ML16312A067
| ML16312A067 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/03/2016 |
| From: | Greg Werner Division of Reactor Safety IV |
| To: | Richard Anderson Entergy Operations |
| References | |
| Download: ML16312A067 (9) | |
See also: IR 05000313/2017008
Text
November 3, 2016
Mr. Rich Anderson, Site Vice President
Arkansas Nuclear One
Entergy Operations, Inc.
1448 SR 333
Russellville, AR 72802-0967
SUBJECT: ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NOTIFICATION OF NRC
INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES
AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND
EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/
MULTI-UNIT DOSE ASSESSMENT PLANS (05000313/2017008 AND
05000368/2017008) AND REQUEST FOR INFORMATION
Dear Mr. Anderson:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
staff will conduct a mitigation strategies for beyond-design-basis external events, spent fuel
pool instrumentation, and emergency preparedness enhancements inspection at Arkansas
Nuclear One, Units 1 and 2, from January 23 - 27, 2017. The inspection will consist of three
reactor inspectors from the NRC Region IV office plus one of the assigned resident inspectors
at Arkansas Nuclear One for one week. The inspection will be conducted in accordance with
the NRCs Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation
Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness
Communication/Staffing/Multi-Unit Dose Assessment Plans.
Experience has shown that this inspection is resource intensive both for the NRC inspectors
and licensee staff. In order to minimize the impact to your on-site resources and to ensure a
productive inspection, we have enclosed a request for documents needed for this inspection
activity. Please note that the documents are requested to be provided by December 30, 2016.
During the on-site inspection, inspectors will verify that plans for complying with NRC
Orders EA-12-049 and EA-12-051 are in place and are being implemented. Inspectors will
also verify the establishment of staffing and communications plans provided in response to the
March 12, 2012, request for information letter, and multi-unit dose assessment information
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency
Preparedness for Japan Lessons Learned, dated March 27, 2013. These plans and
information were provided in the site-specific submittals, which were subsequently reviewed by
the NRC staff for understanding and documented in the NRCs plant safety evaluations and
safety assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX
strategies, spent fuel pool instrumentation, and emergency preparedness enhancements
should be available to support the inspectors at the site during the inspection.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD
ARLINGTON, TX 76011-4511
R. Anderson
- 2 -
If there are any questions about this inspection or the material requested, please contact the
team lead inspector, John M. Mateychick, by telephone at (817) 200-1560 or by e-mail at
john.mateychick@nrc.gov.
This letter does not contain new or amended information collection requirements subject to
the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
requirements were approved by the Office of Management and Budget, control
number 3150 0011. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget control
number.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter and its enclosure will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of NRCs
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gregory E. Werner, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-313 and 50-368
Enclosure:
Request for Information
cc w/encl: Electronic Distribution
SUNSI Review
By: JMateychick
Yes No
Publicly Available
Non-Publicly Available
Non-Sensitive
Sensitive
Keyword:
OFFICE
SRI:EB2
C:EB2
NAME
JMateychick
GWerner
SIGNATURE
/RA/
/RA/
DATE
10/31/16
11/3/16
Letter to Rich Anderson from Gregory E. Werner, dated November 3, 2016
SUBJECT: ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NOTIFICATION OF NRC
INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES
AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND
EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/
MULTI-UNIT DOSE ASSESSMENT PLANS (05000313/2017008 AND
05000368/2017008) AND REQUEST FOR INFORMATION
Electronic distribution by RIV:
Regional Administrator (Kriss.Kennedy@nrc.gov)
Deputy Regional Administrator (Scott.Morris@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
Senior Resident Inspector (Brian.Tindell@nrc.gov)
Resident Inspector (Margaret.Tobin@nrc.gov)
Resident Inspector (Andy.Barrett@nrc.gov)
Branch Chief, DRP/E (Neil.OKeefe@nrc.gov)
Project Engineer, DRP/E (Brian.Correll@nrc.gov)
Project Engineer, RIDP (Jackson.Choate@nrc.gov)
ANO Administrative Assistant (Mary.Bennett@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Project Manager (Thomas.Wengert@nrc.gov)
Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Project Engineer, DRS/IPAT (Eduardo.Uribe@nrc.gov)
Senior Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)
Inspection Team Lead, Senior Reactor Inspector, DRS/EB2 (John.Mateychick@nrc.gov)
Team Member, Project Engineer, DRP/A (Thomas.Sullivan@nrc.gov)
Request for Information
FLEX Strategies, Spent Fuel Pool Instrumentation, and EP Enhancements Inspection
Arkansas Nuclear One, Units 1 and 2
Information Requested for the In-Office Preparation Week
The following information should be sent to the Region IV office in hard copy or electronic
format (use of the Certrec IMS information portal is preferred), to the attention of
John Mateychick, by December 30, 2016. (If electronic/CD format is preferred by Arkansas
Nuclear One, three copies will need to be sent to the Region IV office and one to the
Arkansas Nuclear One resident inspectors office.) The inspectors will select specific items
from the information requested below and then request from your staff additional documents
needed during the on-site inspection week. Also, we request that you categorize the
documents in your response with the numbered list below. Please provide requested
documentation electronically if possible. If requested documents are large and only hard
copy formats are available, please inform the team lead inspector, and provide subject
documentation during the first day of the on-site inspection. If you have any questions
regarding this information request, please call the team lead inspector as soon as possible.
