GNRO-2013/00060, Entergy'S 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 (EA-12-049)

Entergy'S 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 (EA-12-049)

ML13240A264
Person / Time
Site:	Grand Gulf
Issue date:	08/28/2013
From:	Kevin Mulligan Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, GNRO-2013/00060
Download: ML13240A264 (6)

Text

~Entergy Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2013/00060 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's 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)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Str~tegies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

2. Entergy Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2013 (GNRO-2013/00015, ML13059A316)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued.an order (Reference 1) to.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.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). 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 attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

GNRO-2013/00060 Page 2 of 2 This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Christopher R. Robinson, Licensing Manager, at (601) 437-7326.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.

Sincerely,

~"'F------

KJM/slw

Attachment:

Grand Gulf Nuclear Station's 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 cc: U. S. Nuclear Regulatory Commission ATTN: Steven A. Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission ATTN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission ATTN: Jessica A. Kratchman Mail Stop OWFN/9 02 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2013/00060 Grand Gulf N~clear Station's 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

Attachment to GNRO-2013/00060 Page 1 of 3 Grand Gulf Nuclear Station's 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 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the divers~ and flexible strategies (FLEX), in response to Reference 2.

This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments As of August 28,2013, the following milestone(s) have been completed:

Submit 6 Month Updates - Update 1 (August 2013).

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. 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.

• Validation:

Walk-through(s) or Demonstration(s): A target completion date has been added to the milestone listing for completion of the walk-through(s). The walk-through(s) will be completed during the FLEX modification implementation outage. This new milestone target date does not impact the Order implementation date.

Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status 'Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Not Started No Change Update 3 Aug 2014 Not Started No Change Update 4 Feb 2015 Not Started No Change Update 5 Aug 2015 Not Started No Change Update 6 Feb 2016 Not Started No Change Update 7 Aug 2016 Not Started Deleted*

Perform Staffing Analysis Not Started No Change Modifications Develop Mods (Design Start) May 2014 Not Started No Change

Attachment to GNRO-2013/00060 Page 2 of 3

,. Revised Target Activity Target Milestone Completion Status Completion Date Date Develop Strategies In Progress Nov 2014 Develop Mods (Design Complete) Nov 2014 Not Started No Change Implementation Outage** Mar 2016 Not Started No Change Implement Mods Dec 2016 Not Started Mar 2016 On-site FLEX Equipment Purchase In Progress No Change Procure In Progress No Change Off-site FLEX Equipment Develop Strategies / Contract with In Progress No Change RRC Procedures Issue GG FSGs Not Started No Change Create Maintenance Procedures Not Started No Change Procedure Changes Training Material Not Started No Change Complete Training Develop Training Plan Not Started No Change Implement Training Not Started No Change Validation / Demonstration Mar 2016 Not Started Submit Completion Report Dec 2016 Not Started Aug 2016

• Deleted due to Completion Report bemg submitted m August 2016.

• • Full compliance since second refueling outage is before 12/31/2016.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

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

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan and the status of each item. The U.S. Nuclear Regulatory Commission (NRC) has not issued a draft safety evaluation for GGNS; therefore, there are no open items for the Draft Safety Evaluation identified at this time.

Overall Integrated Plan Open Item Status

1. Structure, content and details of the Regional Not Started Response Center playbooks will be determined.

Attachment to GNRO-2013/00060 Page 3 of 3 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.

1. "Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27,2013 (GNRO-2013/00015, ML13059A316).

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 (ML12054A735).