GNRO-2014/00060, Entergys Third 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
| ML14239A316 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/26/2014 |
| From: | Kevin Mulligan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, GNRO-2014/00060 | |
| Download: ML14239A316 (14) | |
Text
Q
~Entergy GNRO-2014/00060 August 26, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500
SUBJECT:
Entergy's Third 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)
Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
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 (ML12054A735) 2.
Entergy Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27,2013 (GNRO-2013/00015, ML13059A316) 3.
Entergy Letter to NRC, Entergy'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 (GNRO-2013/0060, ML13240A264) 4.
Entergy Letter to NRC, 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), dated February 28,2014 (GNRO-2014/00011, ML14059A080)
GNRO-2014/00060 Page 2 of 3
Dear Sir or Madam:
On March 12, 2012, the Nuclear Regulatory Commission rNRC" 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.
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). References 3 and 4 provided the first and second six-month status reports. The purpose of this letter is to provide the third 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.
This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. James J. Nadeau', Regulatory Assurance Manager, at (601) 437-2103.
I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2014.
Sincerely,
~A KJM/ras
Attachment:
Grand Gulf Nuclear Station's Third 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 AnN: Kriss Kennedy Deputy Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001
GNRO-2014/00060 Page 3 of 3 U. S. Nuclear Regulatory Commission ATTN: Jessica A. Kratchman Mail Stop OWFN/9 02 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment to GNRO-2014/00060 Grand Gulf Nuclear Station's Third 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 GNRO-2014/00060 Page 1 of 10 Grand Gulf Nuclear Station's Third 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 1
Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attach'ment 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 August 20, 2014:
Submit Six-Month Status Report 1 - August 2013 Submit Six-Month Status Report 2 -February 2014 Submit Six-Month Status Report 3 -
Complete with submission of this document in August 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.
Target completion dates have been added to the following milestones for which no dates were previously included:
Perform Staffing Analysis Purchase Procure Develop Strategies / Contract with NSRC Issue GG FSGs Create Maintenance Procedures Procedure Changes Training Material Complete Develop Training Plan Implement Training These milestone target dates do not impact the Order implementation date.
Attachment to GNRO-2014/00060 Page 2 of 10 Target Revised Milestone Completion Activity Target Datet
.Status Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit Six-Month Updates:
Report 1 Aug 2013 Complete Report 2 Feb 2014 Complete Report 3 Aug 2014 Complete Report 4 Feb 2015 Not Started Report 5 Aug 2015 Not Started Report 6 Feb 2016 Not Started Report 7 Deleted Deleted Deleted*
Perform Staffing Analysis Not Started July 2015 Modifications Develop Mods (Design Start)
May 2014 Complete Develop Strategies Nov 2014 Started Develop Mods (Design Complete)
Nov 2014 Not Started Implementation Outage**
Mar 2016 Not Started Implement Mods Mar 2016 Not Started On-site FLEX Equipment Purchase Started Feb 2015 Procure Started Dec 2015 Off-site FLEX Equipment Develop Strategies / Contract with Started July 2015 NSRC Procedures Issue GG FSGs Not Started May 2015 Create Maintenance Procedures Not Started June 2015 Procedure Changes Training Not Started May 2015 Material Complete Training Develop Training Plan Not Started March 2015 Implement Training Not Started Feb 2016
Attachment to GNRO-2014/00060 Page 3 of 10 Target Revised Milestone Completion Activity Target Datet Status Completion Date Validation I Demonstration Mar 2016 Not Started Submit Completion Report Aug 2016 Not Started
- Deleted due to Completion Report being submitted in August 2016.
- Full compliance since second refueling outage is before 12/31/2016.
tTarget Completion Date is the last submitted date from either the overall integrated plan or previous six-month status report.
4 Changes to Compliance Method In preparation for the design phase of the FLEX project at GGNS, changes have been identified to the compliance strategies as described in the original OIP (Reference 1).
The significant changes are described below. The changes will be incorporated into a future or the final OIP update.
