PNP 2014-085, 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)
| ML14240A279 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/28/2014 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, PNP 2014-085 | |
| Download: ML14240A279 (19) | |
Text
.-
- ~ Entergy
Iii
- 11.E, 1LI7jY Entergy Entergy Nuclear Palisades 27780 Blue 27780 Covert, Nuclear Operations, Palisades Nuclear Blue Star Covert, MI Operations, Inc.
Nuclear Plant Plant Star Memorial Inc.
Memorial Highway MI 49043-9530 49043-9530 Highway Tel 269 Tel 269 764 764 2000 2000 Anthony J.
Anthony J. Vitale Vitale Site Site Vice President President PNP 2014-085 August 28, 2014 u.s.
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
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)
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 8eyond-Design-Basis Beyond-Design-Basis 12, 2012 (ADAMS Accession No.
External Events, dated March 12,2012 1 2054A736) 12054A736)
- 2. NRC Interim Staff Guidance JLD-ISG-2012-01, 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, Revision 0, dated August 29, 2012 (ADAMS Accession No. No.
ML1 2229A1 74)
- 3. NFl 12-06, Diverse and Flexible Coping Strategies (FLEX)
NEI12-06, Implementation Guide, Revision 0, dated August 2012 (ADAMS 0, dated Accession No.
No. ML1 2242A378)
- 4. Entergy Entergy Nuclear Operations, Operations, Inc.
Inc. letter to NRC, NRC, PNP PNP 2012-091, 2012-091, Initial Status Status Report in Response to March March 12, 2012 Commission 12,2012 Commission Order Modifying Modifying Licenses Licenses with with Regard to Requirements for Mitigation Mitigation Strategies Strategies for Beyond-Design-Basis Beyond-Design-Basis External Events Events (Order Number EA-12-049),
EA-12-049), dated dated October October 25, 2012 (ADAMS 25,2012 (ADAMS Accession Accession No.No.
ML1 2300A065)
- 5. Entergy
- 5. Entergy Nuclear Nuclear Operations, Operations, Inc. letter to Inc. letter to NRC, NRC, PNP PNP 2013-010, 2013-010, Overall Overall Integrated Integrated Plan in in Response Response to March 12, to March 12, 2012 2012 Commission Commission Order Order Modifying Modifying Licenses Licenses with with Regard Regard to to Requirements Requirements for Mitigation Mitigation Strategies Strategies for for Beyond-Design-Basis Beyond-Design-Basis External External Events Events (Order (Order Number Number EA-12-049), dated February EA-12-049), dated February 28, 2013 (ADAMS 28,2013 (ADAMS Accession Accession No.No.
ML1 3246A399)
PNP 2014-085 PNP 2014-085 Page 22 of Page of 33
- 6. Entergy
- 6. Entergy Nuclear Nuclear Operations, Operations, Inc.
Inc. letter letter to NRC, PNP to NRC, PNP 2013-064, 2013-064, Palisades Nuclear Palisades Nuclear Plant Plant First First Six-Month Six-Month Status Status Report Report in in Response Response toto March 12, 2012 March 12, 2012 Commission Commission Order Modifying Licenses Order Modifying Licenses with with Regard Regard toto Requirements for Requirements for Mitigation Mitigation Strategies Strategies for for Beyond-Design-Basis Beyond-Design-Basis External Events External Events (Order (Order Number Number EA-12-049),
EA-12-049), dated August August 28,2013 28, 2013 (ADAMS Accession No. No. ML ML113241 A234) 3241 A234)
- 7. Entergy
- 7. Entergy Nuclear Operations, Inc. Inc. letter letter to NRC, PNP 2014-011, NRC, PNP Palisades Nuclear Plant Second Six-Month Status Report Report in Response
Response
to March 12,12, 2012 Commission Commission OrderOrder Modifying Licenses with Regard Strategies for Beyond-Design-Basis to Requirements for Mitigation Strategies (Order Number EA-12-049),
External Events (Order EA- 12-049), dated February 28,2014 28, 2014 (ADAMS Accession No. ML ML114059A078) 4059A078)
Dear Sir or Madam:
12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1)
On March 12,2012, 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 pooi cooling capabilities in the event of a beyond-design-basis external event.
Reference 11 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, 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.
