RBG-47389, 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)

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)

ML13247A414
Person / Time
Site:	River Bend
Issue date:	08/28/2013
From:	Olson E Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RBG-47389
Download: ML13247A414 (6)

Text

Entergy Operations, Inc.

River Bend Station Entergya 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Eric W. Olson Site Vice President RBG-47389 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Entergy's 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)

River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47

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 (ADAMS Accession No. ML12054A736)

(RBC-51013)

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 ForBeyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012

4. 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 (OrderNumber EA-12-049),

RBG-47302, dated October 24, 2012

5. Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049),

RBG-47329, dated February 28, 2013

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc.

(Entergy). Reference 1 was immediately effective and directs River Bend Station (RBS) 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. Specific requirements are outlined in Attachment 2 of Reference 1.

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RBG-47389 Page 2 of 3 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the RBS initial status report regarding mitigation strategies. Reference 5 provided the RBS overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first 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 enclosed 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. Joseph Clark, Manager- Licensing, at 225-381-4177.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.

Sincerely, EWO/TAE/JAC/wjf

Attachment:

River Bend Station's First 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 Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 NRC Resident Inspector R-SB-14 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326

RBG-47389 Page 3 of 3 cc: (continued)

Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738 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: Robert J. Fretz Jr.

Mail Stop OWFN/4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert L. Dennig Mail Stop OWFN/10E1 11555 Rockville Pike Rockville, MD 20852-2378 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section ATTN: JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 U. S. Nuclear Regulatory Commission ATTN: Ms. Jessica A. Kratchman Mail Stop OWFN/9D2 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Mr. Eric E. Bowman Mail Stop OWFN/12D20 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Ms. Eileen M. McKenna Mail Stop TWFN/10D5 11555 Rockville Pike Rockville, MD 20852-2378

Attachment to RBG-47389 River Bend Station's First 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 RBG-47389 River Bend Station's First 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 August 2013

1. Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan for River Bend Station (RBS) in Reference 1, which documented the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, 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 the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013:

None.

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.

0 Validation/Demonstration A target completion date has been added to the milestone listing for completion of the FLEX Strategy Validation/Demonstration. The validation/demonstration will be completed during the FLEX modification implementation outage. This new milestone target date does not impact the Order implementation date.

Target Activity Revised Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Feb 2013 Complete Implementation Plan Submit 6 Month Status Report Aug 2013 Complete Develop Mods Dec 2013 In-process Develop Strategies (Playbook) with Regional Response Center Purchase/Procure Equipment April 2014 In-process Submit 6 Month Status Report Feb 2014 Not Started Issue FLEX Procedures Create Maintenance Procedures Submit 6 Month Status Report Aug 2014 Not Started Procedure Changes Training Material Complete Develop Training Plan Submit 6 Month Status Report Feb 2015 Not Started Implement Training Submit 6 Month Status Report Aug 2015 Not Started Page 1 of 2

Attachment to RBG-47389 Target Activity Revised Target Milestone Completion Completion Date Status Date Submit 6 Month Status Report Feb 2016 Not Started Submit 6 Month Status Report Aug 2016 Not Started Implement Non-Outage Mods* Dec 2016 Not Started Validation / Demonstration Dec 2016 Not Started Submit Completion Report Dec 2016 Not Started

• (Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016)

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5. Need for RelieflRelaxation and Basis for the Relief/Relaxation RBS 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 Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status

1. Beyond-design-basis external event impact on Not Started requirements in existing licensing documents will be determined based on input from the industry groups and direction from the NRC.

2. Structure, content and details of the Regional Not Started Response Center playbook will be determined.

Draft Safety Evaluation Open Item Status None

7. Potential Draft Safety Evaluation Impacts The Draft Safety Evaluation has not been issued at this time.

8. References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. River Bend Station Overall Integrated Plan In Response To March 12, 2012 Commission Order To Modify Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013.

2. NRC Order Number EA-1 2-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

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