GNRO-2015/00004, Entergy'S Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mititgation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

ML15054A537
Person / Time
Site:	Grand Gulf
Issue date:	02/19/2015
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, GNRO-2015/00004
Download: ML15054A537 (14)

Text

Q

~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-2015/00004 February 19, 2015 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Fourth 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)

4. Entergy Letter to NRC, 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), dated February 28,2014 (GNRO-2014/00011, ML14059A080).

5. Entergy Letter to NRC, Entergy's 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 (Order Number EA-12-049), dated August 26,2014 (GNRO-2014/00060, ML14239A316).

GNRO-2015/00004 Page 2 of 3

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). References 3, 4, and 5 provided the first, second, and third six-month status reports. The purpose of this letter is to provide the fourth 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. James J. Nadeau, Regulatory Assurance Manager, at (601) 437-2103.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 19, 2015.

Sincerely, KJM/tmc

Attachment:

Grand Gulf Nuclear Station's Fourth 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: Kriss Kennedy Deputy 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, NRR/DORL Mail Stop OWFN/B B1 Washington, DC 20555-0001

GNRO-2015/00004 Page 3 of 3 (cc continued):

U. S. Nuclear Regulatory Commission ATIN: Jessica A. Kratchman Mail Stop OWFN/9 D2 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2015/00004 Grand Gulf Nuclear Station's Fourth 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-2015/00004 Page 1 of 10 Grand Gulf Nuclear Station's Fourth 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), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 6), 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 1, 2014, and are current as of January 31, 2015:

• Submit Six-Month Status Report 3 -August 2014

• Develop Strategies - November 2014

• Submit Six-Month Status Report 4 - Complete with submission of this document in February 2015 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.

These milestone target dates do not impact the Order implementation date.

Revised Target Activity Target Milestone Completion Status Completion Datet 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 Report 2 Feb 2014 Complete Report 3 Aug 2014 Complete

Attachment to GNRO-2015/00004 Page 2 of 10 Revised Target Activity Target Milestone Completion Status Completion Date t Date Report 4 Feb 2015 Complete Report 5 Aug 2015 Not Started Report 6 Feb 2016 Not Started Report 7 Deleted* Deleted Perform Staffing Analysis July 2015 Not Started Modifications Develop Mods (Design Start) May 2014 Complete Develop Strategies Nov 2014 Complete Develop Mods (Design Complete) Nov 2014 Started Mar 2015 Implementation Outage** Mar 2016 Not Started Implement Mods Mar 2016 Not Started On-site FLEX Equipmer:-t Purchase Feb 2015 Started Procure Dec 2015 Started Off-site FLEX Equipment Develop Strategies / Contract with July 2015 Started NSRC Procedures Issue GG FSGs May 2015 Started Mar 2016 Create Maintenance Procedures June 2015 Not Started Oct 2015 Procedure Changes Training May 2015 Not Started Feb 2016 Material Complete Training Develop Training Plan March 2015 Not Started Implement Training Feb 2016 Not Started Validation I Demonstration Mar 2016 Not Started Submit Completion Report Aug 2016 Not Started

• Deleted due to Completion Report being submitted in 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.

Attachment to GNRO-2015/00004 Page 3 of 10 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at GGNS, changes have been identified to the compliance strategies as described in the original 01P (Reference 1). The significant changes are described below. The changes will be incorporated into a future or the final OIP update.

• Modifications required for core cooling as described on page 21 of the OIP have changed. In lieu of new cross tie piping from the High Pressure Core Spray (HPCS) Service Water (SW) piping in the Diesel Generator (DG) Building to the Auxiliary Building (AB), a hose will be run from the HPCS SW piping in the DG building to the AB. In lieu of a single connection point on the Residual Heat Removal (RHR) Loop C piping, a primary and alternate hose connection will be added on piping associated with the Condensate and Refueling Water Storage and Transfer (CRWST) system piping on the 139' elevation of the AB. The primary hose connection point will allow injection via the RHR C system and the alternate hose connection point will allow injection via the Low Pressure Core Spray (LPCS) system. These hose routes are less than 100' and it has been determined that there are adequate resources and time available to implement these strategies. The hoses will be maintained in the FLEX storage buildings and will be subject to the same maintenance and controls as other FLEX hoses.

• The Spent Fuel Pool (SFP) cooling "Method 3" strategy described on page 40 of the OIP has changed. In lieu of modifying the SFP pipe upstream of valve 1G41 F007, an existing flush line upstream of a SFP cooling heat exchanger will be utilized. Following the BDBEE, the existing blind flange outboard of the flush line's manual isolation valve 1G41 F247A will be removed and a flanged hose connection will be bolted on. Hose will be routed from the 185' elevation of the AB to the 139' elevation to connect to the hose run from the HPCS SW piping in the' DG building. The physical location of this flush line is in the same area and elevation of the AB as the 01P proposed pipe modification location upstream of valve 1G41 F007 such that this revised strategy can be implemented in approximately the same time. The final delivery point into the SFP has not changed.

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 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.

