GNRO-2015/00052, Fifth 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)

Fifth 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)

ML15240A020
Person / Time
Site:	Grand Gulf
Issue date:	08/28/2015
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, GNRO-2015/00052
Download: ML15240A020 (14)

Text

Q

~Entergy Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2015/00052 August 28, 2015 u.s. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

2. Entergy Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27,2013 (GNRO-2013/00015, ML13059A316)

3. Entergy Letter to NRC, Entergy's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013 (GNRO-2013/0060, ML13240A264)

4. Entergy Letter to NRC, Entergy's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2014 (GNRO-2014/00011, ML14059A080).

5. Entergy Letter to NRC, 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), dated August 26,2014 (GNRO-2014/00060, ML14239A316).

GNRO-2015/00052 Page 2 of 3 6 Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537).

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). References 3, 4, 5 and 6 provided the first, second, third and fourth six-month status reports. The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. James J. Nadeau, Regulatory Assurance Manager, at (601) 437-2103.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2015.

Sincerely,

~'W-(- - - ---"'"'----a......--

KJM/ras 3

Attachment:

Grand Gulf Nuclear Station's Fifth 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: See next page

GNRO-2015/00052 Page 3 of 3 cc: U. S. Nuclear Regulatory Commission AnN: Kriss Kennedy Deputy Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRR/DORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Jessica A. Kratchman Mail Stop OWFN/9 02 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2015/00052 Grand Gulf Nuclear Station's Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigatio'n Strategies for Beyond-Design-Basis External Events

Attachment to GNRO-2015/00052 Page 1 of 10 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference?), 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, 2015, and are current as of July 31, 2015:

• Submit Six-Month Status Report 4 - February 2015

• Submit Six-Month Status Report 5 - Complete with submission of this document in August 2015

• Develop Mods (Design Complete) - Complete with submission of this document in August 2015 with ongoing design support throughout the implementation phase

• Develop Strategies / Contract with NSRC - Complete with submission of this document in August 2015 with the response plan final report issued in September 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.

These milestone target dates do not impact the Order implementation date.

Revised Target Target Milestone Completion Activity Status Completion Date" Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit Six-Month Updates:

Report 1 Aug 2013 Complete Report 2 Feb 2014 Complete

Attachment to GNRO-2015/00052 Page 2 of 10 Revised Target Target Milestone Completion Activity Status Completion Date t Date Report 3 Aug 2014 Complete Report 4 Feb 2015 Complete I, Report 5 Aug 2015 Complete Report 6 Feb 2016 Not Started Report 7 Deleted* Deleted Perform Staffing Analysis July 2015 Started Note 1 Oct 2015 Modifications Develop Mods (Design Start) May 2014 Complete Develop Strategies Nov 2014 Complete Develop Mods (Design Complete) Mar 2015 Com plete Note 2 Implementation Outage** Mar 2016 Not Started Implement Mods Mar 2016 Started On-site FLEX Equipment Purchase Feb 2015 Started Sept 2015 Procure Dec 2015 Started Off-site FLEX Equipment Develop Strategies / Contract with Com plete Note 3 July 2015 Sept 2015 NSRC Procedures Issue GG FSGs Mar 2016 Started" Create Maintenance Procedures Oct 2015 Not Started Procedure Changes Training Feb 2016 Not Started Material Complete Training Develop Training Plan March 2015 Started Sept 2015 Implement Training Feb 2016 Not Started Validation I Demonstration Mar 2016 Not Started Submit Completion Report Aug 2016 Not Started

• Deleted due to Completion Report being submitted in August 2016.

• • Full compliance since second refueling outage is before 12/31/2016.

Attachment to GNRO-2015/00052 Page 3 of 10 "Tarqet Completion Date is the last submitted date from either the overall integrated plan or previous six-month status report.

Note 1 - Onsite staffing analysis complete. Staffing analysis report will be issued to NRC October 2015.

Note 2 - Design support continues for any change during modification implementation, procedure development, or validation.

Note 3 - Onsite assessment complete. The GG Response Plan will be issued September 2015.

4 Changes to Compliance Method In the continuing design development phase of the FLEX project at GGNS, changes have been identified to the compliance strategies as described in the original OIP (Reference 1). The significant changes are described below. The changes will be incorporated into a future or the final OIP update.

• The 480 VAC portable diesel generator size has changed to 300 kW. This is based on repowering the installed diesel fuel oil transfer pump for the fuel oil strategy as outlined in Section 4 of GGNS's second six month FLEX status report (Reference 5 of section 8) in addition to increasing the margin available to repower the station battery chargers.

• The OIP states that 6000 CFM of ventilation is provided to the main control room via the deployment of portable ventilation fans powered from a 120 VAC 3 kW portable diesel generator. The 01P text that states two 6000 CFM fans will be deployed is corrected and clarified to state that 6000 CFM of ventilation will be provided via one or more portable fans powered by a 5.5 kW portable diesel generator staged adjacent to the control building entrance as described in the OIP.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation GGNS expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes a listing of Audit Questions and the status of each item.

