supplied from the emergency cooling pond (ECP) water utilizing a diesel-driven fire pump to address Phase 1 for a wind/missile event.

The ANO-1 borated water storage tank and ANO-2 refueling water tank are not being missile protected. Instead a new borated water tank is planned to be installed at a location that will provide sufficient separation for missile protection; however, several other alternatives are still being evaluated.

ANO-1 RCS inventory control is planned to be provided by re-energizing an ANO-2 charging pump from the portable diesel generator and cross-connection of the charging pump to ANO-1 high pressure injection.

The turbine-driven EFW pump supply for Phase 2 and Phase 3 is planned to be provided by the ECP.

The coping strategy identified in Enclosure 2 remains consistent with the guidance provided in WCAP-17601-P, RCS Response to the Extended Loss of Alternating Current (AC) Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs (Reference 3), and satisfies the requirements of NEI 12-06, FLEX Implementation Guide (Reference 4).

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

Open Items from Overall Integrated Plan and Draft Safety Evaluation None Potential Draft Safety Evaluation Impacts The NRC has not yet issued draft safety evaluations for ANO-1 and ANO-2; therefore, there are no potential impacts to the draft safety evaluation identified at this time.

to 0CAN081302 Page 4 of 4 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (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 Beyond-Design-Basis External Events, dated March 12, 2012 (0CNA031206) (ML12056A045)

3. WCAP-17601-P, RCS Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs, Revision 0, August 2012

4. NEI 12-06, FLEX Implementation Guide, Revision B1, May 2012 (ML12144A419)

Enclosure 2 to 0CAN081302 Revised Arkansas Nuclear One (ANO) Diverse and Flexible Coping Strategies (FLEX) Overall Integrated Implementation Plan (OIP)

Enclosure to 0CAN081302 Page 1 of 49 Revised ANO FLEX OIP Revisions are denoted in BOLD text.

General Integrated Plan Elements Determine Applicable In accordance with Reference 1, the Arkansas Nuclear One Extreme External Hazard (ANO) site has been evaluated, and the following applicable hazards have been identified:

Ref: Nuclear Energy Institute (NEI) 12-06 Section 4.0 -9.0

Seismic events JLD-ISG-2012-01 Section 1.0

External flooding

Severe storms with high winds

Snow, ice, and extreme cold

Extreme heat Entergy Operations, Inc. (Entergy) has reviewed the NEI Diverse and Flexible Coping Mitigation Strategies (FLEX) guidance and determined the hazards that FLEX equipment should be protected from include seismic; flooding; severe storms with high winds; snow, ice and extreme cold; and extreme high temperatures. Entergy has determined the functional threats from each of these hazards and identified FLEX equipment that may be affected. The FLEX storage locations will provide the protection required from these hazards. Entergy is also developing procedures and processes to further address plant strategies for responding to these various hazards.

Seismic:

Per Safety Analysis Report (SAR) seismic input (Reference 4), the seismic criteria for ANO includes two design basis earthquake spectra: operating basis earthquake (OBE) and design basis earthquake (DBE).

The site-specific design response spectra define the vibratory ground motion of the OBE and DBE. The maximum horizontal acceleration for the DBE is 0.20g and the OBE has a maximum horizontal acceleration of 0.10g.

The seismic hazard applies to ANO. As a result, the credited FLEX equipment will be assessed based on the current ANO seismic licensing basis to ensure that the equipment remains accessible and available after a beyond-design-basis external event (BDBEE) and that the FLEX equipment does not become a target or source of a seismic interaction from other systems, structures, or components. The FLEX strategies developed for ANO will

Enclosure to 0CAN081302 Page 2 of 49 include documentation ensuring that any storage locations and deployment routes meet the FLEX seismic criteria.

External Flooding:

The types of events evaluated to determine the worst potential flood included (1) probable maximum flood (PMF) due to flood flow at Dardanelle Dam yielding a water level at 358 feet (ft) mean sea level (MSL), (2) catastrophic failure of the closest dam upstream of Dardanelle Dam yielding a water level of 361 ft MSL, and (3) the effect of wind induced waves.

The maximum plant site flood level from any cause is Elevation 361 ft MSL. A flood of the magnitude of the maximum probable flood will be forecast about five days prior to its arrival at the plant site. The plant will be shut down by the time the flood level reaches 354 ft, which is the elevation where flooding of the turbine building would commence. The plant will be shut down using normal shutdown procedures and, during the flood, the operators will maintain the plant in a safe shutdown condition.

In summary, the ANO site is not considered a dry site and the flooding hazard is screened in.

High Wind:

Figures 7-1 and 7-2 from NEI 12-06 (Reference 2) were used for this assessment.

The ANO site is located at 35° - 18 N (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively); therefore, ANO is not susceptible to hurricanes based on its location in Arkansas. The plant site is north of the final contour line shown in Figure 7-1 of NEI 12-06 (Reference 2).

It was determined that the ANO site has the potential to experience damaging winds caused by a tornado exceeding 130 mph. Figure 7-2 of NEI 12-06 (Reference 2) indicates a maximum wind speed of 200 miles per hour (mph) for Region 1 plants, including ANO, which is located at 35°-18' N, 93°-13' W (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively). Therefore, high-wind hazards are applicable to the ANO site.

In summary, (1) based on Figure 7-1 of NEI 12-06 (Reference 2), ANO is not susceptible to hurricanes so the hazard is screened out and (2) based on local data and Figure 7-2 of NEI 12-06 (Reference 2), ANO has the

Enclosure to 0CAN081302 Page 3 of 49 potential to experience damaging winds so the hazard is screened in.

Snow, Ice, and Extreme Cold:

Per the FLEX guidance, all sites should consider the temperature ranges and weather conditions for their site in storing and deploying their FLEX equipment. That is, the equipment procured should be suitable for use in the anticipated range of conditions for the site, consistent with normal design practices.

Applicability of snow and extreme cold:

NEI 12-06 (Reference 2) states that plants above the 35th parallel should provide the capability to address the impedances caused by extreme snow and cold. The ANO site is located marginally above the 35th parallel at 35°-18' N (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively); therefore, the FLEX strategies must consider the impedances caused by extreme snowfall with snow removal equipment, as well as the challenges that extreme cold temperature may present.

Applicability of ice storms:

The ANO site, located at 35°-18' N, 93°-13' W (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively), is not a Level 1 or 2 region as defined by Figure 8-2 of NEI 12-06 (Reference 2); therefore, the FLEX strategies must consider the hindrances caused by ice storms.

In summary, based on the available local data and Figures 8-1 and 8-2 of NEI 12-06 (Reference 2), the hazards of snow, ice, and extreme cold temperatures are screened in for the ANO site.

Extreme Heat:

Per NEI 12-06 (Reference 2), all sites must address high temperatures. Virtually every state in the lower 48 contiguous United States has experienced temperatures in excess of 110F. Many states have experienced temperatures in excess of 120F. All sites will consider the impacts of these conditions on the FLEX equipment and its deployment.