The purpose of this letter is to provide the third six-month status report pursuant to Section IV, IV, Condition C.2, of Reference 1, 1, that delineates delineates progress mademade in implementing the requirements of Reference 1. 1. The attachment attachment provides an an update of milestone accomplishments, including any any changes to the compliance method, schedule, or need for relief and the basis, ifif any.
This This letter letter contains no new commitments and no new and no no revised commitments.
II declare declare under under penalty penalty of of perjury perjury that the foregoing foregOing isis true true and and correct; executed executed on August 28, 28, 2014.
2014.
ncerely Sincerely, ,,
ajv/jse ajv/jse
PNP 2014-085 Page 3 of 3
Attachment:
Palisades Nuclear Plant Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements 12, for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) cc: Office Director, NRR, USNRC Ill, USNRC Administrator, Region III, Project Manager, Palisades, USNRC USN RC Resident Inspector, Palisades, USNRC
ATTACHMENT 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-1 2-049)
Events (Order Number EA-12-049) 1 Introduction 1
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 last status report (Reference 4), 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, 2014, and are current as 31, 2014.
of July 31,2014.
- Second Six-Month Status Report - February 2014
- Modifications Evaluation - April 2014
- N-i Walkdown - February 2014 N-1
- Third Six-Month Status Report - Complete with submission of this document in August 2014.
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.
- Perform Staffing Analysis The Perform Staffing Analysis milestone completion date has been changed to April 2015. This new milestone target completion date does not impact the Order implementation date.
- Modifications - Design Engineering The Design Engineering Engineering milestone completion date has been changed to September 2014. This new milestone target completion date does not not impact the Order implementation date.
date.
- On-site FLEX Equipment - Purchase and Procure The On-Site On-Site FLEX FLEX Equipment Purchase Purchase and and Procure Procure milestone milestone completion date has been date has been changed to to August 2015. This new new milestone target completion date date does does not impact impact the Order Order implementation date.
date.
Page Page 11 of 16 16
- Create PNP Create PNP FLEXFLEX FSG FSG The Create The Create PNP FLEX FSG PNP FLEX FSG milestone milestone completion completion date date has has been been changed changed to to December December 2014. This new 2014. This new milestone milestone target target completion completion date date does does not impact the not impact the Order Order implementation date.
implementation date.
Target Target Revised Revised Target Target Milestone Milestone Completion Completion Activity Status Status Completion Completion Date*
Date* Date Submit Overall Integrated Submit Integrated Feb 2013 Feb Complete Implementation Plan Implementation Plan Updates Six-Month Status Updates Update 11 Aug 2013 Complete Update 2 Feb2014 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Jan 2014 Complete Perform Staffing Analysis Apr2014 Started Apr2015 Modifications Modifications Evaluation Apr 2014 Apr2014 Complete Engineering and Implementation N-i Walkdown N-1 Feb 2014 Complete Design Engineering May 2014 In Progress September 2014 Implementation Outage Implementation Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Jun 2014 Started Aug 2015 Off-site FLEX Equipment Develop Strategies with RRC Jan 2015 Started Install Install Off-Site Delivery Delivery Station (If Oct 2015 2015 Not Started Necessary)
Necessary)
Procedures Pressurized Pressurized Water Reactor Owners Group (PWROG) issues Nuclear Group Nuclear Jun 2013 Jun 2013 Complete Steam Steam Supply Supply System (NSSS)
(NSSS)-
Specific Specific Guidelines Guidelines Create PNP Create PNP FLEX FLEX FSG FSG Mar Mar 2015 2015 Started Started Dec Dec 2014 2014 Create Create Maintenance Maintenance Procedures Procedures Mar Mar 2015 2015 Not Not Started Started Training Training Develop Develop Training Training Plan Plan Jun Jun 2015 2015 Not Not Started Started Training Complete Training Complete Sept 2015 Sept 2015 Not Not Started Started Page Page 22 of of 16 16
Target Revised Target Milestone Completion Activity Status Completion Date*
Date* Date Validation!I Demonstration Validation Oct 2015 Not Started Submit Completion Report Oct 2015 Not Started
- Target Completion Date
- Target Date is the last submitted date from either the overall integrated integrated plan or previous six-month status reports.
