GNRO-2016/00003, Sixth (Final) Six-Month Status Report in Response to March 12, 2102 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Sixth (Final) Six-Month Status Report in Response to March 12, 2102 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML16056A610
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/25/2016
From: Kevin Mulligan
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, GNRO-2016/00003
Download: ML16056A610 (13)
v • d • e


Text

  • Entergy

" 'P Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2016/00003 February 25, 2016 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Sixth (Final) Six-Month Status Report in Response to March 12, 2102 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 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)
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-2013/00060, ML13240A264)
4. Entergy Letter to NRC, Entergy's Second Six-Month Staus 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), dated February 28,2014 (GNRO-2014/00011, ML14059A080)

GNRO-2016/00003 Page 2 of 3

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)
6. Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537)
7. Entergy Letter to NRC, Entergy's Fifth 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, 2015 (GNRO-2015/00052, ML15240A020)
8. NRC Letter to Entergy, Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0954 and MF0955), dated November 24, 2015 (ML15308A298)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) 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 (BDBEEs).

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). References 3, 4, 5, 6 and 7 provided the first, second, third, fourth and fifth six-month status reports. Reference 8 provides the results of the on-site implementation audit. The purpose of this letter is to provide the sixth (final) 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 a final 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.

GNRO-2016/00003 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct; executed on February 25,2016.

Sincerely, KJM/sas

Attachment:

Grand Gulf Nuclear Station's Sixth 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: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. B. J. Smith Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2016/00003 Grand Gulf Nuclear Station's Sixth 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-2016/00003 Page 1 of 9 Grand Gulf Nuclear Station's Sixth 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 a final update of milestone accomplishments since submittal of the last status report (Reference 7), 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 July 31, 2015, and are current as of February 23, 2016:

  • Submit Six-Month Status Report 5 - August 2015
  • Submit Six-Month Status Report 6 - Complete with submission of this document in February 2016
  • Staffing Analysis - Complete with submission of GNRO-2015/00054 in October 2015
  • On-site FLEX Equipment - February 2016
  • Procedure Changes Training Material Complete - February 2016
  • Training - February 2016 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 Target Milestone Completion Activity Status Completion Date!

Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete

Attachment to GNRO-2016/00003 Page 2 of 9 Revised Target Target Milestone Completion Activity Status Completion Date" Date Submit Six-Month Updates:

Report 1 Aug 2013 Complete Report 2 Feb 2014 Complete Report 3 Aug 2014 Complete Report 4 Feb 2015 Complete Report 5 Aug 2015 Complete Report 6 Feb 2016 Complete Report 7 Deleted* Deleted Perform Staffing Analysis Oct 2015 Complete Modifications Develop Mods (Design Start) May 2014 Complete Develop Strategies Nov 2014 Complete Develop Mods (Design Complete) Mar 2015 Complete Note 1 Implementation Outage** Mar 2016 Started Implement Mods Mar 2016 Started On-site FLEX Equipment Purchase Sept 2015 Complete Procure Dec 2015 Complete Off-site FLEX Equipment Develop Strategies / Contract with Sept 2015 Complete NSRC Procedures Issue GG FSGs Mar 2016 Started Create Maintenance Procedures Oct 2015 Started Mar 2016 Procedure Changes Training Feb 2016 Complete Material Complete Training Develop Training Plan Sept 2015 Complete Implement Training Feb 2016 Complete Validation I Demonstration Mar 2016 Started

Attachment to GNRO-2016/00003 Page 3 of 9 Revised Target Target Milestone Completion Activity Status Completion Date" Date 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.

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

Note 1 - Design support continues for any change during modification implementation, procedure development, or validation.

4 Changes to Compliance Method Since submittal of the last six month update report, no significant changes to the compliance strategies as described in the original OIP have been identified.

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, any open items or confirmatory items documented in the Interim Staff Evaluation (ISE), and the open item documented in the implementation audit report. A fifth 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 National SAFER Onsite assessment Resource Center (NSRC) Grand Gulf Response Plan will be complete and the GG determined. Response Plan has been issued.