The event considered herein is a loss of all alternating current (AC) power as a result of short extreme high

Enclosure to 0CAN081302 Page 4 of 49 temperatures coincident with high electrical grid demands, resulting in regional blackout. During this type of event, with the equipment and water inventories in the units operating within the technical specification (TS) limits, no additional limitations on initial conditions/failures/abnormalities are expected.

In summary, per NEI 12-06, all sites will address high temperatures. Therefore, the extreme heat hazard is screened in for ANO.

Key Site assumptions to Assumptions are consistent with those detailed in implement NEI 12-06 NEI 12-06 (Reference 2, Section 3.2.1) and the Executive strategies. Summary of the Pressurized Water Reactor Owners Group (PWROG) Core Cooling Position Paper (OG-12-482).

Ref: NEI 12-06 Section 3.2.1 ANO Site-Specific Assumptions:

The following assumptions are specific to the ANO site:

A1. Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March 12, 2012 (Reference 1), are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action system and addressed on a schedule commensurate with other licensing bases changes.

A2. Exceptions for the site security plan or other (license/site-specific) requirements will be addressed in the Flex Support Guidelines (FSGs).

A3. Deployment resources are assumed to begin arriving at hour 6 after the event and the site is assumed to be fully staffed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A4. Hardened connections are assumed to be protected and diverse with respect to the applicable hazards.

A5. A flood of the magnitude of the PMF will be forecast about five days prior to the floods arrival at the plant site. It is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are available for the deployment of FLEX equipment for the preparation for a flooding scenario, and that power is available during this time.

A6. Entergy will declare an extended loss of AC power (ELAP) within sufficient time to take actions to stage equipment and initiate coping strategies.

Enclosure to 0CAN081302 Page 5 of 49 A7. No events or single failures of systems, structures, and components in addition to those presented in NEI 12-06 (Reference 2), are assumed to occur immediately prior to or during the event, including security events.

A8. This plan defines strategies capable of mitigating a simultaneous loss of all AC power and loss of normal access to the ultimate heat sink (UHS) resulting from a BDBEE by providing adequate capability to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the unit guidance.

The plant TSs contain the limiting conditions for normal unit operations to ensure that design safety features are available to respond to a design-basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the BDBEE may place the plant in a condition where it cannot comply with certain TSs and/or with its Security Plan, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p). See Reference 9.

Extent to which the guidance, Entergy expects to comply with the guidance in JLD-ISG-2012-01 and NEI JLD-ISG-2012-01 (Reference 3) and NEI 12-06 12-06, are being followed. (Reference 2) in implementing FLEX strategies for the ANO Identify any deviations to JLD- site. See Attachment 1B.

ISG-2012-01 and NEI 12-06.

Ref: JLD-ISG-2012-01 Ref: NEI 12-06 Section 13.1 Provide a sequence of events The sequence of events and any associated time and identify any time constraints are identified for ANO-1 and ANO-2 for Modes 1 constraint required for through 4. See the attached sequence of events timeline success including the (Attachment 1A) for a summary of this information.

technical basis for the time constraint.

Ref: NEI 12-06 Section 3.2.1.7 JLD-ISG-2012-01 Section 2.1

Enclosure to 0CAN081302 Page 6 of 49 Identify how strategies will be Deployment of FLEX equipment is described for each FLEX deployed in all modes. function in the subsequent sections below and covers all modes.

Ref: NEI 12-06 section 13.1.6 Provide a milestone schedule. See attached milestone schedule in Attachment 2.

This schedule should include:

Modifications timeline o Phase 1 o Phase 2 o Phase 3

Procedure guidance development complete o Strategies o Maintenance

Storage plan (reasonable protection)

Staffing analysis completion

FLEX equipment acquisition timeline

Training completion for the strategies

Regional Response Centers operational Ref: NEI 12-06 Section 13.1 Identify how the programmatic Equipment associated with these strategies will be controls will be met procured as commercial equipment with design, storage, maintenance, testing, and configuration control in Ref: NEI 12-06 Section 11 accordance with NEI 12-06, (Reference 2, Section 11).

JLD-ISG-2012-01 Section 6.0 The unavailability of equipment and applicable connections that directly perform a FLEX mitigation strategy will be managed using plant equipment control guidelines developed in accordance with NEI 12-06, (Reference 2, Section 11.5).

Programs and controls will be established to assure personnel proficiency in the mitigation of

Enclosure to 0CAN081302 Page 7 of 49 beyond-design-basis events is developed and maintained in accordance with NEI 12-06, (Reference 2, Section 11.6).

Existing plant configuration control procedures will be modified to ensure that changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06, (Reference 2, Section 11.8).

Procedure Guidance:

Procedures and guidance to support deployment and FLEX coping strategy implementation, including interfaces with emergency operating procedures (EOPs), special events procedures, abnormal operating procedures (AOPs), and system operating procedures, will be coordinated within the site procedural framework. The procedural documentation will be auditable, consistent with generally accepted engineering principles and practices, and controlled within the Entergy document control system.

Entergy is participating with the PWROG to develop and implement the FSGs at ANO in a timeline to support the implementation of FLEX by Fall of 2014 for ANO-1 and by Fall of 2015 for ANO-2. The PWROG has generated these guidelines in order to assist utilities with the development of site-specific procedures to cope with an ELAP in compliance with the requirements of NEI 12-06 (Reference 2).

Actions that maneuver the plant will remain contained within the typical controlling procedures, and the FSGs will be implemented as necessary to maintain the key safety functions of core cooling, containment, and SFP cooling in parallel with the controlling procedure actions.

Maintenance and Testing:

The FLEX mitigation equipment will be initially tested (or other reasonable means used) to verify performance conforms to the limiting FLEX requirements. It is expected that the testing will include the equipment and the assembled sub-system to meet the planned FLEX performance. Additionally, Entergy plans to use the guidance in the maintenance and testing template upon issuance by the Electric Power Research Institute (EPRI).

The template will be developed to meet the FLEX guidelines established in Section 11.5 of NEI 12-06 (Reference 2).

Enclosure to 0CAN081302 Page 8 of 49 Staffing:

The FLEX strategies documented in the event sequence analysis assume:

On-site staff are at minimum shift staffing levels No independent, concurrent events All personnel on-site are available to support site response Entergy plans to address staffing considerations in accordance with NEI 12-06 (Reference 2) to fully implement FLEX at the site.

Configuration Control:

Per NEI 12-06 (Reference 2) and the Interim Staff Guidance (Reference 3), the FLEX strategies must be maintained to ensure that future plant changes do not adversely impact the FLEX strategies. Therefore, Entergy plans to maintain the FLEX strategies and modify existing plant configuration control procedures to ensure changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies.