4 Changes to Compliance Method There are no changes to the compliance method as documented in previous correspondence.
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 interim Staff Evaluation (ISE) (Reference 5). A fourth fou rth 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 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 Item is 1SE ISE Open ItemItem 3.1.1 .2.A and is addressed on updated 3.1.1.2.A Audit Question (AQ) response spreadsheet on the ePortal.
012. Develop Phase 3 deployment deployment Started strategy with correspondence with Staging areas have been identified.
identified. The National the RRC.
SAFER Response Center Center (NSRC) [formerly known known as as the Regional Response Center (RRC)] kickoff meeting meeting was conducted on 7/22/14 to complete checklist as Page Page 33 of 1616
Overall Integrated Plan Open Item Status approved by AREVA. The NSRC and Palisades are in process of developing Site Response Plans. This Open Item is related to ISE Confirmatory Item 3.4.A Open and is addressed on updated 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 (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
-2 and TT-81
-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 T-81
-81 has been posted to the ePortal.
This Open Item is also addressed by updated AQ PAL-044 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 TDAFW pump is qualified qualified with the exception of an outlier related to a check for bolt tightness. Bolt tightness on the pump is being performed under under WO# 372138 and documented documented under EC 46465.
016. Evaluate strategies to extend Complete/Closed battery coping time.
The battery load 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 indicate a coping time of at least least 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> hours for the installed batteries Page 44 of of 16 16
Overall Integrated Plan Open Item Status accompanying the expected deep load shed list. This Open Item is addressed by updated AQ PAL-018 PAL-018 response.
017. Evaluate sources of non- Complete/Closed borated water in addition to T-81,, makeup to the steam After depletion of T-2 and T-81 condensate storage tank (T (T-2)
-2) and generators (SGs) will be from a portable pump with 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 updated 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 250 gpm NSRC demineralized water treatment unit is preferred over the 100 gpm NSRC reverse osmosis unit in order to support SG makeup and provide makeup to the NSRC mobile boration unit. The mobile purification 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.
0113. Evaluate the use of Complete/Closed high-efficiency LED lighting.
lighting.
The use of high-efficiency LED lighting lighting has been evaluated for its impact to battery coping time and control room heat heat loads. LED lighting would have have Page 55 of 16 16
Integrated Plan Open Item Overall Integrated Status minimal impact and is not required or recommended.
0114. Perform evaluation to Complete/Closed determine if additional parameters 12-06, PWROG FLEX guidance was NEt 12-06, In addition to NEI will need to be monitored during reviewed for key parameter monitoring. The NEI NEt 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 survivabiIit of containment.
survivability Containment analysis has been completed using the Modular Accident Analysis Program (MAAP). Results of this analysis show containment design parameters will not be exceeded for the at-power scenario (Le., (i.e.,
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 titled Shutdown "Shutdown / Refueling Modes."
Modes. This Open Item is addressed by updated 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 updated 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, 12-06, Section 12.
12.
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 downstream of service water FLEX pump to provide 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 NSRC UHSUHS pump. This Open Item is Open Item is related to ISE Confirmatory Item Item 3.2.4.1 .B and is 3.2.4.1.B is addressed on updated updated AQ response spreadsheet on the ePortal. ePortal.
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Overall Integrated Plan Open Item Status 0119. Evaluate the use of lake water Complete/Closed during 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 impacts
(
(ELAP). ). water as the makeup source. The analysis determined that the heat transfer capability of each steam generator was diminished by approximately 4.4%
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 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 (Le.,
(i.e., PCS level, pressure, 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 I/ 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 the status update to 01 Cl 18.
- 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 updated AQ PAL-041 response.
Interim 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 updated Audit Question equipment. (AQ) response spreadsheet on the ePortal.
ePorta!.
3.1.1 .2.B 3.1.1.2.8 Evaluate the potential need need for a power source This item is is addressed addressed on to move or deploy deploy the equipment (e.g., to open updated updated AQ response Page 7 ofof 16 16
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 updated AQ response potential impact on the mitigating strategies. spreadsheet on the ePortal.
3.1.1 .3.B 3.1.1.3.B Evaluate the potential for ground water to This item is addressed on mitigating strategies.
impact the mitigating updated AQ response spreadsheet on the ePortal.
