PNP 2015-007, Fourth 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)
| ML15062A011 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/27/2015 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, PNP 2015-007, TAC MF0768 | |
| Download: ML15062A011 (18) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway fl Ml 49043-9530 Covert, MI Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2015-007 27, 2015 February 27,2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Palisades Nuclear Plant Fourth 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)
Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20
REFERENCES:
- 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 12, 2012 (ADAMS Accession No.
1 2054A736) 12054A736)
- 2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA- 12-049, Order Modifying Licenses with Regard to Requirements for EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, 29, 2012 (ADAMS Accession No.
Revision 0, dated August 29,2012 ML112229A174)
ML 2229A1 74)
NEI 12-06, Diverse and Flexible Coping Strategie$
Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. MLML12242A378) 12242A378)
- 4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-091, Initial 12, 2012 Commission Order Status Report in Response to March 12,2012 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number 25, 2012 (ADAMS Accession No.
EA-12-049), dated October 25,2012 ML112300A065 ML 2300A065
- 5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2013-010, Overall 12, 2012 Commission Order Integrated Plan in Response to March 12,2012 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number 28, 2013 (ADAMS Accession No.
EA-12-049), dated February 28,2013 ML113246A399)
ML 3246A399)
PNP 2015-007 Page 2 of 3
- 6. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2013-064, Palisades Nuclear Plant 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 EA- 12-049), dated August 28,2013 External Events (Order Number EA-12-049), 28, 2013 (ADAMS Accession No. ML ML1132413241 A234)
- 7. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-011, Palisades Nuclear Plant 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 EA- 12-049), dated February 28,2014 External Events (Order Number EA-12-049), 28, 2014 (ADAMS Accession No. ML ML114059A078) 4059A078)
- 8. Entergy Nuclear Operation, Inc. letter to NRC, PNP 2014-085, Palisades Nuclear Plant Third Six-Month Status Report in Response to 12, 2012 Commission Order Modifying Licenses with Regard to March 12,2012 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28,201428, 2014 (ADAMS Accession No. ML ML114240A279) 4240A279)
Interim Staff Evaluation
- 9. NRC letter, Palisades Nuclear Plant -Interim Regarding Overall Integrated Plan in Response to Order EA-12-049 EA- 12-049 (Mitigation Strategies) (TAC No. MF0768), dated February 10, 2014 (ADAMS Accession No. ML ML113365A264) 3365A264)
Dear Sir or Madam:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (ENO). Reference 1 1 was immediately effective and directs ENO 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 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 Nuclear Energy Institute (NEI) 12-06, Revision 1 1 (Reference 3) with clarifications and exceptions identified in Reference 2.
Reference 4 provided the Palisades Nuclear Plant (PNP) initial status report regarding mitigation strategies. Reference 5 provided the PNP overall integrated plan.
Reference 1 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. Reference 7 provided the second six-month status report. Reference 8 provided the third six-month status report. In Reference 9, the NRC issued an interim staff evaluation for the PNP overall integrated plan.
The purpose of this letter is to provide the fourth 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 attachment provides an update of milestone accomplishments, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
PNP 2015*007 2015-007 Page 3 of 3 This letter contains no new commitments and no revised commitments.
I declare under penalty of perjury that the foregoing is true and correct; executed on February February 27, 2015.
27,2015.
Sincerely,
/
ajv/jse
Attachment:
Palisades Nuclear Plant Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements Beyond-Design-Basis External Events (Order for Mitigation Strategies for Beyond*Design-Basis Number EA-12-049) cc: Office Director, NRR, USNRC Administrator, Region III, Ill, USNRC USN RC Project Manager, Palisades, USNRC USN RC Resident Inspector, Palisades, USNRC
ATTACHMENT Palisades Nuclear Plant Fourth 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 1 Introduction Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an overall integrated plan (Reference 1), which documented the diverse and flexible coping strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 6), 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, 2014, and are current as of January 31, 2015.
- August 2014 Third Six-Month Status Report -August
- Design Engineering - September 2014
- Install Off-Site Delivery Station - October 2014
- Develop Training Plan - December 2014
- Fourth Six-Month Status Report - Complete with submission of this document in February 2015.
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.
- Develop Strategies with NSRC The Develop Strategies with NSRC milestone completion date has been changed to October 2015. This new milestone target completion date does not impact the Order implementation date.
