PNP 2015-083, Notification of Full Compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

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Notification of Full Compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
ML15351A369
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/16/2015
From: Vitale A
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15351A351 List:
References
EA-12-049, PNP 2015-083
Download: ML15351A369 (3)
v • d • e


Text

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~ Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant ~

27780 Blue Star Memorial Highway Covert, MI 49043*9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2015-083 December 16, 2015 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk 11 555 Rockville Pike Rockville, MD 20852

SUBJECT:

Notification of Full Compliance with NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events, dated March 12,2012 (ADAMS Accession No. ML12054A736).
2. Entergy Nuclear Operations, Inc. 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 Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated February 28,2013 (ADAMS Accession No. ML13246A399).
3. NRC letter, Palisades Nuclear Plant -Interim Staff Evaluation Regarding Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0768), dated February 10, 2014 (ADAMS Accession No. ML13365A264).
4. NRC letter, Palisades Nuclear Plant - 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 (TAC Nos. MF0768 AND MF0769), dated October 13, 2015 (ADAMS Accession No. ML15272A324).

Dear Sir or Madam:

The purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) that Entergy Nuclear Operations, Inc. (ENO) Palisades Nuclear Plant (PNP) is in compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 1). On March 12, 2012, the NRC issued Order EA-12-049 which was immediately effective and directed ENO to develop and implement

PNP 2015-083 Page 2 of 3 strategies and guidance to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Order EA-12-049,Section IV.A.2, requires full implementation to be no later than two refueling cycles after submittal of the overall integrated plan (OIP), or December 31, 2016, whichever comes first. In addition,Section IV.C.3 of Order EA-12-049 requires that licensees report to the NRC when full compliance is achieved. The PNP OIP for Order EA-12-049 was submitted on February 28,2013 (Reference 2). On October 19, 2015, PNP entered Mode 2 (startup),

completing two refueling cycles after submittal of the OIP. PNP was in full compliance with Order EA-12-049 at that time.

In Reference 3, the NRC issued an interim staff evaluation (ISE) for Order EA-12-049, which identified open and confirmatory items requiring resolution by ENO.

In Reference 4, the NRC issued a report for an audit conducted at PNP regarding implementation of mitigating strategies and reliable spent fuel pool instrumentation related to Orders EA-12-049 and EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation." The audit included a review of ENO responses to the ISE open and confirmatory items. summarizes PNP compliance with Order EA-12-049. Attachment 2 summarizes PNP compliance with the elements of the Order. Attachment 3 contains responses to the open items from the onsite audit. Attachment 4 contains responses to Interim Staff Evaluation open and confirmatory items. Attachment 5 contains the Final Integrated Plan (FIP) for PNP. The FIP provides strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event at PNP. Attachment 6 contains a system operating procedure attachment that describes measures to protect FLEX equipment from cold weather conditions, which was specifically requested during the onsite audit.

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 December 16, 2015.

Sincerely, AJV/jse Attachments: 1. Compliance with Order EA-12-049

2. Order EA-12-049 Compliance Elements Summary
3. Audit Open Item Responses
4. Interim Staff Evaluation Open Item and Confirmatory Item Responses
5. Final Integrated Plan
6. System Operating Procedure 23, "Plant Heating System," Attachment 14, "Actions When Outside Temperatures Are Less Than 20°F"

1"'1'11"' ~Ul b-UI::S::S Page 3 of 3 cc: Office Director, NRR, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

~ Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant ~

27780 Blue Star Memorial Highway Covert, MI 49043*9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2015-083 December 16, 2015 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk 11 555 Rockville Pike Rockville, MD 20852

SUBJECT:

Notification of Full Compliance with NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events, dated March 12,2012 (ADAMS Accession No. ML12054A736).
2. Entergy Nuclear Operations, Inc. 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 Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated February 28,2013 (ADAMS Accession No. ML13246A399).
3. NRC letter, Palisades Nuclear Plant -Interim Staff Evaluation Regarding Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0768), dated February 10, 2014 (ADAMS Accession No. ML13365A264).
4. NRC letter, Palisades Nuclear Plant - 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 (TAC Nos. MF0768 AND MF0769), dated October 13, 2015 (ADAMS Accession No. ML15272A324).

Dear Sir or Madam:

The purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) that Entergy Nuclear Operations, Inc. (ENO) Palisades Nuclear Plant (PNP) is in compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 1). On March 12, 2012, the NRC issued Order EA-12-049 which was immediately effective and directed ENO to develop and implement

PNP 2015-083 Page 2 of 3 strategies and guidance to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Order EA-12-049,Section IV.A.2, requires full implementation to be no later than two refueling cycles after submittal of the overall integrated plan (OIP), or December 31, 2016, whichever comes first. In addition,Section IV.C.3 of Order EA-12-049 requires that licensees report to the NRC when full compliance is achieved. The PNP OIP for Order EA-12-049 was submitted on February 28,2013 (Reference 2). On October 19, 2015, PNP entered Mode 2 (startup),

completing two refueling cycles after submittal of the OIP. PNP was in full compliance with Order EA-12-049 at that time.

In Reference 3, the NRC issued an interim staff evaluation (ISE) for Order EA-12-049, which identified open and confirmatory items requiring resolution by ENO.

In Reference 4, the NRC issued a report for an audit conducted at PNP regarding implementation of mitigating strategies and reliable spent fuel pool instrumentation related to Orders EA-12-049 and EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation." The audit included a review of ENO responses to the ISE open and confirmatory items. summarizes PNP compliance with Order EA-12-049. Attachment 2 summarizes PNP compliance with the elements of the Order. Attachment 3 contains responses to the open items from the onsite audit. Attachment 4 contains responses to Interim Staff Evaluation open and confirmatory items. Attachment 5 contains the Final Integrated Plan (FIP) for PNP. The FIP provides strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event at PNP. Attachment 6 contains a system operating procedure attachment that describes measures to protect FLEX equipment from cold weather conditions, which was specifically requested during the onsite audit.

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 December 16, 2015.

Sincerely, AJV/jse Attachments: 1. Compliance with Order EA-12-049

2. Order EA-12-049 Compliance Elements Summary
3. Audit Open Item Responses
4. Interim Staff Evaluation Open Item and Confirmatory Item Responses
5. Final Integrated Plan
6. System Operating Procedure 23, "Plant Heating System," Attachment 14, "Actions When Outside Temperatures Are Less Than 20°F"

1"'1'11"' ~Ul b-UI::S::S Page 3 of 3 cc: Office Director, NRR, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

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