TI 2515/191 - Appendix A
1. Provide current revision of the FLEX Final Integrated Plan, including any revisions
since January 2016 submission to the NRC.
2. Provide the FLEX strategy basis document.
3. Provide the operating, off-normal, abnormal, and/or emergency procedures where entry
into the FLEX support guideline(s) is initiated.
4. Provide a list of key pieces of equipment that directly perform a FLEX mitigation strategy
for core cooling (reactor coolant system and steam generators), containment, and/or
spent fuel pool cooling.
5. Provide a list and copies of every FLEX support guideline or equivalent procedure which
you developed or revised to implement your mitigating strategies. Provide copies of the
FLEX support guidelines/procedures which address (as applicable):
a. Restoration of AC power to essential loads.
b. DC Load shedding.
c. Primary (reactor coolant system) loss and makeup, including water source(s).
d. Secondary/steam generator makeup, including water source(s).
e. Containment isolation and safe shutdown valve operations while AC power
is unavailable.
f.
Monitoring and makeup options to the spent fuel pool.
g. Portable lighting (e.g., flashlights or headlamps) necessary for ingress and egress
to plant areas required for deployment of FLEX strategies.
h. Communications systems required for deployment of FLEX strategies.
i.
Achieving area access during a loss of AC power, including the protected area
and internal locked areas where equipment operation is necessary.
j.
Mitigating the effects of a loss of forced ventilation/cooling.
k. Access and pathways to locations where operators will be required to perform
local manual operations.
l.
Potential equipment failure as a result of loss of heat tracing during extended loss of
alternating current power.
m. Replenishment of fuel to diesel/gas powered equipment (e.g., FLEX diesel
generators, pumps, etc.).
n. Deployment and operation of portable systems (such as portable power supplies and
portable pumps).
o. Deployment routes and staging locations for FLEX portable equipment.
p. Containment venting (and/or analysis to demonstrate that containment venting is
not required).
q. Pre-staging or deployment of FLEX equipment necessary to support
shutdown risk processes/procedures (i.e., FLEX strategies in Modes 5 and
6).
6. Applicable site-specific hazards.
a. Seismic
i.
Provide documents which show the locations and configuration of structures which
store FLEX equipment.
ii.
Provide the evaluation/evidence to support that FLEX equipment is stored
in location(s) such that each location:
1. Meets the plants design basis safe-shutdown earthquake.
2. Meets the design requirements as described in ASCE 7-10, Minimum
Design Loads for Buildings and Other Structures.
3. Is outside a structure and evaluated for seismic interactions to ensure
equipment is not damaged by non-seismically robust components or
structures.
iii.
Provide documentation that explains how large portable FLEX equipment such as
pumps and power supplies are secured to protect them during a seismic event
(i.e., safe-shutdown earthquake level).
iv.
Provide documents which show that stored equipment and structures are
protected from seismic interactions to ensure that unsecured and/or non-seismic
components do not damage the equipment.
v.
Provide the travel route(s) for FLEX equipment from storage location(s) to their
location(s) of use, and evaluation(s) which demonstrate that the potential for soil
liquefaction is not of a concern for these travel route(s).
vi.
Seismic concerns for water source(s).
1. If the FLEX water sources are seismically robust, then provide the
assessment confirming that conclusion.
2. If the FLEX water sources are not seismically robust, then provide:
a. An assessment of alternate water sources.
b. Procedure(s) which describe when and how to access those sources.
vii.
If power is required to move or deploy FLEX equipment, then describe and
identify the locations of the power supplies which provide that power, and provide
the procedures which describe implementing those power supplies.
viii.
If equipment is needed to move the FLEX equipment, provide documents that
show how that equipment is protected from the seismic event.
ix.
Provide documents which show that the FLEX equipment connection points to
permanently installed plant system are seismically qualified to the same extent
as the permanently installed equipment.
x.
