RBG-47546, Entergy'S Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) River Bend Station -

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Entergy'S Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) River Bend Station -
ML15062A032
Person / Time
Site: River Bend Entergy icon.png
Issue date: 02/25/2015
From: Olson E
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RBG-47546
Download: ML15062A032 (15)


Text

Entergy Operations, Inc.

River Bend Station mEntergy 5485 U. S. Highway 61 N St. Francisville, LA 70775 Tel 225 381 4374 Fax 225 381 4872 eolson@entergy.com Eric W. Olson Site Vice President RBG-47546 February 25, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Entergy's 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)

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

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 (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-1 2-049), 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. A.

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RBG-47546 February 25, 2015 Page 2 of 4

8. 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-1 2-049), RBG-47502, dated August 28, 2014.

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, 7 and 8 provided the first, second and third six-month status report, respectively. 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 enclosed report provides an update of milestone accomplishments since the last statusg 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 February 25, 2015.

Sincerely, EWO/JAC/dhw

Attachment:

River Bend Station's Fourth 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

RBG-47546 February 25, 2015 Page 3 of 4 cc: U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 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: Mandy Halter Mail Stop OWFN 13F15 11555 Rockville Pike Rockville, MD 20852-2378

RBG-47546 February 25, 2015 Page 4 of 4 U. S. Nuclear Regulatory Commission ATTN: Eric Bowman Mail Stop OWFN/1 2D20 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-47546 (10 pages)

River Bend Station's Fourth 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-47546 February 25, 2015 River Bend Station's Fourth 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 last status report (Reference 5), 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 August 1, 2014, and are current as of January 31, 2015:
  • Third Six-Month Status Report - August 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.

Target Revised Target Milestone Completion Activity Status Cetion Dat Date Completion Date Submit 60 Day Status Report Oct. 2012 Complete Submit Overall Integrated Feb. 2013 Complete Implementation Plan Submit Six-Month Status Report Aug. 2013 Complete Develop Mods Dec. 2013 Complete Develop Strategies (Playbook) with Oct. 2014 Started Feb. 2015 National SAFER Response Center Purchase/Procure Equipment Oct. 2014 Started Feb. 2015 Submit Six-Month Status Report Feb. 2014 Complete Develop FLEX Procedures May 2014 Complete Create Maintenance Procedures Dec. 2014 Started March 2015 Submit Six-Month Status Report Aug. 2014 Complete Page 1 of 10

Attachment RBG-47546 February 25, 2015 Target Revised Target Milestone Completion Activity Status Completion Date Date Procedure Changes Training Material June 2014 Complete Complete Develop Training Plan June 2014 Complete Submit Six-Month Status Report Feb. 2015 Complete 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 Outage Mods March 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 RBS strategy for core cooling has been modified to include an alternate injection path and connection point to the reactor pressure vessel (RPV) for Phase 2. The primary path is from the SPC pump and heat exchanger through the RHR (LPCI) C injection line to the vessel. An alternate path can be established by utilizing a normally closed, cross-tie line between the RHR B pump discharge line and the RHR C pump discharge line. When the cross-tie is opened the SPC pump flow will pass from the RHR C discharge line through the cross-tie to the RHR B discharge line and on to the RPV through the RHR B injection valve.

A review and walkdown of cross-tie path concluded that the piping is seismically robust.

Incorporation of the cross-tie into the FLEX strategy provides an alternate core cooling path through a different connection point to the vessel.

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.

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Attachment RBG-47546 February 25, 2015

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 the NRC FLEX Audit Open Items, which includes open items on previously issued Audit Questions and new Safety Evaluation (SE) Open Items that were not closed during the October 2014 NRC Audit. A fifth table includes a listing of all 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.

