ML14069A320

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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)
ML14069A320
Person / Time
Site: Pilgrim
Issue date: 02/28/2014
From: Dent J
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML14069A320 (14)
v • d • e


Text

SEntergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.

Site Vice President February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station'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)

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER 2.14.011

REFERENCE:

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", dated March 12, 2012 (PNPS Letter 1.12.013)
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 (ML12229A174)
3. Nuclear Energy Institute (NEI) 12-06, Revision 0, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", dated August 2012
4. Pilgrim Nuclear Power Station Letter to NRC, "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)",

dated October 29, 2012 (PNPS Letter 2.12.072)

5. Pilgrim Nuclear Power Station Letter to NRC, "Overall Integrated Plan 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)", dated February 28, 2013 (PNPS Letter 2.13.012)
6. NRC Order Number EA-12-050, "Order to Modify Licenses With Regard To Reliable Hardened Containment Vents", dated March 12, 2012 (PNPS Letter 1.12.014)

PNPS Letter 2.14.011 Page 2 of 4

7. NRC Order Number EA-13-109, "Order to Modify Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions", dated June 6, 2013 (PNPS Letter 1.13.028)
8. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's First 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)" dated August 28, 2013 (PNPS Letter 2.13.069)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an Order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy 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 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 Pilgrim Station initial status report regarding mitigation strategies. Reference 5 provided the Pilgrim 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 8 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 attached 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.

The FLEX strategies in the Overall Implementation Plan presently rely on the current conceptual design of the reliable hardened vent (RHV) system that was developed in response to Reference 6, NRC Order EA-12-050. Reference 7, NRC Order EA-13-109, dated June 6, 2013, rescinds the requirements of NRC Order EA-12-050. Compliance with the requirements of NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required. The industry, through NEI and the owners' group, is addressing the new requirements provided in NRC Order EA 109 on the schedule outlined in NRC Order EA-1 3-109. Because of the new order (NRC Order EA-1 3-109), the design of the hardened containment vent is being reevaluated. Any design changes resulting from the revised hardened vent order will be reflected in a future six month status report.

PNPS Letter 2.14.011 Page 3 of 4 Should you have any questions concerning the content of this letter, please contact Mr.

Joseph R. Lynch, Manager, Regulatory Assurance at (508) 830-8403.

This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014.

Sincerely, J hn A. Dent Jr.

AD/rmb

Attachment:

Pilgrim Nuclear Power Station'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) cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Washington, DC 20555-0001 Ms. Nadiyah Morgan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555

PNPS Letter 2.14.011 Page 4 of 4 Mr. John Giarrusso Jr.

Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 U. S. Nuclear Regulatory Commission Attn: Robert J. Fretz Jr.

OWFN, Mailstop # 4A1 5A 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 U. S. Nuclear Regulatory Commission Attn: Ms. Jessica A. Kratchman OWFN, Mailstop # 9D2 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Eric E. Bowman OWFN, Mailstop # 12D20 11555 Rockville Pike Rockville, MD 20852-2378 NRC Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT To PNPS Letter 2.14.011 PILGRIM NUCLEAR POWER STATION'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)

Attachment to PNPS Letter 2.14.011 Attachment Pilgrim Nuclear Power Station'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)

1. Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Pilgrim Nuclear Power Station (PNPS), documenting 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 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.
  • No new additions or changes to target completion dates for this report.

Page 2 of 10

Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Revised Target Milestone Completion Activity Status Target Date* Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Submit Six-Month Status Report August 2013 Complete Submit Six-Month Status Report February 2014 Complete Modifications Approved for February 2014 In Progress Implementation Develop Training Plan March 2014 Not Started Submit Six-Month Status Report August 2014 Not Started Procedure Changes Training Material October 2014 Not Started Complete Submit Six-Month Status Report February 2015 Not Started Implement Training (Schedule LORT March 2015 Not Started Plan to Support Implementation)

Modification Implementation Complete May 2015 Not Started Demonstration / Functional Test June 2015 Not Started Submit Six-Month Status Report August 2015 Not Started Submit Completion Report December 2015 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 There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).
5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PNPS 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 any 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 which require additional information for complete closure.