Describe training plan Training plans will be developed for plant groups such as the emergency response organization (ERO), fire, security, emergency planning (EP), operations, engineering, mechanical maintenance, and electrical maintenance. The training plan development will be done in accordance with ANO site procedures using the Systematic Approach to Training and will be implemented to ensure that the required Entergy ANO site staff is trained prior to implementation of FLEX. The training program will comply with the requirements outlined in Section 11.6 of NEI 12-06 (Reference 2).

Describe Regional Response The industry is expected to establish two Regional Center plan Response Centers (RRCs) to support utilities during beyond design basis events. Each RRC is expected to hold five sets of equipment; four of which should be able to be fully deployed when requested; the fifth set would have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local assembly area, established by the Strategic Alliance for FLEX Emergency Response

Enclosure to 0CAN081302 Page 9 of 49 (SAFER) team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear sites playbook, is expected to be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request.

Entergy will negotiate and execute a contract with the SAFER for the ANO site which will meet the requirements of NEI 12-06 (Reference 2, Section 12).

Notes: N/A

Enclosure to 0CAN081302 Page 10 of 49 Maintain Core Cooling and Heat Removal Determine Baseline coping capability with installed coping1 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Emergency Feedwater (EFW)

Depressurize Steam Generator (SG) for Makeup with Portable Injection Source

Sustained Source of Water Ref: JLD-ISG-2012-01 Sections 2 and 3 PWR-Installed Equipment Phase 1 During a station blackout (SBO), operator actions are currently governed by the applicable SBO procedures. Heat is removed from the core through the SG using the atmospheric dump valves (ADVs)/main steam safety valves, with the SG being fed by the turbine-driven EFW pumps at both units. Following loss of remote control of the ADV and the turbine-driven EFW pump, local manual action is possible and will be used to continue plant control consistent with procedures.

The Q condensate storage tank (QCST) will supply the initial feedwater inventory for both units. An additional feedwater water supply is required during Phase 1 to assure wind-generated missile protection.

Cooldown for ANO-1 is deferred until the reactor coolant system (RCS) inventory control is assured. ANO-1 and ANO-2 cooldown is deferred until the Phase 2 turbine-driven EFW backup feedwater supply is staged and available.

The turbine-driven EFW pumps will be utilized by both units to provide feedwater flow from an event-qualified source to supply the SGs. The turbine-driven EFW pumps are located in the auxiliary building (AB). The AB is designed to withstand the effects of earthquakes, tornadoes, floods, external missiles, and other appropriate natural phenomena. The Phase 1 water source for seismic and flood events is the QCST. The Phase 1 water source for wind/missile events is initially the QCST supplemented by the emergency cooling pond (ECP) supplied by the diesel-driven fire pump.

Power supplied to the turbine-driven EFW pump, valve operators, and other necessary support systems is independent of AC power sources. The diesel-driven fire pump starts automatically on loss of AC power and will require manual valve operation to align the pumps discharge to the service water header.

The ADVs will be opened in order to remove the steam generated from the SGs and support the natural circulation cooling of the core. For ANO-1, each main steam line, between the reactor building penetration and the corresponding main steam isolation valve (MSIV), is provided with spring-loaded safety valves and air-operated dump valves which discharge to the atmosphere.

This arrangement permits controlled release of steam for RCS cooldown when the MSIVs are 1 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN081302 Page 11 of 49 closed. This will be accomplished by manual operation either from the control room or by using local operation. For ANO-2, each main steam line, between the reactor building penetration and the corresponding MSIV, is provided with spring-loaded safety valves and two sets of steam dump bypass system ADVs and isolation valves. This arrangement permits controlled release of steam for RCS cooling when the MSIVs are closed. This can be accomplished by local operation.

Phase 1 core heat removal during Modes 5 and 6 will be accomplished by maintaining RCS inventory. Refer to the Phase 1 RCS Inventory Control strategy.

Details:

Provide a brief description Existing procedures/strategies/guidelines will be revised to of Procedures / Strategies / consider FSGs.

Guidelines Identify modifications Modification to the diesel-driven fire pump discharge to allow the fire pump to discharge to the turbine-driven EFW suction through the service water piping during a wind/missile event.

Key Reactor Parameters 1. SG Level

2. SG Pressure

3. QCST Level

4. RCS Pressure

5. Core Exit Thermocouples (CETs)

6. RCS Temperature Notes: The key parameters will either be monitored from the control room or taken locally.

Enclosure to 0CAN081302 Page 12 of 49 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 2 The transition into Phase 2 for core heat removal will occur as portable resources are utilized to support the Phase I strategies. The turbine-driven EFW pump will remain available as long as steam is available for powering the pump and a source of supply water is maintained. In preparation of turbine-driven EFW unavailability, the diesel-driven SG FLEX pump will be staged to deliver feedwater to both SGs if the turbine-driven EFW pump becomes unavailable.

As the QCST depletes, portable diesel-driven pumps will be staged to transfer inventory to the QCST or directly to the SG feedwater (turbine-driven EFW or SG FLEX) pump suction. The qualified backup in the event the QCST is depleted is provided from the ECP via a portable FLEX inventory transfer pump.

Phase 1 core heat removal during Modes 5 and 6 will be accomplished by maintaining RCS inventory. Refer to the Phase 1 RCS Inventory Control strategy.

Diesel fuel required for FLEX equipment will be sourced from available onsite diesel fuel storage tanks for both ANO-1 and ANO-2.

Conceptual routings for reactor core cooling and heat removal strategies with SGs available (Modes 1 through 4) are contained in Attachment 3.

Conceptual routings for transfer of inventory to the QCST are contained in Attachment 3.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation of Procedures / Strategies / including interfaces to existing site procedures/ strategies/guidelines Guidelines will be developed in accordance with NEI 12-06 (Reference 2, Section 11.4). Further, the PWROG is developing generic and NSSS-specific FSGs. The FSGs developed for ANO will align with the PWROG guidance.

Identify modifications 1. The ANO-1 and ANO-2 primary and secondary connection points for the SG FLEX feed pump discharge during Modes 1 through 4 would be accessible locations on the EFW system.

2. The ANO-1 and ANO-2 primary and secondary SG FLEX feed pump suction for Modes 1 through 4 would require connections from the QCST piping to the pump.

3. Hose and/or piping connection(s) between the ECP and the QCST or QCST piping.

Key Reactor Parameters 1. SG Level

2. SG Pressure

Enclosure to 0CAN081302 Page 13 of 49 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 2

3. QCST Level

4. RCS Pressure

5. CETs

6. RCS Temperature Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Enclosure to 0CAN081302 Page 14 of 49 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver FLEX equipment to the appropriate staging area.

In the specific case of a flooding event, it is expected that several days notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of portable FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the FLEX equipment flood platform. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will be utilized for deploying any portable FLEX equipment. Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections The ANO-1 and ANO-2 event ANO-1 and ANO-2 primary The primary and secondary strategies are to rely upon the and secondary connections piping connections are installed turbine-driven EFW are required to the EFW located to be protected from pumps with inventory from the system and the QCST piping. the event specific conditions.