- Create PNP FLEX FSG The Create PNP FLEX FSG milestone completion date has been changed to October 2015. This new milestone target completion date does not impact the Order implementation date.
1 of 15 Page 1
- Create Maintenance Procedures The Create Maintenance Procedures milestone completion date has been changed to October 2015. This new milestone target completion date does not impact the Order implementation date.
- Training Complete The Training Complete milestone completion date has been changed to July 2015. This new milestone target completion date does not impact the Order implementation date.
Target Revised Target Milestone Completion Activity Status Completion Date*
Date* Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Six-Month Status Updates Update 11 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Jan 2014 Complete Perform Staffing Analysis Apr2015 Apr 2015 Started Modifications Modifications Evaluation Apr 2014 Complete Engineering and Implementation N-i Walkdown N-1 Feb 2014 Complete Design Engineering Sept 2014 Complete IImplementation mplementation Outage Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Aug 2015 Started Off-site FLEX Equipment Develop Strategies with NSRC Jan 2015 Started October 2015 Install Off-Site Delivery Station (If Oct 2015 Complete Necessary)
Procedures Pressurized Water Reactor Owners Group (PWROG) issues Nuclear Nuclear Jun 2013 Com p lete Complete Steam Supply System (NSSS)-
Specific_Guidelines Specific Guidelines Create PNP FLEX FSG PNP FLEX Dec Dec 2014 Started Started October 2015 2015 Create Maintenance Procedures Mar Mar 2015 Started October 2015 Page 22 of 15 15
Target Revised Target Milestone Completion Activity Status Completion Date*
Date* Date Training Develop Training Plan Jun 2015 Complete Training Complete Sept 2015 Not Started July2015 July 2015 Validation I Demonstration Validation! Oct 2015 Not Started Submit Completion Report Oct2015 Oct 2015 Not Started
- Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month
- Target status reports 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 ENO 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 Interim Staff Evaluation (ISE) (Reference 5). A fourth table includes a listing of audit questions and the status of each item.
Overall Integrated Plan Open Item Status OIl. Perform analysis on Palisades' 011. Palisades Complete/Closed susceptibility to soil liquefaction and Borings were performed on site and soil liquefaction potential consequences on the susceptibility was identified along the FLEX equipment FLEX implementation plan.
deployment route outside 'the the PA. Based on this information a set of FLEX equipment will be stored inside the protected area (PA) for the seismic event.
The other set of FLEX equipment will be stored outside of the PA and be protected against the tornado event. Both locations will be protected against other applicable (screened-in) beyond-design-basis external events (BDBEEs). Additional planning is under way to address other impacts to equipment storage and deployment. This Open Item is related to 3.1.1 .2.A and is addressed on Audit ISE Open Item 3.1.1.2.A Question (AQ) response spreadsheet on the ePortal.
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Overall Integrated Plan Open Item Status 012. Develop Phase 3 deployment Started strategy with correspondence with Staging areas have been identified. The National e RRC.
the SAFER Response Center (NSRC) [formerly known as the Regional Response Center (RRC)] kickoff meeting 7/22/14 to complete checklist as was conducted on 7/22114 approved by AREVA. The NSRC and Palisades are in process of developing Site Response Plans. This Open Item is related to IISE SE Confirmatory Item 3.4.A and is addressed on the AQ response spreadsheet on the ePortal.
013. Evaluate the need to missile Complete/Closed protect primary system makeup The condensate storage tank (CST) (T-2) and T-81 storage tank (T-81) and other are cross-connected such that upon depletion of the external tanks.
CST, at approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the inventory in tank T-81 can also be gravity fed to the TDAFW pump. To allow credit for an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> supply, tanks T-2 and T-81 will be missile protected. Following the required modifications, tanks T T-2 T-81
-2 and T -81 will be considered robust against all of the applicable tornado missile hazards described on Table 2 of RG 1.76, Rev. 1, with the single exception of tank T-81 foundation mounting bolts. Tank T-81 would be fully protected against the design basis tornado missile hazards of a 6-inch Schedule 40 steel pipe and a 1-inch diameter solid steel sphere (the exception being anchor bolting for the automobile missile hazard impact). A white paper describing the tornado generated missile hazard evaluation for tank T-81 has been posted to the ePortal.
This Open Item is also addressed by AQ PAL-044 response.
