RBG-47445, 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)

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)

ML14064A202
Person / Time
Site:	River Bend
Issue date:	02/26/2014
From:	Olson E Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RBG-47445
Download: ML14064A202 (11)

Text

Entergy Operations, Inc.

River Bend Station En tergy 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Eric W. Olson Site Vice President RBG-47445 February 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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)

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-BasisExternal 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-BasisExternal Events (OrderNumber EA-12-049),

RBG-47302, dated October 24, 2012

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

RBG-47329, dated February 28, 2013 6 Entergy's Six-Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies ForBeyond-Design-Basis External Events (Order Number EA-12-049), RBG-47389, dated August 28, 2013.

RBG-47445 February 26, 2014 Page 2 of 4

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 cooing, 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 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. Reference 6 provided the first six-month status report. The purpose of this letter is to provide the second 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 February 26, 2014.

Sincerely, EWO/JAC/dhw

Attachment:

River Bend Station's Second 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 (continued)

RBG-47445 February 26, 2014 Page 3 of 4 NRC Resident Inspector R-SB-14 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 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/4A1 5A 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 (continued)

RBG-47445 February 26, 2014 Page 4 of 4 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/1OD5 11555 Rockville Pike Rockville, MD 20852-2378

Attachment to RBG-47445 (6 pages)

River Bend Station's Second Six-Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

River Bend Station's Second 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 February 2014

1. Introduction Entergy 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 or schedule, or need for relief / relaxation and the basis, if any.

2. Milestone Accomplishments The following milestone(s) have been completed since July 31, 2013, and are current as of January 31, 2014:

" First Six-Month Status Report - August 2013

• Second Six-Month Status Report - Complete with submission of this document in February 2014.

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.

" The target completion date for the Develop Mods milestone has been revised from December 2013 to March 2014. This new milestone target date does not impact the Order implementation date.

" The target completion date for the Implement Non-Outage Mods milestone has been revised from December 2016 to March 2015. This new milestone target date does not impact the Order implementation date.

Target Revised Target Milestone Completion Activity Status Completion Date* Date Submit 60 Day Status Report Oct. 2012 Complete Submit Overall Integrated Feb. 2013 Complete Implementation Plan Submit Six-Month Status Report Aug. 2013 Complete Develop Mods Dec. 2013 Started March 2014 Develop Strategies (Playbook) with Oct. 2014 Not started Regional Response Center Purchase/Procure Equipment April 2014 Started Submit Six-Month Status Report Feb. 2014 Complete Issue FLEX Procedures May 2014 Started Create Maintenance Procedures May 2014 Started Submit Six-Month Status Report Aug. 2014 Not Started Page 1 of 6

Target Revised Target Milestone Completion Activity Status Completion Date Date Procedure Changes Training Material June 2014 Not started Complete Develop Training Plan June 2014 Not started Submit Six-Month Status Report Feb. 2015 Not Started Implement Training Dec. 2014 Not started Submit Six-Month Status Report Aug. 2015 Not Started Submit Six-Month Status Report Feb. 2016 Not Started Submit Six-Month Status Report Aug. 2016 Not Started Implement Non-Outage Mods Dec. 2016 Not Started March 2015 Validation / Demonstration Dec. 2016 Not Started Submit Completion Report Dec. 2016 Not Started Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status report.

4. Changes to Compliance Method During the design phase of the RBS FLEX project, changes were identified to the compliance strategies as described in the Overall Integrated Plan (Reference 1). The changes are summarized below. The changes will be incorporated into a revised OIP, which will be included within a subsequent six-month status report.

" On pages 19, 20, and 50 of 60 of the RBS OIP, the FLEX2 pump is described as an electric motor-driven portable pump. The FLEX2 pump has been changed to a diesel-powered portable pump. This was necessary because portable electric motor-driven pumps are not a normal commercially available item.

" The capacities of the FLEX portable diesel generators (PDG) designated to power the FLEX1 pump and the SPC Pump 1A or 1B, which were preliminarily sized to be 200kW generators in the OIP (pages 19, 20 and 50), have been changed to 500kW. This was the result of generator sizing analysis, which determined the critical performance requirements for the portable generators.

" The FLEX Phase 3 strategy for core cooling and containment integrity as described on pages 25 and 34 of the OIP has been revised. The original primary Phase 3 strategy utilizes RHR in shutdown cooling mode powered from an RRC PDG connected to the Division 2 safety related 4160V bus. The alternate strategy utilized direct electrical power connections from an RRC PDG to components (e.g., RHR pump, etc.) for powering RHR in shutdown cooling mode. The new primary strategy for core cooling and maintaining containment integrity is continued operation of the Phase 2 approach using SPC equipment. The use of SPC as the primary method of core cooling is acceptable as evaluated in FLEX design calculations. The original primary strategy of operating RHR in shutdown cooling mode powered from a 4160V RRC PDG connected to the Division 2 safety related bus is now the alternate Phase 3 core cooling and containment integrity strategy.

" A discussion of the ability of the SSW cooling tower, without powered fans, to provide adequate heat removal well into Phase 3 is included on OIP page 21 of 60. A discussion of Page 2 of 6

repowering the Division 2 SSW basin fans via repowering ENS-SWG01B 4160V bus by a RRC PDG for the original Phase 3 strategy is provided on OaP page 25 of 60. FLEX design calculations have determined that repowering the Division 2 cooling towers is necessary at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the ELAP. Due to the revision of the Phase 3 strategy, this will be accomplished by use of an RRC 800kW 480V PDG connected to 480V MCC ENS-MCC16B. The action to re-power the cooling tower fans will be included as a time constraint in OIP Attachment 1A and in the OIP discussion of time constraints which starts on page 5 of 60 of the OIP. One of the 480V PDGs listed in the BWR Portable Equipment Phase 3 table will be designated for use as the primary power source for the SSW cooling tower fans.