QCST. Either remote or local manual control of the turbine-driven EFW pump and flow control valves will be utilized;

Enclosure to 0CAN081302 Page 15 of 49 The plant will steam through the ADVs with either remote or local manual control of the valves; Transition to FLEX SG feed pump is possible; The FLEX SG feed pumps will feed the SG through connection into normal EFW piping; Primary and secondary connection locations address all external event possibilities; Potential use of the FLEX SG The FLEX connections will be The strategy, previously feed pump for Modes 5 and 6 constructed to withstand the described, is used for Modes 1 would require discharge NEI 12-06 (Reference 2) through 4; The strategy for connections to ANO-1 high hazards as applicable to Modes 5 and 6 (SGs not pressure injection (HPI) and ANO.

available) is addressed in the ANO-2 high pressure safety RCS Inventory Control strategy injection (HPSI)/charging below. piping.

The backup water source is Hose and/or piping The FLEX connections will be from the ECP. If any other connection(s) will be made constructed to withstand the alternate water source survives between the ECP and the NEI 12-06 (Reference 2) the event (such as the ANO-1 and QCST or QCST piping. hazards as applicable to the ANO-2 CSTs, the ANO-2 RMWT, specific water source.

and the ANO-1 RWHT), it can provide additional inventory to the QCST.

Notes: N/A

Enclosure to 0CAN081302 Page 16 of 49 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 3 It is calculated that the decay heat is able to maintain the required steam pressure to the turbine-driven EFW pump for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if provided acceptable sources of SG feed. Because condensate-grade water sources, diesel fuel supplies, and other large equipment cannot be assured to be on site, strategies for delivery of off-site equipment from the RRC must be developed. This strategy credits that back-ups to the Phase 2 equipment will be delivered from the RRC to be on-site during Phase 3 should any Phase 2 equipment fail during the indefinite coping period.

Alternate water sources were evaluated for their capability to extend SG feed time after plant trip.

The primary water source is the QCST. The site alternate water source is the ECP.

The Phase 3 recovery strategy and equipment necessary is independent of operational mode at the start of the event. The strategy involves accessing the ultimate heat sink (UHS) with inventory through the service water system (SWS) to one of the decay heat removal (DHR)/shutdown cooling (SDC) system heat exchangers, combined with re-powering one of the DHR/SDC system pumps.

Details:

Provide a brief description FSGs will be developed to support the Phase 3 core cooling and of Procedures / Strategies / heat removal strategies.

Guidelines Identify modifications A hose connection for an RRC pump will be installed in order to supply water from the UHS through the installed SWS piping, and discharging back into the UHS.

Key Reactor Parameters 1. SG Level

2. SG Pressure

3. QCST Level

4. RCS Pressure

5. CETs

6. RCS Temperature Notes: N/A Deployment Conceptual Design Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections A hose connection for an RRC A hose connection to the UHS The FLEX connections will be pump will be used to supply for an RRC pump will be constructed to withstand the water from the UHS through installed. NEI 12-06 (Reference 2) the installed SWS piping and hazards as applicable to ANO.

discharge back into the UHS.

Enclosure to 0CAN081302 Page 17 of 49 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 3 Any further level of design of None N/A this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to 0CAN081302 Page 18 of 49 Maintain RCS Inventory Control Determine Baseline coping capability with installed coping2 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Low-leak reactor coolant pump (RCP) Seals or RCS makeup required

All Plants Provide Means to Provide Borated RCS Makeup PWR-Installed Equipment Phase 1:

Based on the current conditions and performance of the RCP seals, RCP seal leakage is not anticipated to be an immediate concern. Under scenario conditions, it is not currently possible to add RCS inventory for either unit during Phase 1. RCS makeup remains a Phase 2 action and is discussed below.

On loss of DHR/SDC for Modes 5 and 6 (no SGs available), ANO will close containment and let the RCS heat up and eventually start boiling. A strategy for RCS makeup will be specified in Phase 2.

RCS Inventory Control:

For ANO-1 and ANO-2, RCS inventory control is not required until Phase 2.

RCS Shutdown Margin:

For ANO-1 and ANO-2 adequate shutdown margin is achieved by control rod insertion and Xenon buildup during Phase 1.

Details:

Provide a brief description Existing procedures/strategies/guidelines will be revised to of Procedures / Strategies / consider FSGs.

Guidelines Identify modifications ANO-2 SIT level power supply will need to be added to the batteries.

2 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN081302 Page 19 of 49 Maintain RCS Inventory Control Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Enclosure to 0CAN081302 Page 20 of 49 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

RCS inventory control and boration in Modes 1 through 4 will be provided by injecting borated water.

For ANO-1, one of the ANO-2 charging pumps will be repowered using the portable diesel generator (PDG). The charging pumps discharge will be cross-tied to either a primary or an alternate location in the ANO-1 HPI system. This allows injection of RCS inventory for ANO-1 prior to plant cool down and depressurization. The initial suction source for the charging pumps will be the ANO-2 boric acid makeup tank (BAMT) and subsequently inventory will be provided by the ANO-2 Refueling Water Tank (RWT). Maintaining RCS inventory is required to maintain natural circulation cooling (NCC) during the ANO-1 cooldown and depressurization.

For ANO-2, initial makeup inventory is provided by the safety injection tanks (SITs) during RCS cool down and depressurization. Following RCS cool down and depressurization, RCS inventory will be added as needed by utilizing a portable FLEX RCS makeup pump. The FLEX RCS makeup pump will be provided by either the ANO-1 Borated Water Storage Tank (BWST) or ANO-2 Refueling Water Tank (RWT). If the BWST or RWT are not available due to a tornado, an additional borated water source will be identified and utilized. Maintaining RCS inventory is required to maintain NCC long term.

During Modes 5 and 6 with SGs not available, the FLEX SG feed pumps will be utilized for RCS makeup due to their higher volume capacity with like connections. The BWST and RWT provide for Modes 5 and 6 RCS inventory during non-wind/missile events. Several alternatives are being evaluated to address Modes 5 and 6 RCS inventory needs during a wind/missile event.

Conceptual routings for RCS inventory control are contained in Attachment 3.

Conceptual routings for RCS inventory control with SGs not available (Modes 5 and 6) are contained in Attachment 3.

RCS Shutdown Margin:

For ANO-1, injection of the concentrated boron inventory maintained in the ANO-2 BAMT is sufficient to borate the RCS from hot full power critical boron concentration to cold shutdown (200°F).

The intended FLEX makeup capability supports the inventory makeup capability in existing analyses.

Several alternatives are being evaluated to address RCS inventory needs during a wind/missile event.

For ANO-2 the SITs will inject borated water during the plant cool down and depressurization.