014. Select the location of FLEX Complete/Closed equipment storage facility.
OIl. One set of equipment will be stored in a Refer to 011.
new structure inside the PA designed for the Seismic event. An additional set(s) of equipment will be stored outside the PA in a structure(s) providing an appropriate level of protection for the tornado event.
Both sets will be protected against other applicable (screened-in) BDBEE external hazards.
015. Perform seismic evaluation of Complete/Closed turbine-driven auxiliary feedwater Seismic evaluation documents the seismic pump (TDAFWP) driver K-8.
qualification of the pump and associated components.
The TDAFW pump is qualified with the exception of an outlier related to a check for bolt tightness. Bolt tightness on the pump is being performed under WO# 372138 and documented under EC 46465.
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Overall Integrated Plan Open Item Status 016. Evaluate strategies to extend Complete/Closed battery coping time.
The battery load shedding strategy has been revised to extend the battery coping time through shedding loads in addition to those identified in the station blackout procedure. The results indicate a coping time of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the installed batteries accompanying the expected deep load shed list. This PAL-01 8 response.
Open Item is addressed by AQ PAL-018 017. Evaluate sources of non- Complete/Closed borated water in addition to After depletion of TT-2
-2 and TT-81,
-81, makeup to the steam condensate storage tank (T (T-2)
-2) and (SG5) will be from a portable pump with generators (SGs)
T-81.
the credited suction source being Lake Michigan.
Modifications to credit sources of non-borated water for sources other than T-2, T-81 and Lake Michigan were determined to not be required.
018. Palisades Probabilistic Risk Complete/Closed Assessment (PRA) to provide Palisades PRA provided multiple evaluations for justification why battery room battery room hydrogen generation. It was determined ventilation is not required until 24 that supplemental ventilation is required approximately hours.
1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after charging begins for removal of hydrogen. Ventilation is not required for Phase 2 temperature control. This supplemental ventilation has been included in the Palisades strategy. This Open Item is addressed by AQ PAL-025 response.
019. Evaluate the effects of FLEX Started on security procedures.
The security plan/program will be updated to correspond to FLEX procedures.
0110. Evaluate requirements of Complete/Closed mobile purification unit from RRC.
It was determined that the 500 gpm NSRC water treatment unit is preferred over the 250 gpm NSRC reverse osmosis unit in order to support SG makeup and provide makeup to the NSRC mobile boration unit. The mobile water treatment unit is only required to enhance Phase 3 actions post 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
0111. Evaluate requirements of Complete/Closed mobile boration unit from RRC.
Current strategy is to have adequate borated water inventory onsite for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to cope with any BDBEE.
Therefore, the requirements of the mobile boration unit from NSRC is only required to enhance Phase 3 actions post 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
0112. Evaluate methods of venting Complete/Closed the fuel handling building.
The strategy for venting the fuel handling building will be to open an existing double leaf door/hatch on the roof of the building.
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Overall Integrated Plan Open Item Status 0113. Evaluate the use of high- Complete/Closed efficiency LED lighting.
The use of high-efficiency LED lighting has been evaluated for its impact to battery coping time and control room heat loads. LED lighting would have minimal impact and is not required or recommended.
0114. Perform evaluation to Complete/Closed determine if additional parameters NEI 12-06, PWROG FLEX guidance was In addition to NEI12-06, will need to be monitored during reviewed for key parameter monitoring. The NEI FLEX activities.
12-06 and PWROG guidance regarding recommended instrumentation has been incorporated into the FLEX strategy and the power supply for these instruments evaluated. All the credited instruments are powered by battery/DC buses and available throughout the event.
0115. Perform analysis to ensure Complete/Closed survivability of containment.
Containment analysis has been completed using the Modular Accident Analysis Program (MAAP). Results of this analysis show containment design parameters (i.e.,
will not be exceeded for the at-power scenario (Le.,
event initiating in Mode 1). For the most conservative (i.e., Mode 5 reduced inventory),
shutdown scenario (Le.,
results of the analysis show that a vent path will be required to prevent exceeding the design limits of containment. Containment vent paths that could be used are the personnel air lock, the emergency air lock, or the equipment hatch. Procedural controls will be established using the supplemental guidance provided in the NRC-endorsed NEI position paper Shutdown / Refueling Modes."
titled "Shutdown Modes. This Open Item is addressed by AQ PAL-050 response.