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

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,

Attachment to GNRO-2016/00003 Page 4 of 9 Interim Staff Evaluation Open Items Status 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.

Implementation Audit licensee Input Needed Status Open Item Description The NRC staff noted that the two FSBs The NRC staff notes that the An evaluation of (FLEX Storage Buildings) are designed licensee stated that the the FSBs is to the ASCE 7-10 standard with a seismic criteria were not the complete and has design seismic acceleration level of limiting criteria in the building been submitted to 0.059g, while the site's current design. The staff requests that the NRC on licensing basis for the safe shutdown the licensee make available for ePorta!. A earthquake is a seismic acceleration audit an analysis of the ability summary of the level of 0.15g. This does not meet the of the FSBs to survive a safe analysis results definition of a robust structure as shutdown earthquake, or the will be included in defined on p. A-2 of NEI 12-06, Rev. 0, ground motion response the FLEX nor does it conform to the protection spectrum from the Grand Gulf compliance letter.

level stated in section 5.3.1.2 of NEI seismic hazard and screening 12-06. report dated March 31, 2014.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Confirm that the storage facilities and plans This Confirmatory Item was will conform to the guidance in NEI 12-06, addressed in Section 4 of Section 5.3.1, for protection from seismic GGNS's second six month 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 the GGNS's second six month 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 This item is addressed by the usability when wind generated debris is update to the AQ GGN-052 present in the UHS. response 3.2.1.1.A Confirm that the final Modular Accident This item is addressed by the

Attachment to GNRO-2016/00003 Page 5 of 9 Interim Staff Evaluation Confirmatory Items Status Analysis Program Revision 4 (MAAP4) update to the AQ GGN-019 analysis of the RCS response conforms to response the NEI position paper dated June 2013, entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession Number ML13190A201) and the MAAP4 limitations of the NRC endorsement letter, dated October 3, 2013 (ADAMS Accession No. ML13275A318).

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

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

3.2.1.8.A Confirm that the hydraulic calculations for the This item is addressed by the FLEX pumps demonstrate that the required update to the AQ GGN-034 flow rates can be achieved. response 3.2.2.A Confirm that the SFP area ventilation This item is addressed by the calculation demonstrates that portable update to the AQ GGN-039 ventilation is not required in the SFP area, or response that the licensee provides a strategy to use portable ventilation.

3.2.3.A Confirm that the licensee's strategy for This item is addressed by the maintaining containment capabilities update to the AQ GGN-026 considers the results of the final MAAP4 response analysis for RCS leakage and the containment venting strategy.

3.2.4.2.A Confirm that the RCIC room heat up This item is addressed by the calculation for ELAP uses appropriate heat update to the AQ GGN-045 loads and shows an acceptable room response temperature.

3.2.4.4.A Confirm that any required upgrades to the NRC Confirmatory Action**

site's communications systems have been

Attachment to GNRO-2016/00003 Page 6 of 9 Interim Staff Evaluation Confirmatory Items Status 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 size This item is addressed by the and loading of FLEX generators shows update to the AQ GGN-034 acceptable results. response 3.2.4.8.B Confirm that the llcensee's final proposed This item is addressed by the connections of FLEX Phase 2 and 3 electrical update to the AQ GGN-053 equipment to the permanent plant equipment response are acceptable.

3.2.4.9.A Confirm that the licensee has plans to refuel This item is addressed by the FLEX equipment based on the fuel oil update to the AQ GGN-055 consumption rates. response 3.2.4.10.A Confirm the acceptability of RCIC operation This item is addressed by the without the gland seal compressor (de- update to the AQ GGN-072 energized 30 minutes after loss of all ac response power).

3.2.4.10.B Confirm that the calculations regarding battery This item is addressed by the sizing which show that Vital Batteries can update to the AQ GGN-031 provide required loads for at least 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> response (considering load shedding) are acceptable.

Audit Completion or Target Status Questions Date GGN-001 Closed* - Response available on the ePortal.

Closed* - Response available on the ePortal.