Overall Integrated Plan Open Items Status

1. Structure, content and details of the National SAFER Onsite assessment Resource Center (NSRC) Grand Gulf Response Plan complete. The GG will be determined. Response Plan will be issued September 2015.

Attachment to GNRO-2015/00052 Page 4 of 10 Interim Staff Evaluation Open Items Status 3.1.2.A Since the GGNS Probable Maximum This Open Item was Precipitation is greater than the grade addressed in Section 4 of elevation and sandbags are needed to GGNS's second six month protect against flooding, it is unclear how FLEX status report GGNS can be designated as a "dry" site. (Reference 5 of section 8).

Since the licensee identified GGNS as a dry site, licensee information related to NEI 12-06 guidelines identified in this report, Sections 3.1.2.1, 3.1.2.2, and 3.1.2.3 (storage, deployment, and procedural interfaces, respectively) are not discussed.

If the resolution of this Open Item results in GGNS not being categorized as a "dry" site, the guidelines of the NEI 12-06 Sections related to these report sections will need to be addressed by the licensee as part of that resolution.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Confirm that the storage facilities and This Confirmatory Item was plans will conform to the guidance in NEI addressed in Section 4 of 12-06, Section 5.3.1, for protection from GGNS's second six month seismic events. FLEX status report (Reference 5 of section 8) 3.1.3.1.A Confirm that at least one of the two FLEX This Confirmatory Item was equipment storage buildings would not be addressed in Section 4 of damaged by tornado missiles, based on GGNS's second six month the guidance in NEI 12-06, Section 7.3.1. FLEX status report (Reference 5 of section 8) 3.1.3.2.A Confirm that procedures address UHS This item is addressed by usability when wind generated debris is the update to the AQ present in the UHS. GGN-052 response 3.2.1.1.A Confirm that the final Modular Accident This item is addressed by Analysis Program Revision 4 (MAAP4) the update to the AQ analysis of the RCS response conforms to GGN-019 response the NEI position paper dated June 2013, entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (ADAMS Accession Number ML13190A201) and the MAAP4 limitations of the NRC endorsement letter, dated October 3, 2013

Attachment to GNRO-2015/00052 Page 5 of 10 Interim Staff Evaluation Confirmatory Items Status (ADAMS Accession No. ML13275A318).

3.2.1.2.A Confirm that the MAAP4 analysis includes This item is addressed by appropriate recirculation pump seal the update to the AQ leakage. GGN-025 response 3.2.1.3.A Confirm that the final Sequence of Events This item is addressed by (SOE) reflects the results of the final the update to the AQ MAAP4 analysis of the RCS response and GGN-026 response the licensee provides reasonable assurance by some means (e.g. by walkthrough) that the timing of the actions in the SOE is achievable.

3.2.1.4.A Confirm that operation with the This item is addressed by suppression pool temperature at its the update to the AQ calculated maximum temperature will not GGN-024 response impact the mitigation strategies, especially RCIC operation and structural integrity of the suppression pool.

3.2.1.8.A Confirm that the hydraulic calculations for This item is addressed by the FLEX pumps demonstrate that the the update to the AQ required flow rates can be achieved. GGN-034 response 3.2.2.A Confirm that the SFP area ventilation This item is addressed by calculation demonstrates that portable the update to the AQ ventilation is not required in the SFP area, GGN-039 response or that the licensee provides a strategy to use portable ventilation.

3.2.3.A Confirm that the licensee's strategy for This item is addressed by maintaining containment capabilities the update to the AQ considers the results of the final MAAP4 GGN-026 response analysis for RCS leakage and the containment venting strategy.

3.2.4.2.A Confirm that the RCIC room heat up This item is addressed by calculation for ELAP uses appropriate heat the update to the AQ loads and shows an acceptable room GGN-045 response temperature.

3.2.4.4.A Confirm that any required upgrades to the NRC Confirmatory Action**

site's communications systems have been completed, as noted in the NRC's review of the GGNS communications assessment (ADAMS Accession No. ML13129A132).

3.2.4.8.A Confirm that the licensee's analyses for This item is addressed by size and loading of FLEX generators the update to the AQ shows acceptable results. GGN-034 response

Attachment to GNRO-2015/00052 Page 6 of 10 Interim Staff Evaluation Confirmatory Items Status 3.2.4.8.B Confirm that the licensee's final proposed This item is addressed by connections of FLEX Phase 2 and 3 the update to the AQ electrical equipment to the permanent GGN-053 response plant equipment are acceptable.

3.2.4.9.A Confirm that the licensee has plans to This item is addressed by refuel FLEX equipment based on the fuel the update to the AQ oil consumption rates. GGN-055 response 3.2.4.10.A Confirm the acceptability of RCIC operation This item is addressed by without the gland seal compressor (de- the update to the AQ energized 30 minutes after loss of all ac GGN-072 response power).

3.2.4.10.B Confirm that the calculations regarding This item is addressed by battery sizing which show that Vital the update to the AQ Batteries can provide required loads for at GGN-031 response least 1*1 hours (considering load shedding) are acceptable.