0116. Evaluate borated water Complete/Closed sources in addition to safety All additional sources of borated water were evaluated injection refueling water tank for use following a BDBEE. This Open Item is
(
(SIRWT). ). addressed by AQ PAL-048 response.
0117. Entergy, for the Palisades Complete/Closed site, will negotiate and execute a contract with Strategic Alliance for FLEX Emergency Response (SAFER) that will meet the requirements of NEI 12-06, Section 12.
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Overall Integrated Plan Open Item Status 0118. Evaluate a location to install a Complete/Closed tee in the service water system to Several locations in the service water system were allow the ultimate heat sink (UHS) evaluated. A pipe elbow downstream of service water FLEX pump to provide cooling.
cooling, system (SWS) pump P-7C was identified as the best location for connecting a pipe tee to allow flow from the NSRC UHS pump. This Open Item is related to 3.2.4.1 .B and is addressed on ISE Confirmatory Item 3.2.4.1.8 the AQ response spreadsheet on the ePortal.
0119. Evaluate the use of lake water Complete/Closed to cool the steam generators during An analysis has been completed that determined the an extended loss of ac power impacts on the steam generators when using lake (ELAP)
(ELAP).
water as the makeup source. The analysis determined that the heat transfer capability of each steam generator was diminished by approximately 4.4% after 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. This reduction in heat transfer 4.40/0 capability was determined to be inconsequential due to the reduced decay heat load by 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> into the event and therefore is acceptable.
0120. Evaluate time until primary Complete/Closed coolant system (PCS) makeup is An evaluation was performed that documented the necessary in Modes 5 & 6.
time until PCS makeup is required in shutdown modes. The time when makeup is required varies greatly depending on the status of the PCS when the event occurs (i.e., PCS level, pressure, pressur~, and temperature). The most limiting scenario was found to be such that PCS makeup could be required as early as one hour after the event if the PCS is vented and at reduced inventory. High risk evolutions such as vented PCS and reduced inventory will be managed by outage risk planning and contingency actions such as pre-staging equipment as discussed in the NEI Shutdown / Refueling Modes."
position paper titled "Shutdown Modes.
0121. Evaluate connection to ensure Complete/Closed cooling water can be provided for Cooling water flow to the containment air fans is containment air fans.
through the service water system addressed in 01 Cl 18.
Connection of the NSRC supplied FLEX UHS pump to the SWS will provide the necessary means/connection for cooling water flow to the containment air coolers.
0122. Evaluate the robustness of Complete/Closed the charging pumps.
The charging pumps have been evaluated as robust for all applicable external events (seismic, tornado, high temperature, low temperature and flooding). This Open Item is addressed by AQ PAL-041 response.
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Interim Staff Evaluation Open Items Status 3.1.1 .2.A 3.1.1.2.A Evaluate the impact of potential soil This item is addressed on liquefaction on deployment of portable FLEX the Audit Question (AQ) equipment. response spreadsheet on the ePortal.
3.1.1 .2.B 3.1.1.2.8 Evaluate the potential need for a power source This item is addressed on to move or deploy the equipment (e.g., to open the AQ response location),
the door from a storage location). spreadsheet on the ePortal.
3.1.1 .3.A 3.1.1.3.A Evaluate impacts from large internal flooding This item is addressed on sources that are not seismically robust and the the AQ response potential impact on the mitigating strategies. spreadsheet on the ePortal.
3.1.1 .3.B 3.1.1.3.8 Evaluate the potential for ground water to This item is addressed on impact the mitigating strategies. the AQ response spreadsheet on the ePortal.
3.1.5.1 .A 3.1.5.1.A Evaluate the potential for high temperature This item is addressed on hazards to impact the functionality of FLEX the AQ response facility, equipment in the FLEX storage faCility. spreadsheet on the ePortal.
3.1 .5.3.A 3.1.5.3.A Evaluate the potential for high temperature This item is addressed on hazards to impact the deployment of FLEX the AQ response equipment. spreadsheet on the ePortal.
3.2.1 .8.A 3.2.1.B.A Verify resolution of the generic concern This item is addressed by associated with the modeling of the timing and updated AQ PAL-015 uniformity of the mixing of a liquid boric acid response.
solution injected into the PCS under natural circulation conditions potentially involving two-phase flow.