The Phase 2 core cooling and containment integrity strategy described on Pages 17 and 31 of the OIP was based on a "feed and bleed" approach with water feeding the reactor via FLEX pumps drawing from the Ultimate Heat Sink (UHS) and the alternate decay heat removal (ADHR) pumps bleeding suppression pool water back to the UHS. Entergy has revised the Phase 2 strategy to a "feed and vent" strategy. The revised strategy maintains feeding coolant to the vessel for core cooling in the same manner, but replaces the bleeding of suppression pool water back to the UHS with venting of steam through the containment vent path.
Neither the ADHR nor the suppression pool makeup systems are used as part of the simplified response for the revised "feed and vent" strategy.
The Phase 2 core cooling discussion on Page 17 of the 01P states that the FLEX pump discharge connection will be made to the High Pressure Core Spray (HPCS) Service Water (SW) piping inside the Standby Service Water (SSW) pump house via connection points on the side of the pump house. The FLEX pump discharge connection will now be made in the seismically qualified, missile protected HPCS SW return line in SSW Valve Room A instead.
The FLEX Phase 3 strategy for core cooling and containment integrity as described on pages 24 and 35 of the OIP has been revised. The original primary Phase 3 strategy utilizes Residual Heat Removal (RHR) in alternate shutdown cooling mode powered from a National SAFER Resource Center (NSRC) portable diesel generator (PDG) connected to the Division 2 safety related 4160V bus and supplying the RHR B heat exchanger with service water from NSRC pumps. NSRC heat removal equipment was to be used to cool the return water from the RHR heat exchanger before being discharged to the UHS. The original alternate strategy maintained the Phase 2 equipment in service using Phase 3 NSRC equipment to cool and makeup to the UHS.
The revised Phase 3 primary strategy for core cooling and maintaining containment integrity is continued operation of the Phase 2 "feed and vent"
Attachment to GNRO-2014/00060 Page 4 of 10 strategy discussed in the first bullet above with offsite equipment used to makeup to the UHS. The plant recovery strategy will continue to rely on operation of RHR powered from a 4160V NSRC PDG connected to the Division 2 safety related bus with NSRC equipment providing service water flow. This will be accomplished by portable equipment and procedures rather than permanent plant modifications. In addition, with the revised Phase 2 strategy no longer reliant on bleeding suppression pool water to the UHS, the safety related, seismically qualified, missile protected SSW cooling towers will be utilized in lieu of NSRC heat removal equipment.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation GGNS 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 and the status of each item.
Overall Integrated Plan Open Items Status 1.
Structure, content and details of the National SAFER Not Started Resource Center (NSRC) Grand Gulf Response Plan will be determined.
Interim Staff Evaluation Open Items Status 3.1.2.A Since the GGNS Probable Maximum This Open Item was Precipitation is greater than the grade elevation addressed in Section and sandbags are needed to protect against 4 of GGNS's second flooding, it is unclear how GGNS can be six month FLEX designated as a "dry" site. Since the licensee status report identified GGNS as a dry site, licensee (Reference 5 of information related to NEI 12-06 guidelines section 8).
identified in this report, Sections 3.1.2.1, 3.1.2.2, and 3.1.2.3 (storage, deployment, and procedural interfaces, respectively) are not discussed. If the resolution of this Open Item results in GGNS not being categorized as a "dry" site, the guidelines of the NEI 12-06 Sections related to these report sections will need to be addressed by the licensee as part of that resolution.
Attachment to GNRO-2014/00060 Page 5 of 10 Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Confirm that the storage facilities and This Confirmatory Item was plans will conform to the guidance in NEI addressed in Section 4 of 12-06, Section 5.3.1, for protection from GGNS's second six month seismic events.
FLEX status report (Reference 5 of section 8) 3.1.3.1.A Confirm that at least one of the two FLEX This Confirmatory Item was equipment storage buildings would not be addressed in Section 4 of damaged by tornado missiles, based on GGNS's second six month the guidance in NEI 12-06, Section 7.3.1.