GGN-002 (associated with ISE Confirmatory Item 3.1.1.1.A)

Closed* - Response available on the ePortal.

GGN-003 (associated with ISE Confirmatory Item 3.1.3.1.A)

GGN-005 Closed* - Response available on the ePortal.

GGN-007 Closed* - Response available on the ePortal.

GGN-008 Closed* - Response available on the ePortal.

GGN-010 Closed* - Response available on the ePortal.

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

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

GGN-013 Closed* - Response available on the ePortal.

GGN-014 Closed* - Response available on the ePortal.

Attachment to GNRO-2016/00003 Page 7 of 9 Audit Completion or Target Status Questions Date GGN-015 Closed* - Response available on the ePortal.

GGN-016 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-017 ePortal.

Closed* - Updated response available on the GGN-019 ePortal. (associated with ISE Confirmatory Item 3.2.1.1.A).

GGN-021 Closed* - Response available on the ePortal.

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

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

Closed* - Response available on the ePortal.

GGN-024 (associated with ISE Confirmatory Item 3.2.1.4.A).

Closed* - Response available on the ePortal.

GGN-025 (associated with ISE Confirmatory Item 3.2.1.2.A).

Closed* - Response available on the ePortal.

GGN-026 (associated with ISE Confirmatory Items 3.2.1.3.A and 3.2.3.A).

GGN-028 Closed* - Response available on the ePortal.

GGN-029 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-030 ePortal.

Closed* - Updated response available on the GGN-031 ePortal. (associated with ISE Confirmatory Item 3.2.4.10.B).

Closed* - Updated response available on the GGN-034 ePortal. (associated with ISE Confirmatory Items 3.2.1.8.A and 3.2.4.8.A).

GGN-036 Closed* - Response available on the ePortal.

GGN-038 Closed* - Response available on the ePortal.

Closed* - Response available on the ePortal.

GGN-039 (associated with ISE Confirmatory Item 3.2.2.A).

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

GGN-041 Closed* - Response available on the ePortal.

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

GGN-043 Closed* - Response available on the ePortal.

Attachment to GNRO-20 16/00003 Page 8 of 9 Audit Completion or Target Status Questions Date GGN-044 Closed* - Response available on the ePorta!.

Closed* - Response available on the ePorta!.

GGN-045 (associated with ISE Confirmatory Item 3.2.4.2.A).

GGN-046 Closed* - Response available on the ePorta!.

GGN-047 Closed* - Response available on the ePorta!.

GGN-048 Closed* - Response available on the ePorta!.

GGN-050 Closed* - Response available on the ePorta!.

Closed* - Response available on the ePorta!.

GGN-052 (associated with ISE Confirmatory Item 3.1.3.2.A).

Closed* - Response available on the ePorta!.

GGN-053 (associated with ISE Confirmatory Item 3.2.4.8.8).

Closed* - Updated response available on the GGN-055 ePorta!. (associated with ISE Confirmatory Item 3.2.4.9.A).

Closed* - Updated response available on the GGN-057 ePorta!.

GGN-058 Closed* - Response available on the ePorta!.

GGN-061 Closed* - Response available on the ePorta!.

GGN-062 Closed* - Response available on the ePorta!.

Closed* - Updated response available on the GGN-063 ePorta!.

GGN-064 Closed* - Response available on the ePorta!.

GGN-065 Closed* - Response available on the ePorta!.

GGN-066 Closed* - Response available on the ePorta!.

GGN-067 Closed* - Response available on the ePorta!.

Closed* - Updated response available on the GGN-071 ePorta!.

Closed* - Response available on the ePorta!.

GGN-072 (associated with ISE Confirmatory Item 3.2.4.1 O.A).