Audit Completion or Status Questions Target Date GGN-001 Closed* - Response available on the ePortal.

Closed* - Response available on the ePortal.

GGN-002 (associated with ISE Confirmatory Item 3.1.1.1.A)

Closed* - Updated response available on the GGN-003 ePortal. (associated with ISE Confirmatory Item 3.1.3.1.A)

GGN-005 Closed* - Response available on the ePortal.

GGN-007 Closed* - Response available on the ePortal.

GGN-008 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-010 ePortal.

GGN-011 Closed* - Response available on the ePortal.

GGN-012 Closed* - Response available on the ePortal.

GGN-013 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-014 ePortal.

GGN-015 Closed* - Response available on the ePortal.

Attachment to GNRO-2015/00052 Page 7 of 10 Audit Completion or Status Questions Target Date GGN-016 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-017 ePortal.

Closed* - Updated response available on the GGN-019 ePortal. (associated with ISE Confirmatory Item 3.2.1.1.A).

Closed* - Updated response available on the GGN-021 ePortal.

GGN-022 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-023 ePortal.

Closed* - Updated response available on the GGN-024 ePortal. (associated with ISE Confirmatory Item 3.2.1.4.A).

Closed* - Updated response available on the GGN-025 ePortal. (associated with ISE Confirmatory Item 3.2.1.2.A).

Closed* - Updated response available on the GGN-026 ePortal. (associated with ISE Confirmatory Items 3.2.1.3.A and 3.2.3.A).

Closed* - Updated response available on the GGN-028 ePortal.

Closed* - Updated response available on the GGN-029 ePortal.

In Progress - This AQ response will be updated GGN-030 Sept 2015 when information is available.

In Progress - Updated response available on the GGN-031 ePortal. (associated with ISE Confirmatory Item Sept 2015 3.2.4.10. B).

In Progress - Updated response available on the GGN-034 ePortal. (associated with ISE Confirmatory Items Sept 2015 3.2.1.8.A and 3.2.4.8.A).

Closed* - Updated response available on the GGN-036 ePortal.

Closed* - Updated response available on the GGN-038 ePortal.

Closed* - Updated response available on the GGN-039 ePortal. (associated with ISE Confirmatory Item

Attachment to GNRO-2015/00052 Page 8 of 10 Audit Completion or Status Questions Target Date 3.2.2.A).

GGN-040 Closed* - Response available on the ePortal.

GGN-041 Closed* - Response available on the ePortal.

GGN-042 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-043 ePortal.

GGN-044 Closed* - Updated response available on the ePortal.

Closed* - Updated response available on the GGN-045 ePortal. (associated with ISE Confirmatory Item 3.2.4.2.A).

GGN-046 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-047 ePortal.

GGN-048 Closed* - Response available on the ePortal.

GGN-050 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-052 ePortal. (associated with ISE Confirmatory Item 3.1.3.2.A).

Closed* - Updated response available on the GGN-053 ePortal. (associated with ISE Confirmatory Item 3.2.4.8.8).

In Progress - Updated response available on the GGN-055 ePortal. (associated with ISE Confirmatory Item Sept 2015 3.2.4.9.A).

In Progress - Updated response available on the GGN-057 Sept 2015 ePortal.

GGN-058 Closed* - Response available on the ePortal.

GGN-061 Closed* - Response available on the ePortal.

Closed* - Updated response available on the GGN-062 ePortal.

In Progress - Updated response available on the GGN-063 Sept 2015 ePortal.

Closed* - Updated response available on the GGN-064 ePortal.

GGN-065 Closed* - Response available on the ePortal.

Attachment to GNRO-2015/00052 Page 9 of 10 Audit Completion or Status Questions Target Date GGN-066 Closed* - Response available on the ePortal.

GGN-067 Closed* - Response available on the ePortal.

In Progress - Updated response available on the GGN-071 Sept 2015 ePortal.

Closed* - Updated response available on the GGN-072 ePortal. (associated with ISE Confirmatory Item 3.2.4.10.A).

• Closed indicates that Entergy's response is complete.

• • This item is addressed by NRC confirmation of implementation of the issued modifications for the site's communications systems.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except those identified in Section 4.

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

1. "Overall Integrated Plan in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013 (GNRO-2013/00015, ML13059A316).

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12, 2012 (ML12054A735).

3. Entergy Letter to NRC, Entergy's first Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013 (GNRO-2013/0060, ML13240A264).

4. NRC Letter, "Grand Gulf Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)

(TAC No. MF0954)," dated February 19, 2014 (ML14007A718).

5. Entergy Letter to NRC, Entergy's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Attachment to GNRO-2015/00052 Page 10 of 10 (Order Number EA-12-049), dated February 28,2014 (GNRO-2014/00011, ML14059A080.

6. Entergy Letter to NRC, 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), dated August 26,2014 (GNRO-2014/00060, ML14239A316).

7. Entergy Letter to NRC, 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), dated February 19, 2015 (GNRO-2015/00004, ML15054A537).