Subsequent RCS makeup will be provided by the FLEX RCS makeup pump supplied with borated water from the ANO-1 BWST or ANO-2 RWT. Several alternatives are being evaluated to address RCS inventory needs during a wind/missile event.

RCS Mode 5 and Mode 6 Boric Acid Precipitation Control:

Enclosure to 0CAN081302 Page 21 of 49 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

The first concern for an ELAP during shutdown conditions is the selection of a makeup pump with sufficient capacity to match the expected steaming rate. The second concern is when to provide flushing flow in order to prevent the precipitation of boric acid. The capacity of the makeup provided during these modes addresses these concerns.

Details:

Provide a brief description FSGs will be developed to support the Phase 2 strategies for RCS of Procedures / Strategies inventory control.

/ Guidelines Identify modifications 1. One ANO-2 charging pump will be powered from a PDG to supply RCS makeup to ANO-1.

2. The ANO-2 charging pump requires connection to the ANO-1 HPI system.

3. The ANO-2 FLEX RCS makeup pump requires suction from the RWT and/or BWST.

4. The ANO-2 primary and secondary FLEX RCS makeup pump requires primary and secondary connections to the HPSI/charging piping.

5. For Modes 5 and 6 use of the FLEX SG feed pump would require discharge connections to ANO-1 HPI and ANO-2 HPSI/charging piping.

6. ANO-2 SIT level power supply will need to be added to the batteries.

7. Several alternatives are being evaluated to address RCS inventory needs during Modes 5 and 6 for wind-missile events.

Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements

Enclosure to 0CAN081302 Page 22 of 49 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Modification In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate staging area.

In the specific case of a flooding event, it is expected that several days notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time.

Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the FLEX equipment flood platform. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment. Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment. Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections For ANO-1, the ANO-2 charging For ANO-1, the ANO-2 The FLEX connections will be

Enclosure to 0CAN081302 Page 23 of 49 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

pump will be used to inject charging pumps require constructed to withstand the borated water into the HPI system connection to the ANO-1 HPI NEI 12-06 (Reference 2) with suction from the BAMT and piping. hazards as applicable to ANO.

then RWT. The discharge connection is to be hard-piped as much as practical to minimize the required length of high pressure hose.

For ANO-2, a FLEX RCS makeup ANO-2 FLEX RCS makeup pump would inject borated water pump requires primary and into the HPSI/charging system secondary connections to the with suction from the RWT or HPSI/charging piping and the BWST. RWT or BWST.

Modes 5 and 6 (with SGs not Potential use of the FLEX SG available) may require a higher feed pump for Modes 5 and 6 capacity pump, e.g., the FLEX SG would require discharge feed pump. connections to ANO-1 HPI and ANO-2 HPSI/charging piping.

ANO-2 SIT level power supply will need to be added to the batteries.

Several alternatives are being evaluated to address RCS inventory needs during Modes 5 and 6 for wind-missile events.

Notes: N/A

Enclosure to 0CAN081302 Page 24 of 49 Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

For Phase 3, Entergy intends to continue with the Phase 2 strategies with additional support and equipment provided by offsite resources. Phase 3 design will be completed during the detailed design phase. If it is determined in the detailed design phase that a mobile boration unit or a mobile water purification system is required these items will be obtained from the RRC.

Details:

Provide a brief description FSGs will be developed to support the Phase 3 RCS inventory of Procedures / Strategies / control strategies.

Guidelines Identify modifications No modifications are currently identified for Phase 3.

Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: N/A Deployment Conceptual Modification Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections N/A N/A N/A Notes: N/A

Enclosure to 0CAN081302 Page 25 of 49 Maintain Containment Determine Baseline coping capability with installed coping3 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Containment Spray

Hydrogen igniters (ice condenser containments only)

PWR-Installed Equipment Phase 1:

Containment function is not challenged early in the event; therefore, no actions are required in Phase 1 in support of containment function.

For Modes 5 and 6, containment function will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief description N/A of Procedures / Strategies /

Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Notes: N/A 3 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN081302 Page 26 of 49 Maintain Containment PWR Portable Equipment Phase 2:

Containment function is not challenged early in the event; therefore, no actions are required in Phase 2 in support of containment function.

Per the analysis supporting Reference 5, containment is not expected to be challenged for the duration of Phase 2.

For Modes 5 and 6, containment closure will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief description N/A of Procedures / Strategies /

Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Notes: N/A Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic N/A Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Modification N/A Strategy Modifications Protection of connections N/A N/A N/A Notes: N/A

Enclosure to 0CAN081302 Page 27 of 49 Maintain Containment PWR Portable Equipment Phase 3:

Using RRC equipment for restoration of SW to containment cooling, containment function will not be challenged even later in the event; therefore, no further actions are required in Phase 3 in support of containment function.

For Modes 5 and 6, containment closure will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief description FSGs will be developed to support the Phase 3 containment of Procedures / Strategies / strategies as needed.

Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Deployment Conceptual Modification Strategy Modifications Protection of connections The large UHS pump delivered No additional modification. N/A from the RRC will be utilized to recover the SWS.

Containment coolers are supplied from the SWS per normal operation. The large generator will support loads of the containment cooler fans.

Any further level of design of None N/A this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to 0CAN081302 Page 28 of 49 Maintain SFP Cooling Determine Baseline coping capability with installed coping4 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Makeup with Portable Injection Source PWR-Installed Equipment Phase 1:

SFP cooling is not challenged early in the event for either unit.

During phase 1, SFP cooling will be by boil-off of inventory in the pool. SFP makeup will be addressed in Phase 2, but during Phase 1 a makeup hose will be staged to ensure that makeup capability is available for Phase 2.

For ANO-1, for the maximum credible heat load, the time to boil is 3.87 hours0.00101 days 0.0242 hours 1.438492e-4 weeks 3.31035e-5 months . The boil-off rates of 28.10 gpm and 66.50 gpm were determined for normal and maximum decay heat in the SFP, respectively. These values correspond to a required volumetric flow rate of 27.32 gpm and 64.66 gpm, respectively, to replace any boil-off losses in the SFP using water with coolant properties at 130°F.

For ANO-2, for the maximum credible heat load, the time to boil is 2.19 hours2.199074e-4 days 0.00528 hours 3.141534e-5 weeks 7.2295e-6 months . ANO-2 SFP has a smaller volume and a higher decay heat load than the ANO-1 SFP. The boil-off rates of 42.92 gpm and 81.73 gpm were determined for normal and maximum decay heat in the SFP, respectively. These values correspond to a required volumetric flow rate of 41.73 gpm and 79.46 gpm, respectively, to replace any boil-off losses in the SFP using water with coolant properties at 130°F.

Details:

Provide a brief description Procedures/strategies/guidelines will be revised, as necessary, to of Procedures / Strategies / consider timing of requirements for access to the SFP.

Guidelines Identify modifications No modifications are required for Phase 1.