  • Closed indicates that Entergy's response is complete.
    • This item is addressed by NRC confirmation of implementation of the issued modifications (Engineering Change 50711) for the site's communications systems.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

Attachment to GNRO-2016/00003 Page 9 of 9 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).
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).
7. Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537).
8. Entergy Letter to NRC, Entergy's Fifth 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 28,2015 (GNRO-2015/00052, ML15240A020).
9. NRC Letter to Entergy, Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0954 and MF0955), dated November 24, 2015 (ML15308A298)
  • Entergy

" 'P Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2016/00003 February 25, 2016 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Sixth (Final) Six-Month Status Report in Response to March 12, 2102 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 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)
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-2013/00060, ML13240A264)
4. Entergy Letter to NRC, Entergy's Second Six-Month Staus 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), dated February 28,2014 (GNRO-2014/00011, ML14059A080)

GNRO-2016/00003 Page 2 of 3

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)
6. Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537)
7. Entergy Letter to NRC, Entergy's Fifth 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, 2015 (GNRO-2015/00052, ML15240A020)
8. NRC Letter to Entergy, Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0954 and MF0955), dated November 24, 2015 (ML15308A298)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) 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 (BDBEEs).

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). References 3, 4, 5, 6 and 7 provided the first, second, third, fourth and fifth six-month status reports. Reference 8 provides the results of the on-site implementation audit. The purpose of this letter is to provide the sixth (final) 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 a final 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.

GNRO-2016/00003 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct; executed on February 25,2016.

Sincerely, KJM/sas

Attachment:

Grand Gulf Nuclear Station's Sixth 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: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. B. J. Smith Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2016/00003 Grand Gulf Nuclear Station's Sixth 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-2016/00003 Page 1 of 9 Grand Gulf Nuclear Station's Sixth 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 a final update of milestone accomplishments since submittal of the last status report (Reference 7), 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 July 31, 2015, and are current as of February 23, 2016:

  • Submit Six-Month Status Report 5 - August 2015
  • Submit Six-Month Status Report 6 - Complete with submission of this document in February 2016
  • Staffing Analysis - Complete with submission of GNRO-2015/00054 in October 2015
  • On-site FLEX Equipment - February 2016
  • Procedure Changes Training Material Complete - February 2016
  • Training - February 2016 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 Target Milestone Completion Activity Status Completion Date!

Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete

Attachment to GNRO-2016/00003 Page 2 of 9 Revised Target Target Milestone Completion Activity Status Completion Date" Date Submit Six-Month Updates:

Report 1 Aug 2013 Complete Report 2 Feb 2014 Complete Report 3 Aug 2014 Complete Report 4 Feb 2015 Complete Report 5 Aug 2015 Complete Report 6 Feb 2016 Complete Report 7 Deleted* Deleted Perform Staffing Analysis Oct 2015 Complete Modifications Develop Mods (Design Start) May 2014 Complete Develop Strategies Nov 2014 Complete Develop Mods (Design Complete) Mar 2015 Complete Note 1 Implementation Outage** Mar 2016 Started Implement Mods Mar 2016 Started On-site FLEX Equipment Purchase Sept 2015 Complete Procure Dec 2015 Complete Off-site FLEX Equipment Develop Strategies / Contract with Sept 2015 Complete NSRC Procedures Issue GG FSGs Mar 2016 Started Create Maintenance Procedures Oct 2015 Started Mar 2016 Procedure Changes Training Feb 2016 Complete Material Complete Training Develop Training Plan Sept 2015 Complete Implement Training Feb 2016 Complete Validation I Demonstration Mar 2016 Started

Attachment to GNRO-2016/00003 Page 3 of 9 Revised Target Target Milestone Completion Activity Status Completion Date" Date 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.

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

Note 1 - Design support continues for any change during modification implementation, procedure development, or validation.

4 Changes to Compliance Method Since submittal of the last six month update report, no significant changes to the compliance strategies as described in the original OIP have been identified.

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, any open items or confirmatory items documented in the Interim Staff Evaluation (ISE), and the open item documented in the implementation audit report. A fifth 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 National SAFER Onsite assessment Resource Center (NSRC) Grand Gulf Response Plan will be complete and the GG determined. Response Plan has been issued.

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

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,

Attachment to GNRO-2016/00003 Page 4 of 9 Interim Staff Evaluation Open Items Status 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.

