GNRO-2014/00011, Entergy'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses- with- Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Entergy'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses- with- Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14059A080
Person / Time
Site:	Grand Gulf
Issue date:	02/28/2014
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, GNRO-2014/00011
Download: ML14059A080 (9)

Text

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<QQ> Entergy Entergy Operations, Inc.

P: 0: Box 756" Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2014/00011 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses- with- Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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 Strategies 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)

3. Entergy Letter to NRC, 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), dated August 28,2013 (GNRO-2013/0060, ML13240A264)

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.

GNRO-2014/00011 Page 2 of 2 Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). Reference 3 provided the first six-month status report. The purpose of this letter is to provide the second 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.

This letter contains no new regulatory commitments. Should you have any questions regarding- this submittal, please contact Mr. Jeffery A. Seiter, Acting Regulatory Assurance Manager, at (601) 437-2344.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014.

Sincerely,

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KJM/slw

Attachment:

Grand Gulf Nuclear Station's Second 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-2014/00011 Grand Gulf Nuclear Station's Second 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-2014/00011 Page 1 of 6 Grand Gulf Nuclear Station's Second 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 diverse 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 The following milestone(s) have been completed since August 28, 2013 and are current as of January 3l, 2Ut4:

• Submit Six-Month Status Report 1 - August 2013

• Submit Six-Month Status Report 2 - Complete with submission of this document in February 20-1-4.

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.

• There are no changes to milestone completion dates for this report.

Revised Target Activity Target Milestone Completion Status Completion Date t Date-Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit Six-Month Updates:

Report 1 Aug 2013 Complete N/A Report,2 Feb 2014 Complete Report 3 Aug 2014 Not Started Report 4 Feb 2015 Not Started Report 5 Aug 2015 Not Started Report 6 Feb 2016 Not Started Report 7 Deleted Deleted Deleted*

Perform Staffing Analysis Not Started Modifications Develop Mods (Design Start) May 2014 Not Started

Attachment to GNRD-2014/00011 Page 2 of6 Revised Target Activity Target Milestone Completion Status Completion Datet Date Develop Strategies Nov 2014 Started Develop Mods (Design Complete) Nov 2014 Not Started Implementation Dutage** Mar 2016 Not Started Implement Mods Mar 2016 Not Started

-On-site- FLEX Equipment Purchase Started Procure Started Off-site FLEX Equipment Develop Strategies / Contract with Started RRC Procedures Issue GG FSGs Not Started Create Maintenance Procedures Not Started Procedure Changes Training Not Started Material Complete Training Develop Training Plan Not Started Implement Training Not Started Validation I Demonstr~tion Mar 2016 Not Started Submit Completion Report Aug 2016 Not Started

'"Deleted due to Completion Report bemg submitted m August 2016.

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

tTarget Completion Date is the last submitted date from either the overall integrated plan or previous six-month status report.

4 Changes to Compliance Method In preparation for the design phase of the FLEX project at GGNS, changes have been identified to the compliance strategies as described in the original DIP (Reference 1).

The changes are described below. The changes will be incorporated into a revised DIP which will be included with a subsequent six-month status report.

• The external flood hazard assessment for GGNS is discussed on DIP page 1 of

69. The site was originally designated as a drY site for FLEX because the GGNS UFSAR, in Appendix 3A, identified the plant as a dry site based on the plant grade elevation being 30 feet greater than the probable- maximum flood (PMF) level. However, after consideration of the updated flood level due to probable maximum precipitation (PMP), the need for flood barriers for PMP and the guidance of NEI 12-06, Entergy has determined that GGNS will be classified as a wet site for beyond design basis events. As such, the GGNS FLEX strategy will incorporate, as applicable, the guidance of NE112,...06 sections 6.2.2 and 6.2.3 (including sub-sections 6.2.3.1 through 6.2.3.4).

• The description of storage and protection of equipment on DIP page 22 of 69 erroneously referenced NEI 12-06 Section 11. Section 11 is related to programmatic controls. Therefore, this section is revised to reflect the following.

Attachment to GNRO-2014/00011 Page 30f6

-Seismic GGNS will have two pre-engineered metal buildings which will be designed for seismic per NE112-06, Section 5.3.1.1.b (ASCE 7-10 and local building codes).

If information is not already available, soil borings will be taken and a geotechnical report generated to determine the appropriate foundation system and to ensure that soil liquefaction will not be an issue under either building. If information is not already available, soil borings will also be taken along the primary travel path from each building to the deployment loc~tions to ensure that at least one pathway will not be susceptible to soil liquefaction, which satisfies NEI 12-06, Section 5.3.2.1 for soil liquefaction.