3.1.5.1.A 3.1.S.1.A Evaluate the potential for high temperature This item is addressed on hazards to impact the functionality of FLEX updated AQ response facility, equipment in the FLEX storage facility. spreadsheet on the ePortal.
3.1.5.3.A 3.1.S.3.A Evaluate the potential for high temperature This item is addressed on hazards to impact the deployment of FLEX updated AQ response equipment. spreadsheet on the ePortal.
3.2.1.8.A Verify resolution of the generic concern This item is addressed by associated with the modeling of the timing and PAL-015 updated AQ PAL-01S 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.B Provide additional justification for the alternate This item is addressed by approach to N NEI EI 12-06 involving the use of updated AQ PAL-041 installed charging pumps. response.
Interim Staff Evaluation Confirmatory Items Status 3.1.3.1 .A 3.1.3.1.A Confirm that the FLEX storage facility(s) facility(s} will meet This item is addressed on plants design-basis tornado wind speed of 300 the plant's updated 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 updated AQ PAL-Cl PAL-0111 reasonably achievable when the associated ELAP response.
procedures are developed and validated.
3.2.1 .B 3.2.1.B Confirm the robustness of the charging pump This item is addressed by control circuit or provide provide FLEX procedure updated AQ PAL-Cl PAL-0111 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 updated AQ PAL-047 supply source for the charging pumps. response.
3.2.1 .D 3.2.1.D 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.
Page 88 of 1616
Interim Staff Evaluation Confirmatory Items Status 3.2.1 .E 3.2.1.E Confirm the continued functionality of the This item is addressed by Dump Valves in Atmospheric Dump in the context of aa updated AQ PAL-055 updated PAL-055 tornado missile hazard during an ELAP in order to response.
support a symmetric cooldown. Alternatively, address the effects of asymmetric natural circulation cooldown.
3.2.1 .F 3.2.1.F related Confirm the ability of any non-safety related This item is addressed by equipment to function as credited in the mitigation updated AQ PAL-043 strategies in accordance with the external event response.
criteria described in N NEI-12-06.
EI-12-06.
3.2.1.1 .A 3.2.1.1.A Confirm that the use of Combustion Engineering This item is addressed Nuclear Transient Simulator (CENTS) in the ELAP by updated AQ PAL-003 analysis is limited to the flow conditions prior to response.
reflux boiling initiation. This confirmation should 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 Confirm the Primary Coolant Pump (PCP) seal This item is addressed by leakage rate assumed in the ELAP analysis is updated AQ PAL-004 justified. Specifically, if the PCP seal leakage rate response.
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 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 updated AQ PAL-004 greater than 50 degrees Fahrenheit (O (°F).
F). This response.
evaluation should specify the seal leakage flow assumed for the ELAP from time zero to the timeframe when subcooling subcooling in the PCS cold-legs decreases to 50°F, and provide justification for the assumed leakage rate.
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 updated AQ PAL-004 assumption that the integrity of the PCP seals can response.
be maintained, and the seal leakage rate is less than 11 gpm per PCP during an ELAP before CBO is isolated. This evaluation should provide the maximum temperature and pressure and minimum subcooling of the coolant in the PCS cold legs during during the ELAP before CBO isolation. If CBO isolation is being assumed, justify the sequence of events (SOE) and and time constraints so established.
Page Page 99 of 16 16
Interim Staff Evaluation Confirmatory Items Status 3.2.1.3.A Confirm the applicability of ANS 5.1-1979 + +2 This item is addressed by curve, sigma decay heat curve. updated 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 updated AQ PAL-013 justify the adequacy of the computer response.
codes/methodologies, and assumptions used in the analysis.
3.2.1 .5.B 3.2.1.5.8 Confirm whether further instrumentation is needed This item is addressed by evaluations, based upon ongoing ELAP evaluations. updated AQ PAL-013, AQ PAL-027 and AQ PAL-035 responses.
3.2.1 .6.A 3.2.1.6.A Complete validation of the SOESQE timeline. This item is addressed by updated AQ PAL-030 response.
3.2.1.6.B 3.2.1.6.8 IInn the audit process, the licensee has indicated This item is addressed by that an assessment has been performed PAL-Ol 1 updated AQ PAL-011 identifying potential changes to the SOE.
