RBG-47502, 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)

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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)
ML14253A210
Person / Time
Site: River Bend Entergy icon.png
Issue date: 08/28/2014
From: Olson E
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RBG-47502
Download: ML14253A210 (14)
v • d • e


Text

Entergy Operations, Inc.

River Bend Station

'Enterigy 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4374 Eric W. Olson Site Vice President RBG-47502 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

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)

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

REFERENCES:

1. NRC Order Number EA-1 2-049, 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 for Beyond-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 (Order Number 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 (Order Number 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 for Beyond-Design-Basis External Events (Order Number EA-12-049), RBG-47389, dated August 28, 2013.
7. 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), RBG-47445, dated February 26, 2014. .'J I4I~(

RBG-47502 August 28, 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 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 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. References 6 and 7 provided the first and second six-month status report, respectively. 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 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 - Regulatory Assurance, at 225-381-4177.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 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-47502 August 28, 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 Louisiana Department of Environmental Quality ATTN: Ji Young Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 U. S. Nuclear Regulatory Commission ATTN: Alan Wang Mail Stop OWFN 8B1 11555 Rockville Pike Rockville, MD 20852-2378 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: John Hughey Mail Stop OWFN 13C5 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Bo Pham Mail Stop OWFN 13F15 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Carla Roque-Cruz Mail Stop OWFN 13F15 11555 Rockville Pike Rockville, MD 20852-2378 (continued)

RBG-47502 August 28, 2014 Page 4 of 4 U. S. Nuclear Regulatory Commission ATTN: Eric Bowman Mail Stop OWFN/12D20 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Jeremy Bowen Mail Stop OWFN 13F15 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Stewart Bailey Mail Stop OWFN 10A1 11555 Rockville Pike Rockville, MD 20852-2378

Attachment to RBG-47502 (9 pages)

River Bend 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 RBG-47502 August 28, 2014 River Bend 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 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 January 31, 2014, and are current as of July 31, 2014:

" Second Six-Month Status Report - February 2014.

  • Third Six-Month Status Report - 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 Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Implementation Submit Six-Month Status Report Aug 2013 Complete Develop Mods Dec 2013 Complete Develop Strategies (Playbook) with Oct 2014 Started National SAFER Response Center Purchase/Procure Equipment Apr 2014 Started October 2014 Submit Six-Month Status Report Feb 2014 Complete Develop FLEX Procedures May 2014 Complete Create Maintenance Procedures May 2014 Not Started December 2014 Submit Six-Month Status Report Aug 2014 Complete Page 1 of 9

Attachment RBG-47502 August 28, 2014 Target Revised Target Milestone Completion Activity Status Completion Date Date Procedure Changes Training Material Jun 2014 Complete Complete Develop Training Plan Jun 2014 Complete Submit Six-Month Status Report Feb 2015 Not Started Implement Training Dec 2014 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 Mar 2015 Started 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 future update.

The descriptions of storage and protection of equipment in the OIP erroneously referenced NEI 12-06 Section 11. Section 11 is related to programmatic controls. Therefore, the descriptions are revised to reflect the following.

Seismic RBS will have two pre-engineered metal buildings which will be designed for seismic per NEI 12-06, Section 5.3.1.1.b (ASCE 7-10 and local building codes). Soil borings were taken and a geotechnical report generated to determine the appropriate foundation system and to ensure that soil liquefaction will not be an issue under either building. Soil borings were also taken along the primary travel path from each building to the deployment locations to ensure that at least one pathway will not be susceptible to soil liquefaction, which satisfies NEI 12-06, Section 5.3.2.1 for soil liquefaction.

Flooding Both storage buildings will be located above the flood elevation to satisfy NEI 12-06, Section 6.2.3 Consideration 1.a.

Page 2 of 9

Attachment RBG-47502 August 28, 2014 Severe Storms with High Winds Both storage buildings are designed in accordance with NEI 12-06, Section 7.3.1.1.c (ASCE 7-10 and local building codes) to address high winds. Additionally, to provide reasonable assurance that at least one of the storage buildings would not be damaged by tornado missiles, the two buildings are separated by 2,700 feet on a North-South axis that is approximately perpendicular to the axis of the predominant path for tornadoes in the area of the site. The separation distance is based on an evaluation of historical tornado data for the region immediately surrounding the RBS site.

Snow, Ice, and Extreme Cold The storage buildings will be designed to meet NEI 12-06, Section 8.3.1. 1.b (ASCE 7-10 and local building codes) for ice. The site's design basis temperature will be used for the extreme cold considerations. Local block heaters, water jackets, etc. may be provided for equipment such that the entire storage building will not have to be heated.

High Temperatures The storage buildings will be designed to maintain the inside temperature within the FLEX equipment manufacturers' recommended storage temperatures to satisfy NEI 12-06, Section 9.3.1.

