PNP 2013-064, 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)

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)

ML13241A234
Person / Time
Site:	Palisades
Issue date:	08/28/2013
From:	Vitale A Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, PNP 2013-064
Download: ML13241A234 (9)

Text

~ Entergy Entergy Nuclear'Operatlons, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 7642000 Anthony J. Vitale Site Vice President PNP 2013-064 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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 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 (ADAMS Accession No.

12054A736)

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 (ADAMS Accession No. ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

4. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2012-091, 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) , dated October 25, 2012 (ADAMS Accession No. ML12300A065

5. Entergy Nuclear Operations, Inc. (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 Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2013

PNP 2013-064 Page 2 of 2

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 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 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 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 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. The purpose of this letter is to provide the first 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.

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 August 28,2013.

Sincerely, ajv/jse

Attachment:

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 Events (Order Number EA-12-049) cc: Office Director, NRR, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT 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 Events (Order Number EA-12-049) 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 strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013.

None.

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.

• FLEX Strategy Evaluation The FLEX Strategy Evaluation is underway. The milestone target completion date has been changed to December 2013. This new milestone target completion date does not impact the Order implementation date.

• Modifications Evaluation The Modifications Evaluation is underway. The milestone target completion date has been changed to January 2014. This new milestone target date does not impact the Order implementation date.

• N-1 Walkdown The N-1 Walkdown milestone date was changed to February 2014. This engineering design walkdown was to coincide with the refueling outage prior to the implementation outage. The Page 1 of 7

date of this refueling outage.has"changect/sna is' now' scheduled to end in F.ebruary:201'4:*

This new milestone target completion date does not impact the Order implementation date.

• Implementation Outage The Implementation Outage milestone target completion date changed to October 2015.

This is the outage that wi" implement FLEX modificatior:ls, which require the plant to be in a shutdown mode. The date of this refueling outage has changed and is now scheduled to end in October 2015. This new milestone target date does not impact the Order implementation date.

• Purchase and Procure The Purchase and Procure milestone date changed to June 2014 to better align with the Design Engineering milestone, which wi" determine the specific equipment required. This new milestone target completion date does not impact the Order implementation date.

• Develop Strategies with Regional Response Center The Develop Strategies with Regional Response Center (RRC) milestone date was changed to January 2015. This new milestone target completion date does not impact the Order implementation date.

• Insta" Off-Site Delivery Station (If Necessary)

The Insta" Off-Site Delivery Station milestone date was changed to October 2015. This milestone date was revised due to a change in the 2015 refueling outage schedule, which changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion date does not impact the Order implementation date.

• Create Palisades FLEX Support Guideline The Create Palisades FLEX Support Guideline (FSG) milestone date was changed to March 2015. This milestone date was revised due to a change in the 2015 refueling outage schedule, which changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion date does not impact the Order implementation date.

• Create Maintenance Procedures The Create Maintenance Procedures milestone date was changed to March 2015. This milestone date was revised due to a change in the 2015 refueling outage schedule, which changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion date does not impact the Order implementation date.

• Develop Training Plan The Develop Training Plan milestone date was changed to June 2015. This milestone date was revised due to a change in the 2015 refueling outage schedule, which changed from the Spring of 2015 to the Fa" of 2015. This new milestone target completion date does not impact the Order implementation date.

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• Training Complete The Training Complete milestone date was changed to September 2015. This milestone date was revised due to a change in the 2015 refueling outage schedule, which changed from the Spring of 2015 to the Fall of 2015. This new milestone target completion date does not impact the Order implementation date.

• ValidationlDemonstration A FLEX strategy Validation/Demonstration target completion date has been added to the milestone listing . The validation/demonstration will be completed October 2015 following FLEX modification implementation.

• Submit Completion Report The Submit Completion Report target completion date was changed to coincide with the implementation Outage milestone date of October 2015. This new milestone target date does not impact the Order implementation date.