3.2.1 .9.B 3.2.1.9.8 Provide additional justification for the alternate This item is addressed by approach to NEI 12-06 12-06 involving the use of AQ PAL-041 response.
installed charging pumps.
Interim Staff Evaluation Confirmatory Items Status 3.1.3.1.A Confirm that the FLEX storage facility(s) will meet This item is addressed on plants design-basis tornado wind speed of 300 the plant's the AQ response mph or will be designed or evaluated equivalent to spreadsheet on the ASCE 7-10 using a tornado wind speed of 230 ePortal.
mph with separation and diversity between the storage locations. If the method of protection chosen is the later, confirm that separation and diversity is adequate.
3.2.1 .A 3.2.1.A Confirm that the operator actions times in the first This item is addressed by 20 minutes of the event are adequate and PAL-Ol 1 updated AQ PAL-011 reasonably achievable when the associated ELAP response.
procedures are developed and validated.
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Interim Staff Evaluation Confirmatory Items Status 3.2.1 .B 3.2.1.B Confirm the robustness of the charging pump This item is addressed by control circuit or provide FLEX procedure PAL-Ol 1 updated AQ PAL-011 guidance to manually operate the charging pumps response.
by breaker operation.
3.2.1 .C 3.2.1.C Confirm the seismic robustness of the BAST This item is addressed by piping to support use of the BAST water as a AQ PAL-047 response.
supply source for the charging pumps.
3.2.1 .D 3.2.1.0 Confirm the availability and adequacy of a borated This item is addressed by water supply to support the PCS makeup strategy. updated AQ PAL-048 response.
3.2.1 .E 3.2.1.E Confirm the continued functionality of the This item is addressed by Atmospheric Dump Valves in the context of a AQ PAL-055 response.
tornado missile hazard during an ELAP in order to sym metric cooldown. Alternatively, support a symmetric address the effects of asymmetric natural circulation cooldown.
3.2.1 .F 3.2.1.F Confirm the ability of any non-safety related This item is addressed by equipment to function as credited in the mitigation AQ PAL-043 response.
strategies in accordance with the external event NEI-12-06.
criteria described in NEI-12-0S.
3.2.1.1 .A 3.2.1.1.A Confirm that the use of Combustion Engineering This item is addressed by Nuclear Transient Simulator (CENTS) in the ELAP updated AQ PAL-003 analysis is limited to the flow conditions prior to response.
ref lux boiling initiation. This confirmation should reflux include a description of the CENTS- calculated flow quality at the top of the SG U-tube for the condition when two-phase natural circulation ends and reflux boiling initiates.
3.2.1 .2.A 3.2.1.2.A Confirm the Primary Coolant Pump (PCP) (POP) seal This item is addressed by leakage rate assumed in the ELAP analysis is AQ PAL-004 response.
POP seal leakage rate justified. Specifically, if the PCP used in the plant-specific analysis is less than he upper bound expectation for the seal leakage rate (15 gpm/seal) discussed in the PWROG position paper addressing the PCP POP seal leakage for Combustion Engineering plants (ADAMS Accession No. ML ML13235A151, 13235A151, non-publicly available), justification should be provided.
3.2.1 .2.B 3.2.1.2.B Confirm whether seal failure will occur or not when This item is addressed by subcooling of the coolant in the PCS cold-legs is AQ PAL-004 response.
greater than 50 degrees Fahrenheit (OF). (°F). This evaluation should specify the seal leakage flow assumed for the ELAP from time zero to the timeframe when subcooling in the PCS POS cold-legs decreases to 50°F, and provide justification for the assumed leakage rate.
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Interim Staff Evaluation Confirmatory Items Status 3.2.1 .2.C 3.2.1.2.C If the Integrated Plan is changed to credit isolation This item is addressed by of controlled bleed-off (CBO), confirm the AQ PAL-004 response.
assumption that the integrity of the PCP seals can be maintained, and the seal leakage rate is lessless than 11 gpm per PCP during an ELAP before CBO isolated. This evaluation should provide the is isolated.
maximum temperature and pressure and minimum subcooling of the coolant in the PCS cold- legs during the ELAP before CBO isolation. If CBO isolation is being assumed, justify the sequence of events (SOE) and time constraints so established.