Key SFP Parameter SFP Level Notes: The key parameters will either be monitored from the control room or taken locally.

4 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN081302 Page 29 of 49 Maintain SFP Cooling PWR Portable Equipment Phase 2:

SFP cooling in the ELAP condition is accomplished by local pool boiling and evaporation supported by coolant makeup. SFP cooling is not challenged early in the event (Phase 1) for either unit due to the limited inventory loss due to boiling. However, access to the SFP area as a part of Phase 2 response could be challenged due to environmental conditions local to the pool. Thus, actions that require access to the SFP deck will be completed prior to Phase 2.

Makeup will be provided using a separate FLEX SFP makeup pump.

The strategies for the discharge connection to the SFP are to:

install branch connection to the SFP deck to accommodate a hose connection or oscillating spray fire nozzle

provide makeup via connection into existing SFP Cooling system (ANO-1) piping or service water (ANO-2) piping.

Both SFPs are located in a structure that does not require additional ventilation.

Conceptual routings for makeup to the SFP are contained in Attachment 3.

Details:

Provide a brief description FSGs will be developed to support the Phase 2 SFP cooling of Procedures / Strategies / strategies.

Guidelines Identify modifications 1. Install stand pipe in ANO-2 AB stairwell for supplying make-up via the FLEX SFP pump to the ANO-1 and ANO-2 spent fuel pools.

2. A connection into the existing ANO-1 SFP cooling system and ANO-2 service water piping would be required.

Key SFP Parameter SFP Level Notes: The key parameters will be monitored from the control room or taken locally.

Enclosure to 0CAN081302 Page 30 of 49 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate staging area.

In the specific case of a flooding event, it is expected that several days notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the FLEX equipment flood platform. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Enclosure to 0CAN081302 Page 31 of 49 Strategy Modifications Protection of connections The FLEX SFP pump will be Install a stand pipe in ANO-2 The FLEX connections will be used to supply water via a Auxiliary Building stairwell constructed to withstand the hose or oscillating fire monitor for supplying make-up via NEI 12-06 (Reference 2) nozzle. the FLEX SFP pump to the hazards as applicable to ANO.

ANO-1 and ANO-2 spent fuel If the connection into existing pools by hose or oscillating SFP cooling system piping or fire monitor nozzle.

service water is used, a hose will be connected. A connection into existing SFP cooling system piping (ANO-1) and service water (ANO-2) is required.

Notes: N/A

Enclosure to 0CAN081302 Page 32 of 49 Maintain SFP Cooling PWR Portable Equipment Phase 3:

For Phase 3, Entergy intends to continue with the Phase 2 strategies (boil-off) with additional support and equipment provided by off-site resources. RRC equipment can be installed into the existing SWS piping to provide makeup indefinitely.

This strategy credits that back-ups to the Phase 2 equipment will be delivered from the RRC to be on-site during Phase 3 should any Phase 2 equipment fail during the indefinite coping period.

Details:

Provide a brief description FSGs will be developed to support the Phase 3 SFP cooling of Procedures / Strategies / strategies.

Guidelines Identify modifications A hose connection for an RRC pump will be installed in order to supply water from the UHS through the installed SWS piping.

Key SFP Parameter SFP Level Notes: The key parameters will either be monitored from the control room or taken locally.

Deployment Conceptual Design Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections A hose connection for an RRC A pre-engineered, temporary The FLEX connections will be pump will be used to supply modification to connect the constructed to withstand the water from the UHS through RRC pump to an existing SW NEI 12-06 (Reference 2) the installed SWS piping. valve will be required to be hazards as applicable to ANO.

developed.

Any further level of design of None N/A this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to 0CAN081302 Page 33 of 49 Safety Functions Support Determine baseline coping capability with installed coping5 modifications not including FLEX modifications PWR-Installed Equipment Phase 1 Support for the safety functions is provided by continued observation of plant conditions by site personnel in the control room or taken locally. During Phase 1, the installed vital batteries are used to maintain the critical instrumentation, and some control systems (ANO-1 only), available to the site personnel.

The time which vital power will be available can be extended by performing a load shed of all loads which are not considered to be critical for monitoring the conditions of the plant during an ELAP.

DC load shed will be required in order to extend battery life until installed battery chargers can be re-powered via the FLEX PDGs.

Details:

Provide a brief description Procedures/strategies/guidelines will be revised to consider the of Procedures / Strategies FSGs.

/ Guidelines Identify modifications No modifications are required for Phase 1.

Key Parameters DC Bus Voltage Notes: N/A 5 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN081302 Page 34 of 49 Safety Functions Support PWR Portable Equipment Phase 2 The electrical portion of the ANO-1 and ANO-2 Phase 2 coping strategy consists of two main goals:

Maintain power to essential instrumentation by powering the battery charger.

Provide power to one ANO-2 charging pump and other equipment.

Maintaining power to essential instrumentation will be achieved by re-powering an installed battery charger via the FLEX PDG. Powering the one ANO-2 charging pump will be achieved by re-energizing portions of the electrical distribution or by routing cables directly to the pump motor.

Additional installed equipment may be required to be powered by the FLEX generators. This will include fuel oil transfer pumps. Additional equipment that may be required to be powered include portable fans/lighting, pressurizer heaters, and other essential equipment.

Modes 5 and 6 strategies will be evaluated as part of the detailed design phase.

Conceptual routings for safety function support are contained in Attachment 3. The portable equipment is listed in the following table.

Details:

Provide a brief description FSGs will be developed to support the Phase 2 safety functions of Procedures / Strategies / strategies.

Guidelines Identify modifications Installation of spare breaker in applicable existing switchgear and raceway from PDG staging location to tie-in points Key Parameters DC Bus Voltage Notes: N/A

Enclosure to 0CAN081302 Page 35 of 49 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate staging area.

In the specific case of a flooding event, it is expected that several days notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the FLEX equipment flood platform. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Enclosure to 0CAN081302 Page 36 of 49 Strategy Modifications Protection of connections For ANO-1 and ANO-2, a PDG Conduit will be run from the The FLEX connections will be will be used to maintain power PDG staging location to the constructed to withstand the to essential instrumentation by tie-in point for the battery NEI 12-06 (Reference 2) re-powering an existing battery charger that feeds vital DC hazards as applicable to ANO.

charger that feeds vital DC buses.

buses and provide electric power to one ANO-2 charging pump for RCS makeup as necessary.

Notes: N/A

Enclosure to 0CAN081302 Page 37 of 49 Safety Functions Support PWR Portable Equipment Phase 3 Similar Phase 3 coping strategies will be employed for both ANO-1 and ANO-2. Off-site equipment from the RRC will arrive on-site to supply Phase 3 coping capabilities.

Electrically, this includes 4160V diesel generators capable of re-powering 4160V buses. In turn, the 4160V buses will feed the 480V Engineered Safeguards buses so the Phase 2 PDGs are no longer required for this function.