The method for providing makeup to the RBS ultimate heat sink (UHS) is described on page 25 of 60 of the Overall Integrated Plan (Reference 1). The original method was to haul water from the Mississippi River using trucks provided by the NSRC (formerly RRC).

Entergy has now determined that the NSRC will not supply the means for providing makeup to the UHS. Therefore, RBS plans to amend an existing supplier contract to include FLEX support. For FLEX events, the contractor will provide 20,000 gallons of makeup water per hour by truck beginning at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the initiating event. The contractor will also install a pump and hard 12-inch pipeline from the Mississippi River to the UHS. The makeup by truck will continue until the pump and pipeline are functioning.

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 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. Beyond-design-basis external event impact on requirements in Entergy has determined existing licensing documents will be determined based on input from that no FSAR changes the industry groups and direction from the NRC. are required to reflect FLEX.

Page 3 of 9

Attachment RBG-47502 August 28, 2014 Overall Integrated Plan Open Items Status

2. Structure, content and details of the Regional Response Center In progress playbook will be determined.

Interim Staff Evaluation Open Items Status None I Interim Staff Evaluation Confirmatory Items Status 3.1.3.1 .A Confirm that the 2,700 foot separation distance between Addressed by FLEX storage facilities will be sufficient to ensure that that a updated AQ RBS-001 single tornado would not impact both locations when response considering the local tornado data, the actual separation distance and axis.

3.2.1.1.A Confirm that benchmarks are identified and discussed which Addressed by demonstrate that Modular Accident Analysis Program updated AQ RBS-009 (MAAP) is an appropriate code for the simulation of an response ELAP event at RBS, consistent with the NRC endorsement (ADAMS Accession No. ML13275A318} of the industry position paper on MAAP.

3.2.1.1.B Confirm that the collapsed RPV level remains above Top of Addressed by Active Fuel and the reactor coolant system cool down rate is updated AQ RBS-012 within technical specifications limits, response 3.2.1.1.C Confirm that MAAP is used in accordance with Sections 4.1, Addressed by 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper updated AQ RBS-010 (ADAMS Accession No. ML13190A201}. response 3.2.1.1.D Confirm that, in using MAAP, the subset of key modeling Addressed by parameters cited from Tables 4-1 through 4-6 of the "MAAP updated AQ RBS-01 1 Application Guidance, Desktop Reference for Using MAAP response Software, Revision 2" (Electric Power Research Institute Report 1020236, available at www.epri.com). 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 RBS.

3.2.1.2.A Confirm that the details of the seal qualification tests, the Addressed by seal leakage rate models, and supporting test data and any updated AQ RBS-013 conservative margin support the 66 gallons per minute response recirculation pump seal leakage assumed in the ELAP analysis.

Page 4 of 9

Attachment RBG-47502 August 28, 2014 Interim Staff Evaluation Confirmatory Items Status 3.2.1.4.A Confirm that the seismic evaluation of SPC system Addressed by components, the spent fuel pool cooling piping, and the updated AQ RBS-003 battery bus crosstie electrical cabinet used to support FLEX and RBS-056 coping strategies, are completed with acceptable results. responses 3.2.1.4.B Confirm that the allowable minimum system pressure Addressed by required to open the SRVs in relation to the RPV pressure, updated AQ RBS-061 during the depressurization and the RPV fill evolution, is response adequately determined.

3.2.1.4.C Confirm that the stresses associated with passing liquid Addressed in updated phase water through the SRV tail pipe, including those on AQ response the tail pipe, the tail pipe supports, the quencher and the spreadsheet on quencher supports are evaluated with acceptable results. ePortal 3.2.1.7.A Confirm the ability to supply cooling water to the upper Addressed by containment pool when it is being used for fuel storage updated AQ RBS-64 during refueling. This capability should be consistent with response the NEI paper entitled "Shutdown/Refueling Modes" (ADAMS Accession No. ML13273A514), which has been endorsed by the NRC in a letter dated September 30, 2013 (ADAMS Accession No. ML13267A382), and which the licensee has indicated will be followed.

3.2.1.8.A Confirm the acceptability of the alternate approach for use Addressed by of the installed SPC pumps for RPV makeup. Specifically, updated AQ RBS-061 confirm the ability of the backup portable pump's capacity to response and white provide both RPV injection and makeup water to the SFP paper uploaded to concurrently. ePortal on 6/4/2014.

3.2.3.A Confirm that the licensee completes an acceptable MAAP Addressed by analysis to demonstrate that containment functions are updated AQ RBS-013 maintained in all phases of an ELAP, with particular regard response to the qualification of drywell penetrations and seals at elevated temperatures.

3.2.3.B Confirm that the 209 degrees Fahrenheit suppression pool Addressed by temperature reached in the ELAP event (which is over the updated AQ RBS-054 185 degrees Fahrenheit design limit) does not adversely response impact the structural integrity of the containment.