3.2.1 .3.A 3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + + 2 This item is addressed by sigma decay heat curve. AQ PAL-012 response.
3.2.1 .5.A 3.2.1.5.A Confirm the containment temperature, pressure, This item is addressed by and moisture profiles during the ELAP event, and AQ PAL-013 response.
justify the adequacy of the computer codes/methodologies, and assumptions used in the analysis.
3.2.1 .5.B 3.2.1.5.B Confirm whether further instrumentation is needed This item is addressed by based upon ongoing ELAP evaluations. AQ PAL-013, AQ PAL-027 and AQ PAL-035 responses.
3.2.1.6.A Complete validation of the SOE SQE timeline. This item is addressed by AQ PAL-030 response.
3.2.1 .6.B 3.2.1.6.B In the audit process, the licensee has indicated This item is addressed by that an assessment has been performed PAL-al AQ PAL -0111 response.
identifying potential changes to the SOE.
SQE. Confirm that a final SOESQE has been developed incorporating any identified changes.
3.2.1 .9.A 3.2.1.9.A Confirm that the ability to line up portable pumps is This item is addressed by consistent with the times assumed in the final updated AQ PAL-014 version of the Integrated Plan. response.
3.2.2.A Resolve the discrepancy between the licensee- This item is addressed on determined flow rate of 100 100 gallons per minute the AQ response (gpm) SFP spray and the 250 gpm performance spreadsheet on the attribute of NEI 12-06, Table D-3. ePortal.
3.2.3.A Confirm the plan assumptions for containment This item is addressed by cooling, after completion of the containment AQ PAL-050 and AQ response analysis. PAL-053 responses.
3.2.4.1 .A 3.2.4.1.A Confirm whether whether supplemental cooling is required This item is addressed on for components or systems used in the mitigating the AQ response strategies plan. spreadsheet on the ePortal.
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Interim Staff Evaluation Confirmatory Items Status 3.2.4.1 .B 3.2.4.1.B Confirm the connection point for the UHS FLEX This item is addressed on Pump to the Service Water System. the AQ response spreadsheet on the ePortal.
3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by in the battery room to protect the batteries from AQ PAL-023 response.
the effects of extreme high and low temperatures.
3.2.4.2.B Confirm the adequacy of battery room ventilation This item is addressed by to prevent hydrogen accumulation while AQ PAL-025 response.
recharging the batteries in Phase 2 or Phase 3.
3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by borated water systems. AQ PAL-007 response.
3.2.4.4.A Confirm that communication enhancements NRC Confirmatory Action NRCs communication assessment credited in the NRC's
{ADAMS Accession No. ML ML13129A219) 13129A219) are completed as planned.
3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed by and/or operator protective measures will be updated response on the employed in all phases of an ELAP to ensure AQ response spreadsheet operators will be capable of FLEX strategy on the ePortal.
execution under adverse temperature conditions.
3.2.4.7.A Confirm that the evaluation of the CST and T-81 This item is addressed by shows that the tank qualification is consistent with updated AQ PALPAL-044
-044 the strategy and the provisions of NEI 12-06. response.
3.2.4.7.B Confirm that the FLEX Support Guidelines provide This item is addressed by clear criteria for transferring to the next preferred updated AQ PAL-045 source of water when refilling the CST. response.
3.2.4.10.A Confirm that the load shed calculation verifies This item is addressed by adequate battery capacity with sufficient margin PAL-al 8 and AQ PAL-AQ PAL-018 throughout Phase 1 1 to assure the battery does not 033 responses.
get depleted prior to charging, and the results of the analysis are properly integrated into the overall strategy.
3.4.A Confirm that plans for the deployment of portable This item is addressed on equipment used to implement the response the AQ response NEt 12-06, Section 12.2, conform to the criteria of NEI spreadsheet on the with regards to considerations 2 through 10. ePortal.
Audit Completion or Target Status Question Date PAL-002 Closed.** Response available on the ePortal.
Closed.
Updated response available on the ePortal PAL-003 3.2.1.1 .A).
(associated with ISE Confirmatory Item 3.2.1.1.A).
Page 11 of 15
Audit Completion or Target Status Question Date Closed.** Response available on the ePortal Closed.
ISE Confirmatory Item 3.2.1.2.A).
(associated with ISE 3.2.1 .2.A).
