ML11355A153

Responses to Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01

ML11355A153
Person / Time
Site:	River Bend
Issue date:	12/14/2011
From:	Roberts J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001, RBG-47192
Download: ML11355A153 (5)

Text

En ItEntergy8 Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4149 Jerry C. Roberts Director, Nuclear Safety Assurance December 14, 2011 RBG-47192 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Reference:

Responses To Request For Additional Information Regarding 60-Day Response To Bulletin 2011-01 River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47

1.

River Bend Station 60-Day Response to NRC Bulletin 2011-01, "Mitigating Strategies," per RBG-47155, dated July 11, 2011

2.

River Bend Station - Request For Additional Information (RAI) Regarding 60-Day Response To Bulletin 2011-01, "Mitigating Strategies" (TAC NO.

ME6475), per RBC-50977, dated November 28, 2011 On May 11, 2011, the NRC issued Bulletin 2011-01, "Mitigating Strategies," to the holders of operating licenses for nuclear power reactors. The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f). The first response was due 30 days after issuance of the bulletin. By letter dated June 9, 2011, Entergy Operations, Inc., provided a response to the first set of questions for River Bend Station. The second response was due 60 days after issuance of the bulletin. By letter dated July 11, 2011 (Reference 1), Entergy responded to the second set of questions.

The NRC staff reviewed the information provided in Entergy's letters dated June 9 and July 11, 2011, and determined that additional information is needed (Reference 2) for the NRC to complete its review of the 60-day response to the bulletin. The Attachment identifies the RAI questions and responses.

RAI Responses Regarding 60-Day Response To Bulletin 2011-01 RBG-47192 Page 2 of 2 No regulatory commitments are contained in this letter.

If there are any questions, or if additional information is required, please contact Mr. Joseph Clark, Licensing Manager, at 225-381-4177.

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 this 14th day of December 2011.

Sincerely, JCR/wjf

Attachment:

Responses To Request For Additional Information Regarding 60-Day Response To Bulletin 2011-01 cc:

U.S. Nuclear Regulatory Commission Region IV 612 East Lamar Blvd., Suite 400 Arlington, TX 76011 NRC Resident Inspector PO Box 1050 St. Francisville, LA 70775 Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738

RBG-47192 Attachment Responses To Request For Additional Information Regarding 60-Day Response To Bulletin 2011-01

Attachment to RBG-47192 Page 1 of 2 Responses To Request For Additional Information Regarding 60-Day Response To Bulletin 2011-01

1. Describe in detail -the maintenance or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

The bulletin requested that each licensee describe in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies, these devices are commonly used for firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product releases. The NRC staff could not determine if you performed activities to ensure that these devices will be functional when needed.

Response

Maintenance and testing is not currently performed on the monitor nozzles; however, an action to develop a preventative maintenance task has been initiated within the River Bend corrective action program to include inspection and performance testing of the monitor nozzles in conjunction with the annual testing of the B.5.b portable pump.

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

The portable pump mission time for B.5.b strategy implementations is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The River Bend portable pump has a 190 gallon diesel fuel tank integrated into the pump trailer frame.

The primary RBS B.5.b strategy implementation procedure, states: "Sufficient fuel shall be maintained on site for the pump to run at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Maintaining the fuel level in the pump tank at least 3/4 full ensures that it will run for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to needing refueling." One of the pump post-run actions is verifying the pump tank level is at least 3/4 full. If not, diesel is added to the tank prior to storing the pump. Procedural compliance therefore ensures the portable pump has sufficient fuel to meet its' B.5.b mission time with the fuel maintained in the pump fuel tank.

Attachment to RBG-47192 Page 2 of 2

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 needed to support the mitigating strategies.

The bulletin requested that each licensee describe in detail the controls for assuring equipment supporting the mitigating strategies will be available when needed. Firefighter turnout gear, tools, and instruments are generally needed to implement the mitigating strategies. The staff found that tools and instruments are specifically listed in your response, but it is not clear if you inventory firefighter turnout gear.

Response

River Bend Fire Brigade Lockers and the Fire Brigade Van contain fire fighting equipment staged on site, including firefighter turnout gear. Inventories of the Fire Brigade Lockers and the Fire Brigade Van are performed quarterly.

4. Describe in detail how you assure the availability of Grand Gulf and Waterford nuclear plants to provide offsite support in response to a B.5.b event.

The bulletin requested that each licensee describe in detail how it assures the availability of offsite support, including a listing of offsite organization relied upon for emergency response.

The NRC Safety Evaluation documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026) relied upon agreements you had with Grand Gulf and Waterford nuclear plants to provide support to respond to a B.5.b event.

These agreements were not listed in your response to Question 5 of the bulletin.

Response

As reflected in the River Bend B.5.b Conforming License Amendment for Order EA-02-026, dated August 2, 2007, our responses stated that we would describe our strategy for using resources from our nearby sister plants (GGNS & WTFD-3) to supplement our response team. The NRC staff inspection (T12515/168) conducted in July 2006 confirmed that assistance from other EOI sites is addressed by procedures and coordinated by the corporate duty officer. The River Bend primary B.5.b implementing procedure, contains the following in as one of the Emergency Director actions/responsibilities:

"Contact Corporate Emergency Center (CEC) at.... for assistance in the acquisition of additional personnel, equipment and materials, and support services."

Entergy personnel support (other locations/functional areas) during a severe event is not addressed by agreements, but rather by basic company practice. As such, the additional support that Entergy would send to River Bend following a severe event could come from multiple sources, including the Entergy sister plants of Grand Gulf and Waterford-3, but also from other locations, both nuclear and non-nuclear. The statement in the B.5.b implementing procedure is sufficient to assure the mobilization of applicable support.