This item was closed during the October 2014 NRC Audit

2. Structure, content and details of the Regional Response Center This item was closed playbook will be determined, during the October 2014 NRC Audit Interim Staff Evaluation Open Items Status None N/A N/A Interim Staff Evaluation Confirmatory Items Status 3.1.3.1 .A Confirm that the 2,700 foot separation distance between This item was closed FLEX storage facilities will be sufficient to ensure that a during the October single tornado would not impact both locations when 2014 NRC Audit considering the local tornado data, the actual separation (associated with AQ distance and axis. RBS-001) 3.2.1.1.A Confirm that benchmarks are identified and discussed which This item was closed demonstrate that Modular Accident Analysis Program during the October (MAAP) is an appropriate code for the simulation of an 2014 NRC Audit ELAP event at RBS, consistent with the NRC endorsement (associated with AQ (ADAMS Accession No. ML13275A318) of the industry RBS-009) position paper on MAAP.

3.2.1.1.B Confirm that the collapsed RPV level remains above Top of This item was closed Active Fuel and the reactor coolant system cool down rate is during the October within technical specifications limits. 2014 NRC Audit (associated with AQ RBS-012)

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Attachment RBG-47546 February 25, 2015 Interim Staff Evaluation Confirmatory Items Status 3.2.1.1.C Confirm that MAAP is used in accordance with Sections 4.1, This item was closed 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper during the October (ADAMS Accession No. ML13190A201). 2014 NRC Audit (associated with AQ RBS-010) 3.2.1.1.D Confirm that, in using MAAP, the subset of key modeling This item was closed parameters cited from Tables 4-1 through 4-6 of the "MAAP during the October Application Guidance, Desktop Reference for Using MAAP 2014 NRC Audit Software, Revision 2" (Electric Power Research Institute (associated with AQ Report 1020236, available at www.epri.com). This should RBS-01 1) 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 This item was closed seal leakage rate models, and supporting test data and any during the October conservative margin support the 66 gallons per minute 2014 NRC Audit recirculation pump seal leakage assumed in the ELAP (associated with AQ analysis. RBS-013) 3.2.1.4.A Confirm that the seismic evaluation of SPC system This item was closed components, the spent fuel pool cooling piping, and the during the October battery bus crosstie electrical cabinet used to support FLEX 2014 NRC Audit coping strategies, are completed with acceptable results. (associated with AQs RBS-003 and RBS-056) 3.2.1.4.B Confirm that the allowable minimum system pressure This item was closed required to open the SRVs in relation to the RPV pressure, during the October during the depressurization and the RPV fill evolution, is 2014 NRC Audit adequately determined. (associated with AQ RBS-061) 3.2.1.4.C Confirm that the stresses associated with passing liquid This item was closed phase water through the SRV tail pipe, including those on during the October the tail pipe, the tail pipe supports, the quencher and the 2014 NRC Audit quencher supports are evaluated with acceptable results.

3.2.1.7.A Confirm the ability to supply cooling water to the upper This item was closed containment pool when it is being used for fuel storage during the October during refueling. This capability should be consistent with 2014 NRC Audit the NEI paper entitled "Shutdown/Refueling Modes" (associated with AQ (ADAMS Accession No. ML13273A514), which has been RBS-064) endorsed by the NRC in a letter dated September 30, 2013 (ADAMS Accession No. ML13267A382), and which the licensee has indicated will be followed.