Flooding At least one of the two storage buildings will be located above the flood elevation to satisfy NEI 12-06, Section 6.2.3.1 Consideration 1.a.

Severe Storms with High Winds GGNS intends to locate the FLEX equipment storage buildings in accordance with NEI12-06, Section 7.3.1.1.c (ASCE 7-10 and local building codes) to address high wind design criteria. Additionally, to provide reasonable assurance that at least one of the storage buildings would not be damaged by tornado missiles,- the- two buildings will be- separated based on a site specific evaluation and installed on an axis that is approximately perpendicular to the axis of the predominant path for tornadoes in the area of the site. The selected building separation will be based on an evaluation of historical tornado data for the region immediately surrounding the GGNS site.

Snow, Ice, and Extreme Cold The storage buildings will be designed to meet NEI 12-06, Section 8.3.1.1.b (ASCE 7-10 and local building codes) for ice. The site's design basis temperature will be used for the extreme cold considerations. Local block heaters;- water jackets-, etc. may be provided for equipment such that the entire storage building will not have to be heated.

High Temperatures The storage buildings will be designed to maintain the inside temperature within the FLEX equipment manufacturers' recommended storage temperatures to satisfy NEltZ-06, Section 9.3.1.

• Information regarding the transfer of diesel fuel from the underground safety related fuel tanks for use by portable FLEX equipment is provided on pages 20 and 55 of the OIP. GGNS has revised this strategy. The new strategy for all applicable hazards is to initially access fuel oil from the installed external event protected standby diesel generator day tanks. The installed fuel oil transfer pumps will be repowered to replenish the day tank inventories when necessary.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation GGNS-expectsto-complywith the order implementation date and no relief/relaxation is required at this time.

Attachment to GNRO-2014/00011 Page 4 of 6 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes a listing of Audit Questions and the status of each item.

Overall Integrated Plan Open Items Status

1. Structure, content and details of the Regional Not Started Response Center playbooks [Grand Gulf Response Plan] will be determined.

Interim Staff Evaluation Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an Interim Staff Evaluation for GGNS; therefore, there are no open items for the Interim Staff Evaluation identified at this time.

Interim Staff Evaluation Confirmatory Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an Interim Staff Evaluation for GGNS; therefore, ,there are no confirmatory items for the Interim Staff Evaluation identified at this time.

Audit Questions Status Completion or Target Date GGN-001 In Progress Feb 2015 GGN-002 Closed GGN-003 In Progress Feb 2015 GGN-005 Closed GGN-007 Closed GGN-008 Closed GGN-010 In Progress Feb 2015 GGN-011 Closed GGN-012 Closed GGN-013 In Progress Feb 2015 GGN~014 Closed GGN-015 In Progress Feb2015 GGN-016 In Progress Feb 2015 GGN-017 In Progress Feb 2015 GGN-019 In Progress Feb 2015 GGN-021 Closed GGN;.022 Closed GGN-023 Closed GGN-024 In Progress Feb 2015 GGN-025 In Progress Feb 2015

Attachment to GNRO-2014/00011 Page 50f6 Audit Questions Status Completion or Target Date GGN-026 Closed GGN-028 In Progress Feb 2015 GGN-029 Closed GGN-030 Closed GGN-031 In Progress Feb 2015*

GGN-034 In Progress Feb 2015 GGN-036 Closed GGN-038 Closed GGN-039 In ProQress Feb 2015 GGN-040 Closed GGN-041 Closed GGN-042 Closed GGN-043 In Progress Feb 2015 GGN-044 Closed GGN-045 In Progress Feb 2015 GGN-046 In ProQress Feb 2015 GGN-047 Closed GGN-048 Closed GGN-050 Closed GGN-052 Closed GGN-053 In ProQress Feb 2015 GGN-055 In Progress Feb 2015 GGN~057 Close-d GGN-058 In ProQress Feb 2015 GGN-061 Closed GGN-062 In ProQress Feb 2015 GGN-063 Closed GGN-064 In Progress Feb 2015 GGN-065 Closed GGN-066 Closed GGN-067 Closed GGN-071 In Progress Feb 2015 GGN-072 Closed 7 Potential Interim Staff Evaluation Impacts The NRC has not yet issued an interim staff evaluation for GGNS; therefore, there are no potential impacts to the Interim Staff 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).

Attachment to GNRO-2014/00011 Page 6 of6

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).

3. Entergy Letter to NRC, 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), dated August 28, 2013 (GNRO-2013/0060, ML13240A264).