Attachment to GNRO-2015/00004 Page 4 of 10 Overall Integrated Plan Open Items Status

1. Structure, content and details of the National SAFER Not Started Resource Center (NSRC) Grand Gulf Response Plan will be determined.

Interim Staff Evaluation Open Items Status 3.1.2.A Since theGGNS Probable Maximum This Open Item was Precipitation is greater than the grade addressed in Section 4 of elevation and sandbags are needed to GGNS's second six month protect against flooding, it is unclear how FLEX status report GGNS can be designated as a "dry" site. (Reference 5 of section 8).

Since the licensee identified GGNS as a dry site, licensee information related to NEI 12-06 guidelines identified in this report, Sections 3.1.2.1, 3.1.2.2, and 3.1.2.3 (storage, deployment, and procedural interfaces, respectively) are not discussed.

If the resolution of this Open Item results in GGNS not being categorized as a "dry" site, the guidelines of the NEI 12-06 Sections related to these report sections will need to be addressed by the licensee as part of that resolution.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Confirm that the storage facilities and This Confirmatory Item was plans will conform to the guidance in NEI addressed in Section 4 of 12-06, Section 5.3.1, for protection from GGNS's second six month seismic events. FLEX status report (Reference 5 of section 8) 3.1.3.1.A Confirm that at least one of the two FLEX This Confirmatory Item was equipment storage buildings would not be addressed in Section 4 of damaged by tornado missiles, based on GGNS's second six month the guidance in NEI 12-06, Section 7.3.1. FLEX status report (Reference 5 of section 8) 3.1.3.2.A Confirm that procedures address UHS In Progress usability when wind generated debris is This item will be addressed present in the UHS. by update to AQ GGN-052 response when information is available 3.2.1.1.A Confirm that the final Modular Accident In Progress Analysis Program Revision 4 (MAAP4) This item will be addressed analysis of the RCS response conforms to by update to AQ GGN-019

Attachment to GNRO-2015/00004 Page 5 of 10 Interim Staff Evaluation Confirmatory Items Status the NEI position paper dated June 2013, response when information entitled "Use of Modular Accident Analysis is available Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession Number ML13190A201) and the MAAP4limitations of the NRC endorsement letter, dated October 3,2013 (ADAMS Accession No. ML13275A318).

3.2.1.2.A Confirm that the MAAP4 analysis includes In Progress appropriate recirculation pump seal This item will be addressed leakage. by update to AQ GGN-025 response when information is available 3.2.1.3.A Confirm that the final Sequence of Events In Progress (SOE) reflects the results of the final This item will be addressed MAAP4 analysis of the RCS response and by update to AQ GGN-026 the licensee provides reasonable response when information assurance by some means (e.g. by is available walkthrough) that the timing of the actions in the SOE is achievable.

3.2.1.4.A Confirm that operation with the In Progress suppression pooltemperature at its This item will be addressed calculated maximum temperature will not by update to AQ GGN-024 impact the mitigation strategies, especially response when information RCIC operation and structural integrity of is available the suppression pool.

3.2.1.8.A Confirm that the hydraulic calculations for In Progress I

the FLEX pumps demonstrate that the This item will be addressed required flow rates can be achieved. by update to AQ GGN-034 response when information is available 3.2.2.A Confirm that the SFP area ventilation In Progress calculation demonstrates that, portable This item will be addressed ventilation is not required in the SFP area, by update to AQ GGN-039 or that the licensee provides a strategy to response when information use portable ventilation. is available 3.2.3.A Confirm that the licensee's strategy for In Progress maintaining containment capabilities This item will be addressed considers the results of the final MAAP4 by update to AQ GGN-026 analysis for RCS leakage and the response when information containment venting strategy. is available 3.2.4.2.A Confirm that the RCIC room heat up In Progress calculation for ELAP uses appropriate heat This item will be addressed loads and shows an acceptable room by update to AQ GGN-045

Attachment to GNRO-2015/00004 Page 6 of 10 Interim Staff Evaluation Confirmatory Items Status temperature. response when information is available 3.2.4.4.A Confirm that any required upgrades to the NRC Confirmatory Action site's communications systems have been completed, as noted in the NRC's review of the GGNS communications assessment (ADAMS Accession No. ML13129A132).

3.2.4.8.A Confirm that the licensee's analyses for In Progress size and loading of FLEX generators This item will be addressed shows acceptable results. by update to AQ GGN-034 response when information is available 3.2.4.8.B Confirm that the licensee's final proposed This item is addressed by connections of FLEX Phase 2 and 3 updated AQ GGN-053 electrical equipment to the permanent response.

plant equipment are acceptable.

3.2.4.9.A Confirm that the licensee has plans to In Progress refuel FLEX equipment based on the fuel This item will be addressed oil consumption rates. by update to AQ GGN-055 response when information is available 3.2.4.10.A Confirm the acceptability of RCIC operation" In Progress without the gland seal compressor (de- This item will be addressed energized 30 minutes after loss of all ac by update to AQ GGN-072 power). response when information is available 3.2.4.10.B Confirm that the calculations regarding' In Progress battery sizing which show that Vital This item will be addressed Batteries can provide required loads for at by update to AQ GGN-031 least 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> (considering load shedding) response when information are acceptable. is available Audit Completion or Status Questions Target Date Closed* - Updated response available on the GGN-001 ePortal.