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Attachment RBG-47546 February 25, 2015 Interim Staff Evaluation Confirmatory Items Status 3.2.1.8.A Confirm the acceptability of the alternate approach for use This item was closed of the installed SPC pumps for RPV makeup. Specifically, during the October confirm the ability of the backup portable pump's capacity to 2014 NRC Audit provide both RPV injection and makeup water to the SFP (associated with AQ concurrently. RBS-061) 3.2.3.A Confirm that the licensee completes an acceptable MAAP This item was closed analysis to demonstrate that containment functions are during the October maintained in all phases of an ELAP, with particular regard 2014 NRC Audit to the qualification of drywell penetrations and seals at (associated with AQ elevated temperatures. RBS-013) 3.2.3.B Confirm that the 209 degrees Fahrenheit suppression pool This item was closed temperature reached in the ELAP event (which is over the during the October 185 degrees Fahrenheit design limit) does not adversely 2014 NRC Audit impact the structural integrity of the containment. (associated with AQ RBS-054) 3.2.4.4.A Confirm that any planned changes described in the NRC's This item was closed communications assessment (ADAMS Accession No. during the October ML13130A068) are completed. 2014 NRC Audit 3.2.4.8.A Confirm that supporting analyses related to the final This item was closed size/loading of FLEX generators is completed with during the October acceptable results. 2014 NRC Audit (associated with AQ RBS-049) 3.2.4.10.A Confirm that the final minimum dc bus voltage is determined This item was closed as part of the evaluation of an acceptable battery and dc during the October loading profile for the ELAP event. 2014 NRC Audit (associated with AQ RBS-047) 3.4.A Confirm that the licensee has fully addressed the provisions This item was closed of NEI 12-06, Sections 5.3.4, 6.2.3.4, 7.3.4, 8.3.4, and 12.2, during the October regarding considerations in using offsite resources. 2014 NRC Audit October 2014 NRC Audit FLEX Related Open Items (Ref. 7)

Audit Item Reference Item Description Licensee Input Needed Status Reference The need for evaluation of the Provide justification that Information seismic robustness of non-safety FLEX 1 pump is not uploaded to the related class 4 piping located in subject to design basis ePortal on 11-C RBS piping tunnels utilized in the induced internal flooding. 12/12/2014 FLEX strategy is identified on pages 20 and 21 of the OIP. The completed evaluation has Page 5 of 10

Attachment RBG-47546 February 25, 2015 October 2014 NRC Audit FLEX Related Open Items (Ref. 7)

Audit Item]

Reference Item Description Licensee Input Needed Status Reference confirmed that there are a number of pipe lines in the tunnels, including sections that are not considered seismically robust. The evaluation also identified that these piping sections can be isolated by closing five individual valves if the ELAP is initiated by a seismic event. RBS FLEX procedures will include directions to isolate the valves following a seismic event While the following is not a change Information in the compliance strategy uploaded to the described in the OIP, it is a ePortal on clarification with regard to the RBS 12/12/2014 FLEX strategy and the guidance of NEI 12-06. NEI 12- 06 Section 3.2.2, Consideration 13 states that regardless of installed coping capability, all plants will include the ability to use portable pumps to provide RPV/RCS/SG makeup as a means to provide a diverse capability beyond installed equipment. The RBS FLEX strategy does not include this capability, and thus, the crediting of installed SPC pumps for the RBS 13-C FLEX Phase 2 strategy is alternative method for satisfying the NEI 12-06 guidance. The use of the installed SPC pumps to provide RPV makeup is an acceptable alternative to a portable FLEX pump for the transitional phase of FLEX. The guidance states that the ELAP response is to be addressed with a combination of three categories of equipment: installed plant capability, portable on-site equipment, and off-site equipment resources. Only one phase of the response is limited to utilizing equipment from just one of the equipment categories. To ensure that there is enough time to deploy Page 6 of 10

Attachment RBG-47546 February 25, 2015 October 2014 NRC Audit FLEX Related Open Items (Ref. 7)

Audit Item Reference Item Description Licensee Input Needed Status Reference and implement portable equipment, Phase 1 can only use installed plant equipment. Even though Phase 2 and Phase 3 will utilize portable equipment (onsite for Phase 2 and offsite from RRC for Phase 3), there is no prohibition against the use of permanently installed equipment in those two phases, as long as it is robust with respect to design basis external events.

Discuss strategy for swapping Information 3-E RCIC suction from SP to the UCP uploaded to the and justify that the strategy will be ePortal on effective under ELAP conditions. 1/22/2015 In the OIP the licensee states that Justification for not Item closed as heated water is returned to the evaluating the primary subsequent to the UHS from the plant and the fans water haul path for October 2014 NRC are repowered, evaporation of the liquefaction Audit by email basin water will increase. Makeup dated 1/24/2015 RBS-62-B to the basin will eventually be from J. Hughey to required and that this will be done D. Williamson via hauling of water from the (Reference 6)

Mississippi River using trucks provided by the RRC. Provide information on how this will be accomplished.