Closed.** Response available on the ePortal Closed.
PAL-004 PAL-004 ISE Confirmatory Item 3.2.1.2.8).
(associated with ISE 3.2.1 .2.B).
Closed.** Response available on the ePortal Closed.
3.2.1 .2.C).
(associated with ISE Confirmatory Item 3.2.1.2.C).
Closed.** Response available on the ePortal Closed.
PAL-007 (associated with ISE Confirmatory Item 3.2.4.3.A).
PAL-008 Closed.** Response available on the ePortal.
Closed.
Updated response available on the ePortal (ISE 3.2.1 .A).
Confirmatory Item 3.2.1.A).
Updated response available on the ePortal PAL-ol 1 PAL-011 3.2.1 .B).
(associated with ISE Confirmatory Item 3.2.1.8).
Closed.** Response available on the ePortal Closed.
3.2.1 .6.B).
(associated with ISE Confirmatory Item 3.2.1.6.8).
Closed.* Response available on the ePortal Closed.*
PAL-012 3.2.1 .3.A).
(associated with ISE Confirmatory Item 3.2.1.3.A).
Closed.** Response available on the ePortal Closed.
3.2.1 .5.A).
(associated with ISE Confirmatory Item 3.2.1.5.A).
PAL-Ol 3 PAL-013 Closed.** Response available on the ePortal (ISE Closed.
Confirmatory Item 3.2.1.5.8).
3.2.1.5.B).
Updated Response available on the ePortal PAL-014 (associated with ISE Confirmatory Item 3.2.1 .9.A).
3.2.1.9.A).
Updated response available on the ePortal PAL-015 (associated with ISE Open Item 3.2.1 .8.A).
3.2.1.8.A).
PAL-016 Updated response available on the ePortal.
ThisAQ In progress - This AQ response will be updated PAL-017 Oct 2015 when information is available.
Closed.*
Closed.
- Response available on the ePortal PAL-018 (associated with ISE Confirmatory Item 3.2.4.10.A).
3.2.4.1 O.A).
PAL-019 Closed.*
Closed.
- Response available on the ePortal.
PAL-020 Closed.*
Closed.
- Response available on the ePortal.
PAL-021 Closed.*
Closed.
- Response available on the ePortal.
PAL-022 Closed.*
Closed.
- Response available on the ePortal.
Closed.*
Closed.
- Response available on the ePortal.
PAL-023 (associated with ISE Confirmatory Item 3.2.4.2.A).
3.2.4.2.A).
PAL-024 Closed.*
Closed.
- Response available on the ePortal.
Closed.*
Closed: Response available available on the ePortal ePortal PAL-025 (associated with ISE ISE Confirmatory Item Item 3.2.4.2.B).
3.2.4.2.8).
Page 12 of Page 12 of 15 15
Audit Completion or Target Status Question Date PAL-026 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-027 3.2.1 .5.B).
(associated with ISE Confirmatory Item 3.2.1.5.8).
PAL-028 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-030 3.2.1 .6.A).
(associated with ISE Confirmatory Item 3.2.1.6.A).
Closed.* Response available on the ePortal Closed.*
PAL-033 3.2.4.10.A).
(associated with ISE Confirmatory Item 3.2.4.1 O.A).
Closed.** Response available on the ePortal Closed.
PAL-035 3.2.1 .5.B).
(associated with ISE Confirmatory Item 3.2.1.5.8).
PAL-036 Closed.** Response available on the ePortal.
Closed.
PAL-037 Closed.** Response available on the ePortal.
Closed.
PAL-039 Closed.** Response available on the ePortal.
Closed.
PAL-040 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-041 3.2.1.9.B).
(associated with ISE Open Item 3.2.1.9.8).
Closed.** Response available on the ePortal Closed.
PAL-043 3.2.1 .F).
(associated with ISE Confirmatory Item 3.2.1.F).
Updated response available on the ePortal PAL-044 (associated with ISE Confirmatory Item 3.2.4.7.A).
Updated Response available on the ePortal PAL-045 (associated with ISE Confirmatory Item 3.2.4.7.8).
3.2.4.7.B).
PAL-046 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-047 3.2.1 .C).
(associated with ISE Confirmatory Item 3.2.1.C).
(ISE Updated response available on the ePortal (lSE PAL-048 Confirmatory Item 3.2.1.D).
