ML14357A121

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Station'S First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order No. EA-13-109)
ML14357A121
Person / Time
Site: Pilgrim
Issue date: 12/16/2014
From: Dent J
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2.14.083, EA-13-109
Download: ML14357A121 (7)


Text

Entergy Nuclear Operations, Inc.

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

Site Vice President December 16, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Pilgrim Nuclear Power Station's First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

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

REFERENCES:

1. NRC Order Number EA-1 3-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013
2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).
3. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-1 3-109) Rev 0" (Accession No. ML14128A219).
4. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-1 3-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013.
5. Entergy's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109),"

dated June 30, 2014.

LETTER NUMBER 2.14.083

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (Entergy). Reference 1 was immediately effective and directs Entergy to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of Reference 1.

PNPS Letter 2.14.083 Page 2 of 3 Reference 1 required submission of a phase 1 overall integrated plan pursuant to Section IV, Condition D. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 2. Reference 5 provided the Entergy overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. References 2 and 4 provide direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition D, 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 concerning the content of this letter, please contact Mr. Everett (Chip) Perkins Jr. at (508) 830-8323.

This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on December 16, 2014.

Sincerely, J n A. Dent Jr.

eVice President JAD/rmb

Attachment:

Pilgrim Nuclear Power Station's First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-1 3-109)

PNPS Letter 2.14.083 Page 3 of 3 cc: Mr. Daniel H. Dorman 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 Mr. John Giarrusso Jr.

Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 NRC Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT To PNPS Letter 2.14.083 Pilgrim Nuclear Power Station's First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

Attachment to PNPS Letter 2.14.083 Pilgrim Nuclear Power Station's First Six Month Status Report for the Implementation of Order EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction Pilgrim developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 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 November 30, 2014.

0 The Overall Integrated Plan was issued on June 30, 2014.

3 Milestone Schedule Status The following provides an update to Part 5 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.

Milestone Target Activity Comments Completion Date Status Complete HCVS Gap Analysis Jun, 2014 Complete Submit Overall Integrated Implementation Plan Jun, 2014 Complete Submit 6 Month Status Report Dec. 2014 Complete Submit 6 Month Status Report Jun. 2015 Not Started Simultaneous Phase2 iPwith Submit 6 Month Status Report Dec. 2015 Not Started Phase 20OIP Design Engineering On-site/Complete Dec, 2015 Not Started Submit 6 Month Status Report Jun. 2016 Not Started Operations Procedure Changes Developed Dec, 2016 Not Started Site Specific Maintenance Procedure Developed Dec, 2016 Not Started Page 1 of 3

Pilgrim Nuclear Power Station's First Six Month Status Report for the Implementation of HCVS Phase 1 PNPS Letter 2.14.083 Milestone Target Activity Comments Completion Date Status Submit 6 Month Status Report Dec. 2016 Not Started Training Complete Dec, 2016 Not Started Implementation Outage Mar, 2017 Not Started Procedure Changes Active Mar, 2017 Not Started Walk Through Demonstration/Functional Test Mar, 2017 Not Started Submit Completion Report Jun. 2017 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 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 None.

7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. Pilgrim's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-1 3-109)," dated June 30, 2014.
2. NRC Order Number EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013.
3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013.

Page 2 of 3

Pilgrim Nuclear Power Station's First Six Month Status Report for the Implementation of HCVS Phase 1 PNPS Letter 2.14.083

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).
5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).
6. Nuclear Regulatory Commission Audits of Licensee Responses to Phase 1 of Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Accession No. ML14126A545).

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