Revised Target Target Milestone Completion Activity Status Completion Date Date Submit Overall Integrated Feb 2013 Complete Implementation Plan 6 Month Status Updates Update 1 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Apr 2013 Started Dec 2013 Perform Staffing Analysis Dec 2013 Started Modifications Modifications Evaluation Jun 2013 Started Jan 2014 Engineering and Implementation N-1 Walkdown Nov 2013 Not Started Feb 2014 Design Engineering May 2014 Started Page 3 of 7

Revised Target Target Milestone Completion Activity Status Completion Date Date Implementation Outage Mar 2015 Not Started Oct 2015 On-site FLEX Equipment Purchase and Procure Dec 2013 Not Started Jun 2014 Off-site FLEX Equipment Develop Strategies with RRC Nov 2013 Started Jan 2015 Install Off-Site Delivery Station May 2015 Not Started Oct 2015 (If Necessary)

Procedures Pressurized Water Reactor Owners Group (PWROG) issues Nuclear Steam Supply Jun 2013 Complete System (NSSS)-Specific Guidelines Create Palisades FLEX FSG Oct 2014 Not Started Mar 2015 Create Maintenance Procedures Oct 2014 Not Started Mar 2015 Training Develop Training Plan Jan 2015 Not Started Jun 2015 Training Complete Apr2015 Not Started Sept 2015 Validation I Demonstration Oct 2015 Not Started Submit Completion Report May 2015 Not Started Oct 2015 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.

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6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the overall integrated plan or the Draft Safety Evaluation, and the status of each item.

Overall Integrated Plan Open Item Status 011 . Perform analysis on Palisades' susceptibility to soil Started liquefaction and potential consequences on the FLEX implementation plan.

012. Develop Phase 3 deployment strategy with Started correspondence with the RRC.

013. Evaluate the need to missile protect primary system Started makeup storage tank (T-81) and other external tanks.

014. Select the location of FLEX equipment storage Started facility.

015. Perform seismic evaluation of turbine-driven Started auxiliary feedwater pump (TDAFWP) driver K-8.

016. Evaluate strategies to extend battery coping time. Started 017. Evaluate sources of non-borated water in addition Started to condensate storage tank (T-2) and T-81.

018. Palisades Probabilistic Risk Assessment (PRA) to Not Started provide justification why battery room ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

019. Evaluate the effects of FLEX on security Started procedures.

0110. Evaluate requirements of mobile purification unit Started from RRC.

0111. Evaluate requirements of mobile boration unit Started from RRC.

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Overall Integrated Plan~ Open Item' Status-0112. Evaluate methods of venting the fuel handling l Started building.

0113. Evaluate the use of high-efficiency LED lighting. Started 0114. Perform evaluation to determine if additional Started parameters will need to be monitored during FLEX activities.

0115. Perform analysis to ensure survivability of Not Started containment.

0116. Evaluate borated water sources in addition to Started safety injection refueling water tank (SIRWT).

0117. Entergy, for the Palisades site, will negotiate and Complete execute a contract with Strategic Alliance for FLEX Emergency Response (SAFER) that will meet the requirements of NEI 12-06, Section 12.

0118. Evaluate a location to install a tee in the service Not Started wa't er system to allow the ultimate heat sink (UHS)

FLEX pump to provide cooling.

0119. Evaluate the use of lake water to cool the steam Not Started generators during an extended loss of ac power (ELAP).

0120. Evaluate time until primary coolant system (PCS) Started makeup is necessary in Modes 5 & 6.

0121. Evaluate connection to ensure cooling water can Started be provided for containment air fans.

0122. Evaluate the robustness of the charging pumps. Started Draft Safety Evaluation Open Item Status None.

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7 Potential Draft Safety Evaluation Impacts The Draft Safety Evaluation has not been issued at this time.

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

1. Entergy Nuclear Operations, Inc. (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 Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2013

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 (ADAMS Accession No. ML12054A736).

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