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Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 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.

Interim Staff Evaluation Open Items Status 3.2.1.4.A- On pages 16, 23, and 63 of the Integrated Pilgrim calculation M1384, Rev. 0 Plan regarding Portable Equipment to Maintain Core documents the plant hydraulic Cooling, the licensee describes the use of portable analysis that incorporates the pumps to provide RPV injection. No technical basis or a plant FLEX design modifications supporting analysis was provided for the diesel-driven and the use of two diesel-driven FLEX pump capabilities considering the pressure within pumps as described in the the RPV and the loss of pressure along with details Integrated Plan.

regarding the FLEX pump supply line routes, length of hoses runs, connecting fittings, and elevation changes to The approval of this calculation is show that the pump is capable of injecting water into the pending based on the approval of RPV with a sufficient rate to maintain and recover core EC 45558, which is used for inventory for both the primary and alternate flow paths. calculation input.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1 .A- The Integrated Plan does not specify In Progress procedures and programs will provide for securing large portable equipment to protect them during a seismic event or to ensure unsecured and/or non-seismic components do not damage the equipment as is specified in NEI 12-06, Section 5.3.1, considerations 2 and 3.

3.1.1.2.A - The licensee identified that access to at In Progress least one connection point for the equipment will requires access through routes that are not FSAR Seismic Class I, however they have been evaluated and the potential for large scale debris field that would prevent access to the equipment needed to be repowered is not present. Their evaluation should be validated during the site audit.

3.1.1.3.A - The licensee was requested to provide - In Progress additional information concerning coping strategies for the failure of seismically qualified electrical equipment that can be affected by beyond-design-basis seismic events as discussed in NEI 12-06, Section 5.3.3 consideration 1.

Page 4 of 10

Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Interim Staff Evaluation Confirmatory Items Status 3.1.3.1.A - The storage of the FLEX equipment is in In Progress sea vans. The licensee is in the process of performing a calculation to demonstrate conformance with NEI 12-06, Section 7.3.1.b, bullet 4 related to adequate tie down of the sea vans. Evaluation of the completed calculation must be completed to determine if it demonstrates conformance to guidance in NEI 12-06, Section 7.3.1.b, bullet 4.

3.1.3.2.A - During the audit process, the licensee In Progress identified that there are existing plant procedures that address hurricanes. The procedures need to be evaluated for conformance to NEI 12-06, considerations 1, 2, and 5.

3.2.1.1.A- From the June 2013 position paper, In Progress benchmarks must be identified and discussed which demonstrate that the Modular Accident Analysis Program (MAAP) 4 is an appropriate code for the simulation of an Extended Loss of AC Power (ELAP) event at your facility.

3.2.1.1.B -The collapsed level must remain above Top In Progress of Active Fuel (TAF) and the cool down rate must be within technical specification limits.

3.2.1.1 .C - MAAP4 must be used in accordance with In Progress Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.

3.2.1.1 .D -- In using MAAP4, the licensee must identify In Progress and justify the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1 020236). This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant.

3.2.1.1 .E -The specific MAAP4 analysis case that was In Progress used to validate the timing of mitigating strategies in the integrated plan must be identified and should be available on the ePortal for NRC staff to view.

Alternately, a comparable level of information may be included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within tech spec limits.

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Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Interim Staff Evaluation Confirmatory Items Status 3.2.1.2.A -The following is requested: In Progress

1. Justification for the assumptions made regarding primary system leakage from the recirculation pump seals and other sources.
2. Assumed pressure-dependence of the leakage rate.
3. Clarification on whether the leakage was determined or assumed to be single-phase liquid, two-phase mixture, or steam at the donor cell and discuss how mixing of the leakage flow with the drywell atmosphere is modeled.