Implementation Audit licensee Input Needed Status Open Item Description The NRC staff noted that the two FSBs The NRC staff notes that the An evaluation of (FLEX Storage Buildings) are designed licensee stated that the the FSBs is to the ASCE 7-10 standard with a seismic criteria were not the complete and has design seismic acceleration level of limiting criteria in the building been submitted to 0.059g, while the site's current design. The staff requests that the NRC on licensing basis for the safe shutdown the licensee make available for ePorta!. A earthquake is a seismic acceleration audit an analysis of the ability summary of the level of 0.15g. This does not meet the of the FSBs to survive a safe analysis results definition of a robust structure as shutdown earthquake, or the will be included in defined on p. A-2 of NEI 12-06, Rev. 0, ground motion response the FLEX nor does it conform to the protection spectrum from the Grand Gulf compliance letter.

level stated in section 5.3.1.2 of NEI seismic hazard and screening 12-06. report dated March 31, 2014.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Confirm that the storage facilities and plans This Confirmatory Item was will conform to the guidance in NEI 12-06, addressed in Section 4 of Section 5.3.1, for protection from seismic GGNS's second six month 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 the GGNS's second six month 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 This item is addressed by the usability when wind generated debris is update to the AQ GGN-052 present in the UHS. response 3.2.1.1.A Confirm that the final Modular Accident This item is addressed by the

Attachment to GNRO-2016/00003 Page 5 of 9 Interim Staff Evaluation Confirmatory Items Status Analysis Program Revision 4 (MAAP4) update to the AQ GGN-019 analysis of the RCS response conforms to response the NEI position paper dated June 2013, entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession Number ML13190A201) and the MAAP4 limitations of the NRC endorsement letter, dated October 3, 2013 (ADAMS Accession No. ML13275A318).

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

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

3.2.1.8.A Confirm that the hydraulic calculations for the This item is addressed by the FLEX pumps demonstrate that the required update to the AQ GGN-034 flow rates can be achieved. response 3.2.2.A Confirm that the SFP area ventilation This item is addressed by the calculation demonstrates that portable update to the AQ GGN-039 ventilation is not required in the SFP area, or response that the licensee provides a strategy to use portable ventilation.

3.2.3.A Confirm that the licensee's strategy for This item is addressed by the maintaining containment capabilities update to the AQ GGN-026 considers the results of the final MAAP4 response analysis for RCS leakage and the containment venting strategy.

3.2.4.2.A Confirm that the RCIC room heat up This item is addressed by the calculation for ELAP uses appropriate heat update to the AQ GGN-045 loads and shows an acceptable room response temperature.

3.2.4.4.A Confirm that any required upgrades to the NRC Confirmatory Action**

site's communications systems have been

Attachment to GNRO-2016/00003 Page 6 of 9 Interim Staff Evaluation Confirmatory Items Status 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 size This item is addressed by the and loading of FLEX generators shows update to the AQ GGN-034 acceptable results. response 3.2.4.8.B Confirm that the llcensee's final proposed This item is addressed by the connections of FLEX Phase 2 and 3 electrical update to the AQ GGN-053 equipment to the permanent plant equipment response are acceptable.

3.2.4.9.A Confirm that the licensee has plans to refuel This item is addressed by the FLEX equipment based on the fuel oil update to the AQ GGN-055 consumption rates. response 3.2.4.10.A Confirm the acceptability of RCIC operation This item is addressed by the without the gland seal compressor (de- update to the AQ GGN-072 energized 30 minutes after loss of all ac response power).

3.2.4.10.B Confirm that the calculations regarding battery This item is addressed by the sizing which show that Vital Batteries can update to the AQ GGN-031 provide required loads for at least 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> response (considering load shedding) are acceptable.

Audit Completion or Target Status Questions Date GGN-001 Closed* - Response available on the ePortal.

Closed* - Response available on the ePortal.

GGN-002 (associated with ISE Confirmatory Item 3.1.1.1.A)

Closed* - Response available on the ePortal.