PAL-049 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-050 (associated with ISE Confirmatory Item 3.2.3.A).
In progress - This AQ response will be updated PAL-051 Oct 2015 when information is available.
Closed.** Response available on the ePortal Closed.
PAL-053 (associated with ISE Confirmatory Item 3.2.3.A).
PAL-054 Closed.** Response available on the ePortal.
Closed.
Closed.** Response available on the ePortal Closed.
PAL-055 3.2.1 .E).
(associated with ISE Confirmatory Item 3.2.1.E).
PAL-056 Closed.** Response available on the ePortal.
Closed.
Page 13 of 15
Audit Completion or Target I Question Status Date PAL-057 Closed.* Response available on the ePortal.
Closed.
- Closed indicates that Closed indicates that Entergy's response is Entergys response is complete.
complete.
7 Potential Interim Staff Evaluation Impacts In addition to the items identified in Section 6, the following item has been identified which has potential impact to the Interim Staff Evaluation (ISE).
- 1. ISE TER Section 3.1.1.1, page 6, first paragraph after the numbered list, states, Two Two potential storage areas for FLEX portable equipment have been identified. The licensee will determine where the storage facility will be located at Palisades and update.
communicate this information in a future six-month update."
Structures to provide protection of FLEX equipment are constructed to meet the requirements of NEI 12-06 Rev. 0 for seismic, flooding, high winds, snow, ice, extreme cold, and high temperatures. Two structures, one inside the Protected Area (PA) and one outside the PA are utilized to house all portable FLEX equipment. The necessity for two locations as stated arose after the soil outside the PA was found to be liquefiable in a seismic event. Liquefiable soil would likely cause differential settlements of soil along the deployment path, resulting in roads that could not be traversed. At the same time, there is minimal area inside the PA to house a building that could withstand all BDBEE. The solution to this problem is to house FLEX equipment in two structures that will each withstand a portion of the required BDBEE such that at least one set of portable FLEX equipment will be available and accessible for any and all BDBEE. The storage location inside the PA will be a storage container designed to withstand seismic and seismic-induced seiche BDBEE, while the storage location outside the PA will be a FLEX Storage Building designed to withstand external temperature and high wind BDBEE, including tornado generated missiles, as well as seismic BDBEE for protection of the Phase 3 equipment (step-down transformer and the temporary cable to connect to Bus 1 1 D) which will be stored in the building. The storage strategy for the FLEX equipment is to utilize Sea-Land containers (FLEX storage container) inside the Protected Area and one hardened structure (FLEX Storage Building) located near the abandoned security gate, east of the employee parking lot.
Page Page 14 14 of of 15 15
8 References The following references support the updates to the Overall Integrated Plan described in this attachment.
- 1. ENO letter to NRC, PNP 2013-010, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation EA- 12-049), dated Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),
February 28, 2013 (ADAMS Accession No. ML ML13246A399) 13246A399)
EA-1 2-049, Order Modifying Licenses with Regard to
- 2. NRC Order Number EA-12-049, Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated 12, 2012 (ADAMS Accession No. ML March 12,2012 ML12054A736).
12054A736).
- 3. ENO letter to NRC, PNP 2013-064, Palisades Nuclear Plant 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 28, 2013 (ADAMS Accession No.
Events (Order Number EA-12-049), dated August 28,2013 ML113241 ML 3241 A234).
- 4. ENO letter to NRC, PNP 2014-011, Palisades Nuclear Plant Second Six-Month Status 12, 2012 Commission Order Modifying Licenses with Report in Response to March 12,2012 Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External EA- 12-049), dated February 28,2014 Events (Order Number EA-12-049), 28, 2014 (ADAMS Accession No.
4059A078).
ML Interim Staff Evaluation Regarding Overall
- 5. NRC letter, Palisades Nuclear Plant -Interim EA- 12-049 (Mitigation Strategies) (TAC No.
Integrated Plan in Response to Order EA-12-049 MFO768), dated February 10, 2014 (ADAMS Accession No.ML MF0768), No.ML113365A264) 3365A264)
- 6. ENO letter to NRC, PNP 2014-085, Palisades Nuclear Plant 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 EA- 12-049), dated August 28,2014 Events (Order Number EA-12-049), 28, 2014 (ADAMS Accession No.
4240A279)
ML Page 15 of 15