Conceptual routings for safety function support are contained in Attachment 3. The portable equipment and commodities are listed in the following tables.

Details:

Provide a brief description FSGs will be developed to support the Phase 3 safety functions of Procedures / Strategies / strategies.

Guidelines Identify modifications None Key Parameters DC Bus Voltage Notes: N/A Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate staging area.

In the specific case of a flooding event, it is expected that several days notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the FLEX equipment flood platform. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Enclosure to 0CAN081302 Page 38 of 49 Safety Functions Support PWR Portable Equipment Phase 3 Strategy Modifications Protection of connections The ANO-1 and ANO-2 None The FLEX connections will be Phase 3 electrical coping constructed to withstand the strategy is to re-power 4160V NEI 12-06 (Reference 2)

Engineered Safeguards buses. hazards as applicable to ANO.

Notes: N/A

Enclosure to 0CAN081302 Page 39 of 49 PWR Portable Equipment Phase 2 Use and (potential / flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibilit Flow Rate and Maintenance / PM equipment y Required Head requirements (Quantity)

Portable SG 300 gallons per Feed Pump (3) minute (gpm) @ 900 Will follow EPRI X ft total developed template requirements head (TDH)

(estimated)

Portable RCS 40 gpm @ 1500 ft Injection TDH (estimated) Will follow EPRI X

Pump(ANO-2) template requirements (2)

Portable SFP 400 gpm @ 400 ft Will follow EPRI Makeup Pump X TDH (estimated) template requirements (2)

Portable 750 gpm @ 200 ft Inventory TDH (estimated) Will follow EPRI X

Transfer Pump template requirements (2)

Diesel 480 Volt, 800 kiloWatt Will follow EPRI X

Generator (2) (estimated) template requirements Debris Removal To Be Determined X

Equipment (TBD)

Enclosure to 0CAN081302 Page 40 of 49 PWR Portable Equipment Phase 3 Use and (potential/flexibility) diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibilit Flow Rate and equipment y Required Head ANO-1 SW 2500 gpm 9.8 gallons per hour X X X RRC Pump 52.15 ft (gph) fuel required ANO-1/2 SW 2500 gpm RRC Pump X X X 9.8 gph fuel required 52.15 ft (N+1)

ANO-2 SW 2500 gpm X X X 9.8 gph fuel required RRC Pump 52.15 ft Large Fuel X X X X TBD Fuel Replenish/Transfer Truck SW Suction X X X TBD Hose SW Discharge X X X TBD Hose Large 4160V X X X TBD DG Large 4160V X X X TBD DG (N+1)

Enclosure to 0CAN081302 Page 41 of 49 Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment N/A

Survey instruments

Dosimetry

Off-site monitoring/sampling

Radiological counting equipment

Radiation protection supplies

Equipment decontamination supplies

Respiratory protection Commodities N/A

Food o Meals ready to eat o Microwavable meals

Potable water Fuel Requirements N/A

#2 Diesel Fuel

Diesel fuel bladders Heavy Equipment N/A

4 wheel-drive transportation equipment (tow vehicle)

Debris clearing equipment (skid steer type)

Enclosure to 0CAN081302 Page 42 of 49

References:

1. NRC EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEE, March 12, 2012 [ADAMS Accession Number ML12056A045]

2. NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, August 2012

3. NRC JLD-ISG-2012-01, Revision 0, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, August 2012

4. ANO SARs

a. ANO-1 SAR, Amendment 25, Facility Operating License Number DPR-51, Docket Number 50-313

b. ANO-2 SAR, Amendment 24, Facility Operating License Number NPF-6, Docket Number 50-368

5. Entergy Document, Arkansas Nuclear One Station Response to INPO IER 11-4, Near-Term Actions to Address the Effects of an Extended Loss of All AC Power in Response to the Fukushima Daiichi Event, Attached in EDMS as ANO IER 11-4 Responses.zip

6. ANO Procedures

a. ANO-1 Procedure 1202.008, Blackout

b. ANO-2 Procedure 2202.008, Station Blackout

7. WCAP-17601-P, Revision 1, RCS Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs, January 2013

8. ANO Procedures

a. ANO-1 Procedure 1203.028, Loss of Decay Heat Removal

b. ANO-2 Procedure 2203.029, Loss of Shutdown Cooling

c. ANO-2 Procedure 2202.011, Lower Mode Functional Recovery

9. Task Interface Agreement 2004-04, "Acceptability of Proceduralized Departures from TSs Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332),"

dated September 12, 2006. (Accession No. ML060590273)

Enclosure to 0CAN081302 Page 43 of 49 Attachment 1A - ANO-1 Sequence of Events Timeline Action Elapsed Action Time Remarks / Applicability Item Time Constraint Y/N (hours) 0 Event Starts N/A Plant at 100% power 0 Perform Actions Consistent with Station N/A Actions performed per EOP Blackout Procedure (Reference 6a) 1 1 Declare ELAP Y ELAP declared when power sources cannot be restored 2 3 Perform Battery Load Shed Y Extended battery load shedding performed to extend life to Phase 2 3 5 Clear Debris Y Debris cleared for deployment paths for equipment 4 6 Perform Damage Assessment Y FSG requirement to devise coping strategies 5 6 Deploy and Connect FLEX 480V Y Establish connections to Generator provide power to ANO-2 Charging Pumps and ANO-1 Battery Chargers. Diesel Generator is shared between units and is adequately sized to provide power to both ANO-1 and ANO-2.

6 6 Align ANO-2 Charging pump for Y A makeup flow rate of 35 gpm ANO-1 RCS injection is used assuming a 20°F/hr cooldown. BWST volume should last throughout the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ELAP event.

ANO-2 Charging pumps are capable of supplying 44 gpm each.

7 8 Align inventory transfer pump Y Inventory transfer pump staged and aligned to provide makeup from the ECP via service water piping to the QCST prior to exhausting its normal operating volume. Pending analysis of makeup requirements for DHR.

8 8 Commence Plant Cooldown Y Confirmed by previous analysis 9 12 Deploy hose for SFP makeup Y Prior to onset of boiling 10 16 Refuel Diesel Equipment Y Assuming 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of fuel is available in all diesel

Enclosure to 0CAN081302 Page 44 of 49 equipment, the RCS makeup pump and 480V generator need to be refueled at ANO-1 starting at 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months . The QCST makeup pump needs to be refueled at 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

Requires hose to be staged from Fuel Oil Storage Building to diesel equipment staging areas. Re-power fuel oil transfer pumps using small portable diesel generator.

11 24 Prepare site for receipt of RRC Y RRC equipment expected to be equipment able to arrive 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event 12 24 Align SFP Feed Pump to SFP Y Assuming 15 feet of water is needed above the fuel racks for shielding; makeup to the ANO-1 SFP is not required until 47.67 hours7.75463e-4 days 0.0186 hours 1.107804e-4 weeks 2.54935e-5 months after the event.