FLEX status report (Reference 5 of section 8) 3.1.3.2.A Confirm that procedures address UHS In Progress usability when wind generated debris is This item will be addressed present in the UHS.
by update to AQ GGN-052 response when information is available 3.2.1.1.A Confirm that the final Modular Accident In Progress Analysis Program Revision 4 (MAAP4)
This item will be addressed analysis of the RCS response conforms to by update to AQ GGN-019 the NEI position paper dated June 2013, response when information entitled "Use of Modular Accident Analysis is available Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession Number ML13190A201) and the MAAP4 limitations of the NRC endorsement letter, dated October 3, 2013 (ADAMS Accession No. ML13275A318).
3.2.1.2.A Confirm that the MAAP4 analysis includes In Progress appropriate recirculation pump seal This item will be addressed leakage.
by update to AQ GGN-025 response when information is available 3.2.1.3.A Confirm that the final Sequence of Events In Progress (SOE) reflects the results of the final This item will be addressed MAAP4 analysis of the RCS response and by update to AQ GGN-026 the licensee provides reasonable response when information assurance by some means (e.g. by is available walkthrough) that the timing of the actions in the SOE is achievable.
3.2.1.4.A Confirm that operation with the In Progress suppression pool temperature at its This item will be addressed calculated maximum temperature will not by update to AQ GGN-024 impact the mitigation strategies, especially response when information RCIC operation and structural integrity of is available the suppression pool.
Attachment to GNRO-2014/00060 Page 6 of 10 Interim Staff Evaluation Confirmatory Items Status 3.2.1.8.A Confirm that the hydraulic calculations for In Progress the FLEX pumps demonstrate that the This item will be addressed required flow rates can be achieved.
by update to AQ GGN-034 response when information is available 3.2.2.A Confirm that the SFP area ventilation In Progress calculation demonstrates that portable This item will be addressed ventilation is not required in the SFP area, by update to AQ GGN-039 or that theJicensee provides a strategy to response when information use portable ventilation.
is available 3.2.3.A Confirm that the licensee's strategy for In Progress maintaining containment capabilities This item will be addressed considers the results of the final MAAP4 by update to AQ GGN-026 analysis for RCS leakage and the response when information containment venting strategy.
is available 3.2.4.2.A Confirm that the RCIC room heat up In Progress calculation for ELAP uses appropriate heat This item will be addressed loads and shows an acceptable room by update to AQ GGN-045 temperature.
response when information is available 3.2.4.4.A Confirm that any required upgrades to the NRC Confirmatory Action site's communications systems have been completed, as noted in the NRC's review of the GGNS communications assessment (ADAMS Accession No. ML13129A132).
3.2.4.8.A Confirm that the licensee's analyses for In Progress size and loading of FLEX generators This item will be addressed shows acceptable results.
by update to AQ GGN-034 response when information is available 3.2.4.8.8 Confirm that the licensee's final proposed In Progress connections of FLEX Phase 2 and 3 This item will be addressed electrical equipment to the permanent by update to AQ GGN-053 plant equipment are acceptable.
response when information is available 3.2.4.9.A Confirm that the licensee has plans to In Progress refuel FLEX equipment based on the fuel This item will be addressed oil consumption rates.
by update to AQ GGN-055 response when information is available 3.2.4.10.A Confirm the acceptability of RCIC operation In Progress without the gland seal compressor (de-This item will be addressed energized 30 minutes after loss of all ac
Attachment to GNRO-2014/00060 Page 7 of 10 Interim Staff Evaluation Confirmatory Items Status power).
by update to AQ GGN-072 response when information is available 3.2.4.10.B Confirm that the calculations regarding In Progress battery sizing which show that Vital This item will be addressed Batteries can provide required loads for at by update to AQ GGN-031 least 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> (considering load shedding) response when information are acceptable.