• Makeup to the SSW cooling tower basin is discussed on OIP page 25 of 60. This identifies the need for makeup to the basin, but does not establish the timing of makeup. FLEX design calculations have determined that makeup to the basin is required to be initiated by 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the ELAP. This action will be added as a time constraint in OIP Attachment 1A and in the OIP discussion of time constraints which starts on page 5 of 60.

" The need for evaluation of the seismic robustness of non-safety related class 4 piping located in RBS piping tunnels utilized in the FLEX strategy is identified on pages 20 and 21 of the OIP. The completed evaluation has confirmed that there are a number of pipe lines in the tunnels, including sections that are not considered seismically robust. The evaluation also identified that these piping sections can be isolated by closing five individual valves if the ELAP is initiated by a seismic event. RBS FLEX procedures will include directions to isolate the valves following a seismic event.

" As documented in the OIP, the RBS FLEX strategy was developed based on analysis using the GOTHIC computer code. Following discussions with NRC staff regarding the use of the GOTHIC computer code, Entergy elected to perform a new containment / RCS analysis utilizing the MAAP4 computer code. In developing the new MAAP4 analysis, Entergy will abide by the limitations contained in the NRC's endorsement letter (ADAMS Accession No.:

ML13275A318) of the Nuclear Energy Institute (NEI) position paper dated June 2013, entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession No. ML13190A201). It is anticipated that the results of the new MAAP4 analysis will not result in significant changes to the FLEX strategies described in the OIP.

• While the following is not a change in the compliance strategy described in the OIP, it is a clarification with regard to the RBS FLEX strategy and the guidance of NEI 12-06. NEI 12-06 Section 3.2.2, Consideration 13 states that regardless of installed coping capability, all plants will include the ability to use portable pumps to provide RPV/RCS/SG makeup as a means to provide a diverse capability beyond installed equipment. The RBS FLEX strategy does not include this capability, and thus, the crediting of installed SPC pumps for the RBS FLEX Phase 2 strategy is alternative method for satisfying the NEI 12-06 guidance. The use of the installed SPC pumps to provide RPV makeup is an acceptable alternative to a portable FLEX pump for the transitional phase of FLEX. The guidance states that the ELAP response is to be addressed with a combination of three categories of equipment: installed plant capability, portable on-*ite equipment, and off-site equipment resources. Only one phase of the response is limited to utilizing equipment from just one of the equipment categories. To ensure that there is enough time to deploy and implement portable equipment, Phase 1 can only use installed plant equipment. Even though Phase 2 and Phase 3 will utilize portable equipment (onsite for Phase 2 and offsite from RRC for Phase 3), there is no prohibition against the use of permanently installed equipment in those two phases, as long as it is robust with respect to design basis external events.

Page 3 of 6

5. Need for Relief/Relaxation 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 Interim Staff Evaluation The following tables provide a summary and status of and open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes a listing of Audit Questions and the status of each item.

Overall Integrated Plan Open Items 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.

Interim Staff Evaluation Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an Interim Staff Evaluation for RBS; therefore, there are no open items for the Interim Staff Evaluation identified at this time.

Interim Staff Evaluation Confirmatory Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an Interim Staff Evaluation for RBS; therefore, there are no open confirmatory items for the Interim Staff Evaluation identified at this time.

Audit Questions Status Completion or Target Date RBS-001 Closed RBS-002 Closed RBS-003 Closed RBS-004 In progress February 2014 RBS-005 In progress August 2014 RBS-006 Closed RBS-008 In progress August 2014 RBS-009 In progress February 2014 RBS-01 0 In progress February 2014 RBS-01 1 In progress February 2014 RBS-012 In progress February 2014 RBS-01 3 In progress February 2014 RBS-01 5 Closed RBS-016 In progress February 2014 Page 4 of 6

Audit Questions Status Completion or Target Date RBS-01 8 In progress August 2014 RBS-019 Closed RBS-020 In progress February 2014 RBS-021 In progress August 2014 RBS-022 In progress August 2014 RBS-024 Closed RBS-027 Closed RBS-028 Closed RBS-030 In progress August 2014 RBS-031 In progress August 2014 RBS-032 Closed RBS-033 Closed RBS-034 Closed RBS-035 Closed RBS-037 Closed RBS-039 Closed RBS-045 Closed RBS-046 In progress August 2014 RBS-047 In progress February 2014 RBS-049 Closed RBS-051 Closed RBS-052 Closed RBS-053 Closed RBS-054 Closed RBS-055 In progress February 2014 RBS-056 Closed RBS-057 In progress August 2014 RBS-058 Closed RBS-059 Closed RBS-060 Closed RBS-061 Closed RBS-062 In progress August 2014 RBS-063 Closed RBS-064 Closed

7. Potential Interim Staff Evaluation Impacts The NRC has not yet issued an interim staff evaluation for RBS; therefore, there are no potential impacts to the Interim Staff Evaluation identified 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.

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2. 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.

3. Entergy's Six-Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements ForMitigation Strategies ForBeyond-Design-BasisExternal Events (OrderNumber EA-12-049), RBG-47389, dated August 28, 2013.

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