3.2.1.5.A - The integrated plan does not identify non- In Progress powered local instrumentation other than Containment pressure and RPV level and pressure. The integrated plan identifies that phase 2 equipment will have installed local instrumentation needed to operate the equipment.

The licensee needs to identify the instrumentation that will be used to monitor portable FLEX electrical power equipment.

3.2.4.2.A - The licensee was requested to provide the In Progress maximum calculated MCR temperature and a detailed summary of the analysis used to determine the temperature and the procedure for control of MCR temperature. The licensee response was that existing procedure 2.4.149 addresses "Loss of MCR H&V". The procedure is symptom driven, containing temperature limits to perform actions, and it is not time driven. Pilgrim will provide the referenced "GOTHIC" evaluation.

Evaluation of the "GOTHIC" analysis is needed to evaluate the MCR temperature.

3.2.4.4.A - The licensee needs to provide complete In Progress details of portable lighting.

3.2.4.4.B - The licensee provided its communications In Progress assessment in letters dated October 31, 2012 and February 21, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML12321A051 and ML13058A032) in response to the NRC letter dated March 12, 2012, 50.54(f) request for information letter. The NRC staff provided its evaluation on May 21, 2013 (ADAMS Accession No. ML13127A179). The NRC staff has determined that the assessment for communications is reasonable, and the analyzed existing systems, proposed enhancements, and interim measures will help to ensure that communications are maintained. This has been identified for confirmation that upgrades to the site's Page 6 of 10

Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Interim Staff Evaluation Confirmatory Items Status communications systems have been completed.

3.2.4.5.A - The Integrated Plan does not identify In Progress procedures/guidance with regard to the access to the Protected Area and internal locked areas. During the audit process, the licensee identified existing security doors that provide egress capability and have key access in the event of a power loss. Operations and Security are currently researching options, the intention is to include it in the Emergency procedures addressing DDBEE perimeters, the site declaration of 50.54(x), and recognizing resource needs, including Security, and compensatory measures based on the event.

3.2.4.8.A - During the audit process, the licensee was Markup of one-line diagrams E13 requested to provide electrical Single Line Diagrams and E14Sh1 was provided on the showing the proposed connections of Phase 2 and 3 Entergy ePortal 10/07/2013 (Audit electrical equipment to permanent plant equipment. The Question PNPS-066).

licensee responded that Engineering Change markup of the One-Line Diagrams E13 and E14Shl (EC45555 &

EC45556), will be posted to the ePortal. The NRC staff will complete the review after they are posted.

3.2.4.8.B - During the audit process, the licensee In Progress identified Engineering Changes are being developed to support the FLEX project which requires electrical studies to be performed. This includes the electrical diesel loading and load flow studies. The addition of the transfer switches and additional cable lengths are being incorporated into the Pilgrim design calculations (load flow, short circuit and coordination.) The FLEX diesel generator sizes need to be verified after the loading calculations are finalized.

3.2.4.10.A- Attachment 1 A of the Integrated Plan In Progress notes that at one hour, the ELAP decision is made and deep dc load shedding begins at one hour (item 3), and at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the dc load shed is complete (item 4). The licensee was requested to provide the dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool cooling. During the audit process, the licensee responded that the dc load flow profiles are being developed as part of a new electrical battery FLEX extended operation load flow and battery sizing study PS258.

3.2.4.10.B - The licensee was requested to provide a In Progress detailed discussion on the loads that will be shed from the dc bus, the equipment location (or location where the required action needs to be taken). During the audit Page 7 of 10

Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Interim Staff Evaluation Confirmatory Items Status process, the licensee responded by identifying that a tentative list of loads proposed to isolate, isolation time and panel locations are available and provided in the ePortal. The licensee will finalize the load-shed list after a review by Operations.

3.4.A - The licensee's plans for the use of off-site In Progress resources did not address considerations 2 through 10 of NEI 12-06, Section 12.2.