Provide documents which show that staged tools used to connect FLEX
equipment are acceptable/compatible with the connections used.
b. Extreme temperatures
For each key piece of equipment described in number 4 (above) that directly
performs or implements a FLEX mitigation strategy:
1. Provide the document which describes the high and low-temperature limit within
which the equipment will function.
2. Describe how the equipment is maintained within its allowable temperature range in
its storage location.
7. Provide the station-specific FLEX strategies time validation study(ies).
8. Relative to the testing and maintenance program for FLEX equipment, for each key piece
of equipment described in number 4 (above) that directly performs or implements a FLEX
mitigation strategy:
a. Identify the equipment and provide documents that describe either the testing
performed (including electrical cables) or other means used to verify that the
equipment can perform its required function.
b. For portable equipment, provide documentation describing how maintenance and
testing the equipment is in accordance with INPO AP-913 or an acceptable
alternative.
9. Provide documents which describe the programmatic controls in place to ensure that if
equipment or applicable connections are unavailable (e.g., due to maintenance), then
compensatory measures are implemented in accordance with guidance outlined in
10. Identify the procedure(s) provided in response to number 4 above which address:
i.
Early notification to mobilize the offsite response.
ii. Establishment of a point of delivery for the offsite equipment.
iii. Arrangements for delivery and deployment at the site.
iv. Sufficient supplies of commodities to support the equipment and site personnel.
a. Provide documents which describe your evaluation of what equipment and
commodities are needed to sustain and backup the sites coping strategies.
b. Provide documents which show that you have established means to ensure that fuel
for FLEX equipment can be delivered to the site if on-site fuel is unusable or
depleted.
c. Provide documents which describe the process by which you will revise the
required supplied equipment due to changes in the FLEX strategies or plant
equipment or equipment obsolescence.
11. Provide documents which show that your installed mechanical and electrical
connections are compatible with Phase 3 equipment.
a. Provide the station-specific National SAFER Center Playbook.
12. Relative to personnel training on FLEX strategies, provide:
a. FLEX training bases document(s).
b. Lesson plans for site emergency response leaders responsible for the implementation
of FLEX strategies. (Records for staff completing this training may be requested to be
provided to the inspectors during the on-site inspection week.)
c. Lesson plans for site personnel responsible for the execution of mitigating strategies
for beyond-design-basis external events (i.e., operators, craft personnel, security,
radiation protection, etc.) to ensure familiarity and considering available job aids,
instructions, and mitigating strategy time constraints.
13. Provide the procedure(s) which describe your configuration control program; and provide
lists that identify by number, name, and revision number the documents, drawings,
sketches, calculations, analyses, procedures/guidance and evaluations related to your
mitigation strategies.
14. Listing of corrective action program document summaries generated related to
FLEX equipment, strategies, procedures, and/or training.
TI 2515/191 - Appendix B
15. Provide the procedures for maintenance, testing, calibration, and use of the primary and
backup spent fuel pool instrumentation channels.
16. Provide documents which describe the training program that addresses the use,
maintenance, calibration, surveillance, and the use of alternate power to the primary
and backup spent fuel pool instrument channels. Specifically provide training
materials used in that program.
TI 2515/191 - Appendix C
17. Communications:
a. Provide documents which show that the communications system(s), technologies,
equipment, and power supplies would be available from the beginning of the event
and operate during an extended loss of alternating current power.
b. Provide documents which show that you have completed appropriate maintenance
and testing program activities to verify off-site response organizations communication
systems operate as designed.
c. Provide the procedures and/or guidance used to implement the
communication capabilities.
d. Provide documents which show that any new communications equipment, portable
power supplies, and/or systems have been incorporated into the testing and
preventative maintenance programs.
18. Staffing:
a. Provide documents which show that on-site and augmented staff will be available to
implement the strategies in response to a large-scale natural event that results an
extended loss of alternating current power and impedes access to the site, and that
functions/tasks have been appropriately staffed.
b. Provide documents which show that the site access methods (e.g., roadways,
navigable bodies of water and dockage, airlift, etc.) expected to be available following
the event and available to the Emergency Response Organization [as described in
your Phase 1 and 2 staffing assessments and NRC safety assessment].
c. Provide documents which show the testing, training, and drills/exercises performed
by you to demonstrate the Emergency Response Organizations ability to utilize the
communications systems and/or equipment.
19. Provide documents which show that your multi-unit dose assessment is capable of
analyzing concurrent radiological releases from all on-site significant sources
(including releases from spent fuel pools) during an extended loss of alternating
current power.
Lead Inspector Contact Information:
John Mateychick, Senior Reactor Inspector
Mailing Address:
817-200-1560
U.S. NRC, Region IV
John.Mateychick@nrc.gov
1600 East Lamar Blvd.
ATTN: John Mateychick, DRS
Arlington, TX 76011-4511