ML113490429
| ML113490429 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/15/2011 |
| From: | Vitale A J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-11-001, PNP 2011-88, TAC ME6461 | |
| Download: ML113490429 (5) | |
Text
- Entergy Nuclear Operations, Inc.Palisades Nuclear Plant~E'ntergy~B~e~g~lernorial Highway Tel 269 764 2000 Anthony J.Vitale Site Vice President PNP 2011-88 December 15, 2011 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
NRC Bulletin 2011-01-Response to Request for Additional Information Palisades Nuclear Plant Docket 50-255 License No.DPR-20
REFERENCE:
1.Letter, Palisades to USNRC,"60 Day Response to NRC Bulletin 2011-01, Mitigating Strategies, Entergy Nuclear Operations, Inc."PNP2O11-056, dated July 08, 2011 Letter, USNRC to Palisades,"Palisades Nuclear Plant-Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, Mitigating Strategies"(TAC No.ME6461), dated November 21, 2011
Dear Sir or Madam:
In Reference 1, Palisades Nuclear Plant provided the 60-day response to NRC Bulletin 2011-01.In Reference 2, the NRC provided a request for additional information (RAI).Attachment 1 provides responses to each of the RAI questions.
There are no new commitments contained in this submittal.
If you need any additional information, please contact Mr.Otto Gustafson, Licensing Manager, at 269 764 2049.I declare under penalty of perjury that the contents of this response are true and correct to the best of my knowledge and belief.Executed on December 15, 2011.Sincerel ajv/tad
Attachment:
1 N C Bulletin 2011-01-Response to Request for Additional Information CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USN RC Attachment 1 Palisades Nuclear Plant NRC Bulletin 2011-01 Response to Request for Additional Information 3 Pages Follow PNP 2011-88/Attachment 1/Page 1 of 3 NRC Bulletin 2011-01-Response to Request for Additional Information RAI 1: Describe in detail how you ensure that a vehicle is available to move the B.5.b portable pump and other B.5.b equipment to the appropriate place when needed.The bulletin requested that each licensee describe in detail the controls for ensuring equipment needed to execute the mitigating strategies will be available when needed.A vehicle is typically needed to implement the strategies since the portable pump and other equipment is stored away from target areas.The NRC staff could not determine if you performed activities to ensure that a tow vehicle would be available when needed.Response: A Palisades Nuclear Plant (PNP)guidance document lists the available tow vehicles for the B.5.b portable pump and trailer.The guidance document contains instructions to obtain any one of eight on-site vehicles.One vehicle is specifically dedicated for the purpose of B.5.b response.The dedicated vehicle is located outside of the protected area with alternate vehicles located both inside and outside the protected area.The total number of possible tow vehicles ensures a vehicle will be available if needed.RAI 2: Describe in detail how you ensure there is sufficient fuel for the pumping source when needed.The bulletin requested that each licensee describe in detail the maintenance of equipment supporting the mitigating strategies to ensure that it will be functional when needed.The NRC staff could not determine if you performed activities to ensure that sufficient fuel would be available for the pumping source so that it will be functional when needed.Response: Guidance for operation of the pumping source is controlled via a job aid that is physically located with the pump and trailer.A 190 gallon fuel tank is mounted on the pump trailer.The job aid directs the fuel tank be refilled after each operation of the pump.At full throttle, 145 gallons of fuel is needed for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of operation.
Refilling the fuel tank after each operation of the pump ensures the pumping source has sufficient fuel to meet the 12-hour mission time.RAI 3: Identify the minimum inventory frequency for equipment needed for the mitigating strategies not specifically identified in response to the bulletin.Alternatively, describe the inventory frequency for firefighter turnout gear, tools, and instruments needed to support the mitigating strategies.
PNP 2011-88/Attachment 1/Page 2 of 3 The bulletin requested that each licensee describe in detail the controls for ensuring equipment supporting the mitigating strategies will be available when needed.Firefighter turnout gear, tools, and instruments are generally needed to implement the mitigating strategies, but not all of these items were clearly included in your response to the bulletin.Response: In the third response of the 60-day response to the bulletin (reference 1), the minimum inventory frequency for equipment, tools, and instruments needed for the mitigating strategies was identified, with the exception of firefighter turnout gear.The firefighter turnout gear is inventoried quarterly.
RAI 4: Describe in detail how you ensure the availability of local law enforcement agencies relied upon for emergency response to a B.5.b event.The bulletin requested that each licensee describe in detail how it ensures the availability of offsite support, including a listing of offsite organizations relied upon for emergency response.Typically, local law enforcement agencies are relied upon for emergency response to a B.5.b event.In response to Question 5 of the bulletin, you did not identify any local law enforcement agencies as being relied upon to respond to a B.5.b event.Response: Specific to the implementation of the PNP B.5.b strategies, resources from local law enforcement agencies (LLEAs)are not considered.
However, the PNP Physical Security Plan assures the availability of LLEAs in accordance with the requirements of the plan.Off-Site Organization Van Buren County Sheriff's Office Michigan State Police FBI, Michigan State Police, Van Buren County Sheriff's Office Implementing document*PLP Physical Security Plan Sections 8 and 18*PLP-SEC-2009-01 43, Letter of A reement*PLP Physical Security Plan Section 8&18*PLP-SEC-2009-01 44, Letter of A reement*PLP Physical Security Plan*PLP-SEC-201 1-0001, Hostile Action Memorandum of Validation Training/Familiarization and Refresher/Periodicity LLEA meetings conducted with PNP Security Management several times each year 2-year LLEA meetings conducted interval with PNP Security Management several times each year 2-year LLEA meetings conducted interval with PNP Security Management several times each year Periodicit 2-year interval PNP 2011-88/Attachment 1/Page 3 of 3 RAI 5: Clarify what the inspection frequency is for the B.5.b portable hose and equipment trailer.In response to the bulletin, you state that the B.5.b portable hose and equipment trailer is inspected annually in response to Question 1 and quarterly in response to Question 2.Response: In the PNP 60-day response to NRC Bulletin 2011-01 (reference 1), question 1 was specific to maintenance performed on equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.Inspections of the B.5.b portable hose and equipment trailer for damage and functionality is considered maintenance.
The inspection frequency for the B.5.b portable hose and equipment trailer is annually.In the PNP 60-day response to NRC Bulletin 2011-01 (reference 1), question 2 was specific to the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.The actual operation of the portable diesel powered water pump and use of the B.5.b portable hose and equipment trailer is considered testing the equipment.
The testing frequency for the portable diesel powered water pump and the B.5.b portable hose and equipment trailer is quarterly.