is available Audit Status Completion or Questions Target Date GGN-001 In Progress - This AQ response will be updated Feb 2015 when information is available In Progress - This AQ response will be updated GGN-002 when information is available (ISE Confirmatory Feb 2015 Item 3.1.1.1.A)t In Progress - This AQ response will be updated GGN-003 when information is available (ISE Confirmatory Feb 2015 Item 3.1.3.1.A)
GGN-005 Closed*
GGN-007 Closed*
GGN-008 Closed*
GGN-010 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-011 Closed*
GGN-012 Closed*
GGN-013 Closed*
GGN-014 Closed*
GGN-015 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-016 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-017 In Progress-This AQ response will be updated Feb 2015 when information is available In Progress - This AQ response will be updated GGN-019 when information is available (ISE Confirmatory Feb 2015 Item 3.2.1.1.A)
GGN-021 Closed*
Attachment to GNRO-2014/00060 Page 8 of 10 Audit Status Completion or Questions Target Date GGN-022 Closed*
GGN-023 Closed*
In Progress - This AQ response will be updated GGN-024 when information is available (ISE Confirmatory Feb 2015 Item 3.2:1.4.A)
In Progress - This AQ response will be updated GGN-025 when information is available (ISE Confirmatory Feb 2015 Item 3.2.1.2.A)
In Progress - This AQ response will be updated GGN-026 when information is available (ISE Confirmatory Feb 2015 Items 3.2.1.3.A and 3.2.3.A) t GGN-028 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-029 Closed*
GGN-030 Closed*
In Progress - This AQ response will be updated GGN-031 when information is available (ISE Confirmatory Feb 2015 Item 3.2.4.10.8)
In Progress - This AQ response will be updated GGN-034 when information is available (ISE Confirmatory Feb 2015 Items 3.2.1.8.A and 3.2.4.8.A)
GGN-036 Closed*
GGN-038 Closed*
In Progress - This AQ response will be updated GGN-039 when information is available (ISE Confirmatory Feb 2015 Item 3.2.2.A)
GGN-040 Closed*
GGN-041 Closed*
GGN-042 Closed*
GGN-043 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-044 Closed*
In Progress - This AQ response will be updated GGN-045 when information is available (ISE Confirmatory Feb 2015 Item 3.2.4.2.A)
GGN-046 In Progress - This AQ response will be updated Feb 2015 when information is available
Attachment to GNRO-2014/00060 Page 9 of 10 Audit Status Completion or Questions Target Date GGN-047 Closed*
GGN-048 Closed*
GGN-050 Closed*
In Progress - This AQ response will be updated GGN-052 when information is available (ISE Confirmatory Feb 2015 Item 3.1.3.2.A)t In Progress - This AQ response will be updated GGN-053 when information is available (ISE Confirmatory Feb 2015 Item 3.2.4.8.8)
In Progress - This AQ response will be updated GGN-055 when information is available (ISE Confirmatory Feb 2015 Item 3.2.4.9.A)
GGN-057 Closed*
GGN-058 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-061 Closed*
GGN-062 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-063 Closed*
GGN-064 In Progress - This AQ response will be updated Feb 2015 when information is available GGN-065 Closed*
GGN-066 Closed*
GGN-067 Closed*
GGN-071 In Progress - This AQ response will be updated Feb 2015 when information is available In Progress - This AQ response will be updated GGN-072 when information is available (ISE Confirmatory Feb 2015 Item 3.2.4.1 O.A)t
- Closed indicates that Entergy's response is complete.
tOuestion status changed to "in progress" due to potential impact of the associated ISE confirmatory item.
7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except those identified in Section 4.
Attachment to GNRO-2014/00060
. Page 10 of 10 8
References The following references support the updates to the Overall Integrated Plan described in this Attachment.
1.
"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 27,2013 (GNRO-2013/00015, ML13059A316).
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 (ML12054A735).
3.
Entergy Letter to NRC, Entergy'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 (GNRO-2013/0060, ML13240A264).
4.
NRC Letter, "Grand Gulf Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
(TAC No. MF0954)," dated February 19, 2014 (ML14007A718).
5.
Entergy Letter to NRC, Entergy's Second Six-Month Status ReportJn 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 28,2014 (GNRO-2014/00011, ML14059A080).