GGN-003 (associated with ISE Confirmatory Item 3.1.3.1.A)

GGN-005 Closed* - Response available on the ePortal.

GGN-007 Closed* - Response available on the ePortal.

GGN-008 Closed* - Response available on the ePortal.

GGN-010 Closed* - Response available on the ePortal.

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

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

GGN-013 Closed* - Response available on the ePortal.

GGN-014 Closed* - Response available on the ePortal.

Attachment to GNRO-2016/00003 Page 7 of 9 Audit Completion or Target Status Questions Date GGN-015 Closed* - Response available on the ePortal.

GGN-016 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-017 ePortal.

Closed* - Updated response available on the GGN-019 ePortal. (associated with ISE Confirmatory Item 3.2.1.1.A).

GGN-021 Closed* - Response available on the ePortal.

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

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

Closed* - Response available on the ePortal.

GGN-024 (associated with ISE Confirmatory Item 3.2.1.4.A).

Closed* - Response available on the ePortal.

GGN-025 (associated with ISE Confirmatory Item 3.2.1.2.A).

Closed* - Response available on the ePortal.

GGN-026 (associated with ISE Confirmatory Items 3.2.1.3.A and 3.2.3.A).

GGN-028 Closed* - Response available on the ePortal.

GGN-029 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-030 ePortal.

Closed* - Updated response available on the GGN-031 ePortal. (associated with ISE Confirmatory Item 3.2.4.10.B).

Closed* - Updated response available on the GGN-034 ePortal. (associated with ISE Confirmatory Items 3.2.1.8.A and 3.2.4.8.A).

GGN-036 Closed* - Response available on the ePortal.

GGN-038 Closed* - Response available on the ePortal.

Closed* - Response available on the ePortal.

GGN-039 (associated with ISE Confirmatory Item 3.2.2.A).

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

GGN-041 Closed* - Response available on the ePortal.

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

GGN-043 Closed* - Response available on the ePortal.

Attachment to GNRO-20 16/00003 Page 8 of 9 Audit Completion or Target Status Questions Date GGN-044 Closed* - Response available on the ePorta!.

Closed* - Response available on the ePorta!.

GGN-045 (associated with ISE Confirmatory Item 3.2.4.2.A).

GGN-046 Closed* - Response available on the ePorta!.

GGN-047 Closed* - Response available on the ePorta!.

GGN-048 Closed* - Response available on the ePorta!.

GGN-050 Closed* - Response available on the ePorta!.

Closed* - Response available on the ePorta!.

GGN-052 (associated with ISE Confirmatory Item 3.1.3.2.A).

Closed* - Response available on the ePorta!.

GGN-053 (associated with ISE Confirmatory Item 3.2.4.8.8).

Closed* - Updated response available on the GGN-055 ePorta!. (associated with ISE Confirmatory Item 3.2.4.9.A).

Closed* - Updated response available on the GGN-057 ePorta!.

GGN-058 Closed* - Response available on the ePorta!.

GGN-061 Closed* - Response available on the ePorta!.

GGN-062 Closed* - Response available on the ePorta!.

Closed* - Updated response available on the GGN-063 ePorta!.

GGN-064 Closed* - Response available on the ePorta!.

GGN-065 Closed* - Response available on the ePorta!.

GGN-066 Closed* - Response available on the ePorta!.

GGN-067 Closed* - Response available on the ePorta!.

Closed* - Updated response available on the GGN-071 ePorta!.

Closed* - Response available on the ePorta!.

GGN-072 (associated with ISE Confirmatory Item 3.2.4.1 O.A).

  • Closed indicates that Entergy's response is complete.
    • This item is addressed by NRC confirmation of implementation of the issued modifications (Engineering Change 50711) for the site's communications systems.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

Attachment to GNRO-2016/00003 Page 9 of 9 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).
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).
7. Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537).
8. Entergy Letter to NRC, Entergy's Fifth 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 28,2015 (GNRO-2015/00052, ML15240A020).
9. NRC Letter to Entergy, Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0954 and MF0955), dated November 24, 2015 (ML15308A298)
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