Audit Questions Status Completion or Target Date PNPS-002 Closed PNPS-003 Closed PNPS-004 Closed PNPS-006 Closed PNPS-007 Closed PNPS-008 Closed PNPS-009 In progress August 2014 PNPS-010 Closed PNPS-01 1 Closed PNPS-012 Closed PNPS-014 Closed PNPS-015 In progress August 2014 PNPS-016 In progress August 2014 PNPS-017 In progress August 2014 PNPS-018 Closed PNPS-019 In progress August 2014 PNPS-020 Closed PNPS-021 Closed PNPS-022 Closed PNPS-024 Closed PNPS-025 Closed PNPS-026 In progress August 2014 PNPS-027 Closed PNPS-030 Closed PNPS-032 Closed PNPS-033 In progress August 2014 PNPS-034 Closed PNPS-035 Closed PNPS-036 Closed PNPS-037 Closed PNPS-038 Closed PNPS-039 Closed PNPS-040 Closed Page 8 of 10

Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Audit Questions Status Completion or Target Date PNPS-042 Closed PNPS-043 Closed PNPS-044 Closed PNPS-046 Closed PNPS-047 In progress August 2014 PNPS-049 Closed PNPS-053 Closed PNPS-054 In progress August 2014 PNPS-055 In progress August 2014 PNPS-056 Closed PNPS-057 In progress August 2014 PNPS-058 Closed PNPS-059 Closed PNPS-060 Closed PNPS-065 In progress August 2014 Markup of one-line diagrams E13 PNPS-066 Complete and E14Shl provided on the Entergy ePortal 10/07/2013 PNPS-067 Closed PNPS-068 Closed PNPS-070 Closed PNPS-071 Closed

7. Potential Interim Staff Evaluation Impacts Entergy has reviewed the Pilgrim FLEX ISE (Reference 6) and identified one topic in the Technical Evaluation Report (TER) that requires clarification. A summary is provided below.

TER Section 3.2.1.1, Page 24 of 63 - The second paragraph of this section includes a statement that the Sequence of Events (SOE) "is based on an analysis using the industry-developed MAAP Version 4 computer code." The third paragraph includes a similar statement: "The licensee has decided to use the MAAP4 computer code for simulating the ELAP event." These statements should be clarified. As previously discussed during the audit process, Entergy stated that the Pilgrim SOE is based on a conservative simplified heat balance calculation rather than a MAAP analysis. A MAAP analysis was also performed. This analysis was considered a validation of the simplified calculation because the MAAP results were more favorable. Even though the MAAP results were more favorable, Entergy uses the more conservative simplified calculation as the basis for the FLEX strategy. Entergy does plan to revise the Pilgrim MAAP analysis in order to address the generic MAAP concerns. The revision will be performed in accordance with the NRC staff endorsement (Reference 7) of NEI's position paper on MAAP (Reference 8). The results of the analysis will be made available on the Entergy ePortal by the next six-month status report (August 2014).

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Attachment to PNPS Letter 2.14.011 PNPS's Second Six Month Status Report for the Implementation of FLEX February 28, 2014

8. References The following references support the updates to the Overall Integrated Plan described in this enclosure.
1. Pilgrim Nuclear Power Station's "Overall Integrated Plan 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)," dated February 28, 2013.
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.
3. NRC Order Number EA-12-050, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents, dated March 12, 2012.
4. NRC Order Number EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.
5. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's First 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)" dated August 28, 2013 (PNPS Letter 2.13.069).
6. NRC Letter, "Pilgrim Nuclear Power Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No.

MF0777)," dated December 16, 2013.

7. NRC Letter to NEI (ML13275A318), dated October 3, 2013.
8. "Use of Modular Accident Analysis Program (MAAP4) in Support of Post-Fukushima Applications," Report No. 3002001785, EPRI, June 2013 (ML13190A201).

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