PNP 2012-091, Initial 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)

Initial 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)

ML12300A065
Person / Time
Site:	Palisades
Issue date:	10/25/2012
From:	Vitale A Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
PNP 2012-091, EA-12-049
Download: ML12300A065 (4)

Text

'"

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

.=::- Entergy 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2012-091 October 25, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Initial 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)

Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 [ADAMS Accession Number ML12054A736]

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29,2012 [ADAMS Accession Number ML12229A174]

3. Nuclear Energy Institute (NEI) Letter to NRC, "Industry Initiative on Procurement of Equipment for the Diverse and Flexible Coping Strategy (FLEX)," dated February 24,2012

4. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, dated August 2012 [ADAMS Accession Number ML12242A378]

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (ENO). This order was immediately effective and directed ENO to develop, implement, and maintain guidance and strategies to maintain or restore core

PNP 2012-091 Page 2 cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an initial status report 60 days following issuance of the final interim staff guidance. The final interim staff guidance (Reference 2) was issued August 30,2012.

The purpose of this letter is to provide the initial status report pursuant to Section IV, Condition C.2, of Reference 1 within 60 days following issuance of Reference 2. This report confirms ENO has received Reference 2 and is in the process of evaluating the guidance for the purpose of establishing mitigation strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event as described in Attachment 2 of Reference 1.

Major activities completed during this reporting period:

• Additional portable equipment was ordered prior to the issuance of Reference 2, as described in an NEI letter to the NRC (Reference 3).

• A site-specific evaluation is in progress to establish the coping capabilities as defined in NE112-06 (Reference 4).

• Resources are being identified and project plans initiated, including development of milestones, to assure compliance with Reference 1.

Planned activities for the next six months:

• Development and submittal of the overall integrated plan.

Technical difficulties encountered that could affect the ability to provide the licensee's February 28, 2013, submittal:

• None at this time.

Project milestone schedule through completion of installation and testing:

• A project milestone schedule will be provided with the overall integrated plan.

Implementation of the order will be completed for Palisades Nuclear Plant prior to startup from refueling outage 1R24 (scheduled Spring 2015).

This letter contains no new regulatory commitments.

PNP 2012-091 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on October 25,2012.

cc: U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Mac Chawla, Project Manager, Palisades 1155 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Region III Administrator 2443 Warrenville Rd Suite 210 Lisle, IL 60532-4352 U. S. Nuclear Regulatory Commission Attn: Resident Inspector, Palisades 27880 Blue Star Highway Covert, MI 49043 U. S. Nuclear Regulatory Commission Attn: Robert J. Fretz Jr.

OWFN, Mailstop # 4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Robert L. Dennig OWFN, Mailstop # 10E1 11555 Rockville Pike Rockville, MD 20852-2378

PNP 2012-091 Page 4 U. S. Nuclear Regulatory Commission Attn: Ms. Jessica A. Kratchman OWFN, Mailstop # 902 11555 Rockville Pike Rockville, MO 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Eric E. Bowman OWFN, Mailstop # 12020 11555 Rockville Pike Rockville, MO 20852-2378 U. S. Nuclear Regulatory Commission Attn: Ms. Eileen M. McKenna TWFN, Mailstop # 1005 11555 Rockville Pike Rockville, MO 20852-2378