Closed* - Updated response available on the GGN-002 ePortal (associated with ISE Confirmatory Item 3.1.1.1.A)

GGN-003 In Progress - This AQ response will be updated Aug 2015 when information is available (associated with

Attachment to GNRO-2015/00004 Page 7 of 10 Audit Completion or Status Questions Target Date ISE Confirmatory Item 3.1.3.1.A)

Closed* - Updated response available on the GGN-005 ePortal.

Closed* - Updated response available on the GGN-007 ePortal.

Closed* - Updated response available on the GGN-OOS ePortal.

In Progress - This AQ response will be updated Aug 2015 GGN-010 when information is available.

GGN-011 Closed* - Response available on the ePortal.

GGN-012 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-013 ePortal.

Closed* - Updated response available on the GGN-014 ePortal.

Closed* - Updated response available on the GGN-015 ePortal.

Closed* - Updated response available on the GGN-016 ePortal.

In Progress - This AQ response will be updated Aug 2015 GGN-017 when information is available.

In Progress - Updated response available on the GGN-019 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.1.1.A).

In Progress - Updated response available on the GGN-021 Aug 2015 ePortal.

GGN-022 Closed* - Response available on the ePortal.

GGN-023 Closed* - Response available on the ePortal.

In Progress - Updated response available on the GGN-024 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.1.4.A).

In Progress - Updated response available on the GGN-025 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.1.2.A).

In Progress - This AQ response will be updated GGN-026 when information is available (associated with Aug 2015 ISE Confirmatory Items 3.2.1.3.A and 3.2.3.A).

GGN-02S In Progress - Updated response available on the Aug 2015

Attachment to GNRO-2015/00004 Page 8 of 10 Audit Completion or Status Questions Target Date ePortal.

In Progress - This AQ response will be updated GGN-029 Aug 2015 when information is available.

In Progress - This AQ response will be updated GGN-030 Aug 2015 when information is available.

In Progress - This AQ response will be updated GGN-031 when information is available (associated with Aug 2015 ISE Confirmatory Item 3.2.4.1 O.B).

In Progress - This AQ response will be updated GGN-034 when information is available (associated with Aug 2015 ISE Confirmatory Items 3.2.1.8.A and 3.2.4.8.A).

In Progress - Updated response available on the GGN-036 Aug 2015 ePortal.

In Progress - This AQ response will be updated GGN-038 Aug 2015 when information is available.

In Progress - Updated response available on the GGN-039 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.2.A).

GGN-040 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-041 ePortal.

GGN-042 Closed* - Response available on the ePortal.

In Progress - This AQ response will be updated GGN-043 Aug 2015 when information is available.

GGN-044 Closed* - Response available on the ePortal.

In Progress - Updated response available on the GGN-045 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.4.2.A).

Closed* - Updated response available on the GGN-046 ePortal.

In Progress - This AQ response will be updated GGN-047 Aug 2015 when information is available.

GGN-048 Olosed" - Response available on the ePortal.

GGN-050 Closed* -Response available on the ePortal.

In Progress - Updated response available on the GGN-052 ePortal (associated with ISE Confirmatory Item Aug 2015 3.1.3.2.A). I GGN-053 In Progress - Updated response available on the Aug 2015

Attachment to GNRO-2015/00004 Page 9 of 10 Audit Completion or Status Questions Target Date ePortal (associated 'with ISE Confirmatory Item 3.2.4.8.B).

In Progress - This AQ response will be updated GGN-055 when information is available (associated with Aug 2015 ISE Confirmatory Item 3.2.4.9.A).

In Progress - This AQ response will be updated GGN-057 Aug 2015 when information is available.

In Progress - This AQ response will be updated GGN-058 Aug 2015 when information is available.

GGN-061 Closed* - Response available on the ePortal.

In Progress - Updated response available on the GGN-062 Aug 2015 ePortal.

In Progress - Updated response available on the GGN-063 Aug 2015 ePortal.

In Progress - This AQ response will be updated GGN-064 Aug 2015 when information is available.

GGN-065 Closed* - Response available on the ePortal.

GGN-066 Closed* - Response available on the ePortal.

GGN-067 Closed* - Response available on the ePortal.

In Progress - This AQ response will be updated GGN-071 Aug 2015 when information is available.

In Progress - Updated response available on the GGN-072 ePortal (associated with ISE Confirmatory Item Aug 2015 3.2.4.10.A).

• Closed indicates that Entergy's response is complete.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except those identified in Section 4.

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-2015/00004 Page 10 of 10

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).

4. NRC Letter, "Grand Gulf Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)

(TAC No. MF0954)," dated February 19, 2014 (ML14007A718).

5. Entergy Letter to NRC, 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), dated February 28, 2014 (GNRO-2014/00011, ML14059A080.

6. Entergy Letter to NRC, Entergy's 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 (Order Number EA-12-049), dated August 26,2014 (GNRO-2014/00060, ML14239A316).