3.2.4.4.A Confirm that any planned changes described in the NRC's In progress.

communications assessment (ADAMS Accession No. ML13130A068) are completed.

3.2.4.8.A Confirm that supporting analyses related to the final Addressed by size/loading of FLEX generators is completed with updated AQ RBS-049 acceptable results. response Page 5 of 9

Attachment RBG-47502 August 28, 2014 Interim Staff Evaluation Confirmatory Items Status 3.2.4.10.A Confirm that the final minimum dc bus voltage is determined Addressed by as part of the evaluation of an acceptable battery and de updated AQ RBS-047 loading profile for the ELAP event, response 3.4.A Confirm that the licensee has fully addressed the provisions Addressed in updated of NEI 12-06, Sections 5.3.4, 6.2.3.4, 7.3.4, 8.3.4, and 12.2, AQ response regarding considerations in using offsite resources. spreadsheet on ePortal Audit Status Completion or Target Questions Date RBS-001 Updated response available on ePortal (ISE Confirmatory Item 3.1.3.1.A)

RBS-002 Closed*

RBS-003 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.4.A)

RBS-004 Updated response available on ePortal RBS-005 Updated response available on ePortal RBS-006 Closed*

RBS-008 Updated response available on ePortal Updated response available on ePortal (ISE Confirmatory RBS-009 Item 3.2.1.1.A)

RBS-010 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.1.C)

RBS-01 1 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.1.D)

RBS-012 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.1.B)

RBS-013 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.2.A and ISE Confirmatory Item 3.2.3.A)

RBS-015 Updated response available on ePortal RBS-016 Updated response available on ePortal RBS-018 Updated response available on ePortal RBS-019 Closed*

RBS-020 Closed*

RBS-021 Updated response available on ePortal RBS-022 Updated response available on ePortal Page 6 of 9

Attachment RBG-47502 August 28, 2014 Audit Status Completion or Target Questions Date RBS-024 Updated response available on ePortal RBS-027 Closed*

RBS-028 Closed*

RBS-030 Updated response available on ePortal RBS-031 Updated response available on ePortal RBS-032 Updated response available on ePortal RBS-033 Updated response available on ePortal RBS-034 Closed*

RBS-035 Closed*

RBS-037 Closed*

RBS-038 Closed*

RBS-045 Closed*

RBS-046 Updated response available on ePortal RBS-047 Updated response available on ePortal (ISE Confirmatory Item 3.2.4.10.A)

RBS-049 Updated response available on ePortal (ISE Confirmatory Item 3.2.4.8.A)

RBS-051 Closed*

RBS-052 Closed*

RBS-053 Closed*

RBS-054 Updated response available on ePortal (ISE Confirmatory Item 3.2.3.B)

RBS-055 Updated response available on ePortal RBS-056 Updated response available on ePortal (ISE Confirmatory Item 3.2.1.4.A)

RBS-057 Updated response available on ePortal RBS-058 Closed*

RBS-059 Closed*

RBS-060 Updated response available on ePortal RBS-061 Updated response available on ePortal (ISE Confirmatory Items 3.2.1.4.B and 3.2.1.8.A)

RBS-062 Updated response available on ePortal RBS-063 Closed*

Page 7 of 9

Attachment RBG-47502 August 28, 2014 Audit Status Completion or Target Questions Date RBS-064 {Item Updated response available on ePortal (ISE Confirmatory 3.2.1.7.A)

  • Closed indicates that Entergy's response is complete.
7. Potential Interim Staff Evaluation Impacts The following item has been identified which has potential impact to the Interim Staff Evaluation (ISE). Items identified in Section 4 of this report and the previous six month status report (Reference 5) also have potential to impact the ISE.
1. Technical Evaluation Report Section 3.2.1.8, Page 43 states "To evaluate the alternate approach, the reviewer notes that RBS included a strategy to use a portable pump for RPV makeup in the strategies developed pursuant to Order EA-02-026, the subsequently imposed license conditions, and 10 CFR 50.54(hh)(2). The extensive damage mitigation procedure, OSP-0066 provides several methods of injecting water into the RPV using a portable pump, FPW-P4, which can also be used for SFP makeup" and "However, the licensee has not provided a discussion of the pump's capacity to provide both RPV injection and makeup water to the SFP concurrently." Confirmatory Item 3.2.1.8.A in Section 4.2, below." These statements imply that RBS is using the 10 CFR 50.54(hh)(2) pump for core cooling in the FLEX strategy. This is not the case. RBS intends to use SPC pumps as described in the OIP for core cooling. See the status of Confirmatory Item 3.2.1.8.A in above table.
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-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 For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049), RBG-47389, dated August 28, 2013.
4. NRC Letter, "River Bend Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0952)," dated February 25, 2014 (ML13365A281).

Page 8 of 9

Attachment RBG-47502 August 28, 2014

5. 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), RBG-47445, dated February 26, 2014.

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