Audit Status Completion or Target Questions Date This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.1.3.1 .A).

RBS-002 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.4.A)

RBS-004 This item was closed during the October 2014 NRC Audit RBS-005 This item was closed during the October 2014 NRC Audit RBS-006 This item was closed during the October 2014 NRC Audit Page 7 of 10

Attachment RBG-47546 February 25, 2015 Audit Status Completion or Target Questions Date RBS-008 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.1.A)

This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.1 .C)

This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.1 .D)

This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.1.B)

This item was closed during the October 2014 NRC Audit RBS-013 (associated with ISE Confirmatory Item 3.2.1.2.A and ISE Confirmatory Item 3.2.3.A)

RBS-015 This item was closed during the October 2014 NRC Audit RBS-016 This item was closed during the October 2014 NRC Audit RBS-018 This item was closed during the October 2014 NRC Audit RBS-019 This item was closed during the October 2014 NRC Audit RBS-020 This item was closed during the October 2014 NRC Audit RBS-021 This item was closed during the October 2014 NRC Audit RBS-022 This item was closed during the October 2014 NRC Audit RBS-024 This item was closed during the October 2014 NRC Audit RBS-027 This item was closed during the October 2014 NRC Audit RBS-028 This item was closed during the October 2014 NRC Audit RBS-030 This item was closed during the October 2014 NRC Audit RBS-031 This item was closed during the October 2014 NRC Audit RBS-032 This item was closed during the October 2014 NRC Audit RBS-033 This item was closed during the October 2014 NRC Audit RBS-034 This item was closed during the October 2014 NRC Audit RBS-035 This item was closed during the October 2014 NRC Audit RBS-037 This item was closed during the October 2014 NRC Audit RBS-038 This item was closed during the October 2014 NRC Audit RBS-045 This item was closed during the October 2014 NRC Audit RBS-046 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.4.10.A)

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Attachment RBG-47546 February 25, 2015 Audit Status Completion or Target Questions Date This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.4.8.A)

RBS-051 This item was closed during the October 2014 NRC Audit RBS-052 This item was closed during the October 2014 NRC Audit RBS-053 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.3.B)

RBS-055 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.4.A)

RBS-057 This item was closed during the October 2014 NRC Audit RBS-058 This item was closed during the October 2014 NRC Audit RBS-059 This item was closed during the October 2014 NRC Audit RBS-060 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit RBS-061 (associated with ISE Confirmatory Items 3.2.1.4.8 and 3.2.1.8.A)

This item was closed subsequent to the NRC Audit, by RBS-062 email dated 1/24/2015 (from John Hughey to D.H.

Williamson)

RBS-063 This item was closed during the October 2014 NRC Audit This item was closed during the October 2014 NRC Audit (associated with ISE Confirmatory Item 3.2.1.7.A)

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. The River Bend OIP stated in multiple locations that the RPV pressure would be manually reduced to a range between 100 and 200 psig and maintained in that band during the time that RCIC is providing core cooling and makeup. Entergy has revised the RPV pressure range to between 200 and 400 psig. The preferred method of operating RCIC is to manually control flow by varying the speed of the turbine and pump. The lower pressure band required the turbine/pump speed to be reduced below recommended speeds for the turbine and pump when providing the lower, required makeup late in the scenario. The higher pressure band allows RCIC to provide the lower required makeup while operating at the lowest allowable speed. This revision is not a change in the RBS strategy, but is a change in the parameters for RCIC operation.

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Attachment RBG-47546 February 25, 2015

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).
5. 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), RBG-47502, dated August 28, 2014.
6. NRC Email, "Closure of RBS Audit Item 62-B" from J. Hughey (NRC) to D. Williamson (Entergy), dated January 24, 2015.
7. "River Bend Station Unit 1 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051," dated Feb. 18, 2015 (ML15026A645)

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