SFP pump is shared between units and is adequately sized to provide necessary makeup flow for both ANO-1 and ANO-2.

13 N/A Establish any required ventilation N The need for ventilation through 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has not been determined.

Pending additional analysis.

14 N/A Align FLEX SG Feed Pump N Steam pressure is expected to be sufficient to operate the turbine-driven EFW pumps throughout the 72-hour ELAP event. The backup FLEX SG feed pumps should be deployed when time/resources permit.

15 N/A Align 4160V Generators N The 4160V generator aligned when possible 16 N/A Establish Large Fuel Truck Service N On-site fuel resources expected to last for over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 17 N/A Establish FLEX SW RRC Pump N The final details of this equipment will be finalized in the detailed design phase.

Enclosure to 0CAN081302 Page 45 of 49 Attachment 1A - ANO-2 Sequence of Events Timeline Action Elapsed Action Time Remarks / Applicability item Time Constraint Y/N (hours) 0 Event Starts N/A Plant at 100% power 0 Perform Actions Consistent with Station N/A Actions performed per EOP Blackout Procedure (Reference 6b) 1 1 Declare ELAP Y ELAP declared when power sources cannot be restored 2 3 Perform Battery Load Shed Y Extended battery load shedding performed to extend life to Phase 2 3 6 Deploy and Connect FLEX 480V Y Provides power to ANO-2 Generator Battery Chargers. Diesel Generator is shared between units and is adequately sized to provide power to both ANO-1 and ANO-2.

4 8 Commence Plant Cooldown to a Cold Y Assuming an initial cold leg Leg Temperature of 350°F temperature of 550°F cooled to a temperature of 350°F, this cooldown will take 2.67 hours7.75463e-4 days 0.0186 hours 1.107804e-4 weeks 2.54935e-5 months with a 2-hour hold.

5 5 Clear Debris Y Debris cleared for deployment paths for equipment 6 6 Perform Damage Assessment Y FSG requirement to devise coping strategies 7 8 Align inventory transfer pump Y The required time for QCST makeup is based on the credited TS QCST volume and the assumed cooldown strategy at ANO-1, which starts at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The QCST is a shared resource for both units. The exact need time for makeup to this water source is unknown until the cooldown strategy has been finalized.

Inventory transfer pump staged and aligned to provide makeup from the ECP via service water piping to the QCST prior to exhausting its normal operating volume. Pending analysis of makeup requirements for DHR.

8 12 Deploy hose for SFP makeup Y Prior to onset of boiling 9 16 Refuel Diesel Equipment Y Assuming 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of fuel is

Enclosure to 0CAN081302 Page 46 of 49 available in all diesel equipment, the QCST makeup pump needs to be refueled at 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

10 18 Align FLEX RCS Makeup Pump from Y RCS makeup is to be supplied suction source at 17.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months at a flow rate of 20 gpm.

11 24 Prepare site for receipt of RRC Y RRC equipment expected to be equipment able to arrive 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event 12 24 Align SFP Feed to SFP Y Assuming 15 feet of water is needed above the fuel racks for shielding, makeup to the ANO-2 SFP is not required until 24.74 hours8.564815e-4 days 0.0206 hours 1.223545e-4 weeks 2.8157e-5 months after the event.

SFP Feed Pump is shared between units and is adequately sized to provide necessary makeup flow for both ANO-1 and ANO-2.

13 N/A Establish any required ventilation N The need for ventilation through 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has not been determined.

Pending additional analysis.

14 N/A Align FLEX SG Feed Pump N Steam pressure is expected to be sufficient to operate the turbine-driven EFW pumps throughout the 72-hour ELAP event. The backup FLEX SG feed pumps should be deployed when time/resources permit.

15 N/A Align 4160V Generators N The 4160V generator aligned when possible 16 N/A Establish Large Fuel Truck Service N On-site fuel resources expected to last for over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 17 N/A Establish FLEX SW RRC Pump N The final details of this equipment will be finalized in the detailed design phase.

Enclosure to 0CAN081302 Page 47 of 49 Attachment 1B - NSSS Significant Reference Analysis Deviation Table WCAP value WCAP Gap and discussion Item Parameter of interest Plant applied value (WCAP-17601-P, Revision 1) page ANO-1 There are currently no identified deviations in the ANO-1 FLEX conceptual design with respect to the All PWROG guidance pending completion of PWROG-sponsored revision to WCAP-17601 (Reference 7) that is in progress for the updated NSSS strategy for B&W NSSS designs.

ANO-2 Entergy has evaluated WCAP-17601 (Reference 7) considering ANO-2 site-specific parameters and All determined that the conclusions of that document are generally applicable to ANO-2. There are currently no identified deviations in the ANO-2 FLEX conceptual design with respect to the PWROG guidance.

Enclosure to 0CAN081302 Page 48 of 49 Attachment 2 - Milestone Schedule The following milestone schedule is provided. The dates are planning dates that are subject to change as the FLEX program design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent six-month status reports.

ANO Milestone Schedule Status Original Target Completion (Will be updated Activity Date every 6 months)

Submit Overall Integrated Implementation Plan February 2013 Complete Update 1 August 2013 Complete Update 2 February 2014 Update 3 August 2014 Update 4 February 2015 Update 5 August 2015 Perform Staffing Analysis December 2013 Not Started Modifications Modifications Evaluation June 2013 Started Engineering and Implementation June 2013 - October 2015 Not Started ANO-1 Implementation Outage November 2014 February 2015 ANO-2 Implementation Outage October 2015 Not Started On-site FLEX Equipment Purchase June 2014 Not Started Procure November 2014 Not Started Off-site FLEX Equipment Develop Strategies with RRC November 2013 Not Started Install Off-site Delivery Station (if necessary) October 2014 Not Started Procedures PWROG issues NSSS-specific guidelines June 2013 May 2013 Create ANO FSG November 2014 Not Started Create Maintenance Procedures November 2014 Not Started Training Develop Training Plan June 2014 Not Started Implement Training November 2014 Not Started Submit Completion Report December 2015

Enclosure to 0CAN081302 Page 49 of 49 Attachment 3 - Conceptual Drawing Mark-ups Drawings have not been updated.

v t e Letter Sequence Other
TAC:MF0942, (Approved, Closed)
Initiation Request Acceptance Administration Questions 7 May 2013 26 June 2013 29 October 2013 Answers 25 July 2013 Results Approval Other: 0CAN011601, Notification of Full Compliance with NRC Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees), 0CAN021302, Units 1 and 2 - Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), 0CAN021405, 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 EA-12-049), 0CAN021502, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Bdbees), 0CAN021503, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation (Order Number EA-12-051), 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), ML13063A015, ML13241A414, ML13241A415, ML14045A156, ML14140A514, ML15016A433, ML15054A320, ML15236A340
MONTHYEAR2014-02-27 [Table View]

ML13241A414

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