SQE. Confirm response.
that a final SOE 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 100100 gallons per minute updated AQ response (gpm) SFP spray and the 250 gpm performance spreadsheet on the NEt 12-06, Table D-3.
attribute of NEI12-06, ePortal.
3.2.3.A Confirm the plan assumptions for containment This item is addressed by cooling, after completion of the containment updated AQ PAL-050 and response analysis. AQ PAL-053 responses.
3.2.4.1 .A 3.2.4.1.A Confirm whether supplemental cooling is required This item is addressed on for components or systems used in the mitigating updated AQ response strategies plan. spreadsheet on the ePortal.
3.2.4.1 .B 3.2.4.1.8 Confirm the connection point for the UHS FLEX This item is addressed on Pump to the Service Water System. updated AQ response spreadsheet on the ePortal.
3.2.4.2.A Confirm the adequacy of the ventilation provided This item is addressed by in in the battery room to protect protect the batteries from updated AQ PAL-023 the effects of extreme high and low temperatures. response.
3.2.4.2.B 3.2.4.2.8 Confirm the adequacy of battery room ventilation This item is addressed by to prevent hydrogen accumulation while updated AQ PAL-025 recharging the batteries inin Phase 2 oror Phase 3.
- 3. response.
Page 10 10 of of 16 16
Interim Staff Evaluation Confirmatory Items Status 3.2.4.3.A Confirm whether heat tracing is required for This item is addressed by borated water systems. updated AQ PALPAL-007
-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 on and/or operator protective measures will be updated AQ response employed in all phases of an ELAP to ensure spreadsheet on the operators will be capable of FLEX strategy 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 PAL-044 the strategy and the provisions of NEI 12-06. response.
3.2.4.7.B 3.2.4.7.8 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 updated AQ PAL-018 and throughout Phase 1 1 to assure the battery does not AQ PAL-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 updated AQ response conform to the criteria of NEI 12-06, Section 12.2, 12.2, spreadsheet on the with regards to considerations 2 through 10. ePortal.
Page Page 1111 of 16 16
Audit Completion or Target Status Question Date PAL-002 Closed*
Closed*
Updated response available on the ePortal (I(ISE SE PAL-003 3.2.1.i.A)
Confirmatory Item 3.2.1.1.A)
Updated response available on the ePortal (ISE 3.2.1 .2.A)
Confirmatory Item 3.2.1.2.A)
Updated response available on the ePortal (ISE PAL-004 3.2.1 .2.B)
Confirmatory Item 3.2.1.2.8)
Updated response available on the ePortal (I(ISE SE Confirmatory Item 3.2.1.2.C)
Updated response available on the ePortal (ISE PAL-007 PAL-OO?
Confirmatory Item 3.2.4.3.A)
PAL-008 PAL-OOB Updated response available on the ePortal Updated response available on the ePortal (ISE 3.2.1 .A)
Confirmatory Item 3.2.1.A)
Updated response available on the ePortal (ISE PAL-Ol 1 PAL-011 3.2.1 .B)
Confirmatory Item 3.2.1.8)
Updated response available on the ePortal (ISE 3.2.i.6.B)
Confirmatory Item 3.2.1.6.8)
Updated response available on the ePortal (ISE PAL-Ui 2 PAL-012 3.2.i.3.A)
Confirmatory Item 3.2.1.3.A)
(ISE Updated response available on the ePortal (I SE Confirmatory Item 3.2.1.5.A)
PAL-Ol 3 PAL-013 Updated response available on the ePortal (ISE 3.2.1.5.B)
Confirmatory Item 3.2.1.5.8)
Updated response available on the ePortal (I(ISE SE PAL-Ui 4 PAL-014 Confirmatory Item 3.2.i.9.A) 3.2.1.9.A)
Updated response available on the ePortal (ISE PAL-Ol PAL-0155 Open Item 3.2.1.8.A) 3.2.1.B.A)
PAL-Ui PAL-0166 Updated response available on the ePortal In progress - This AQ response will be updated PAL-Ui 7 PAL-01? Oct 2015 when information is available Updated response available on the ePortal (ISE PAL-Ui PAL-01B8 Confirmatory Item 3.2.4.iO.A) 3.2.4.1 O.A)
PAL-Ui9 PAL-019 Updated response available on the ePortal PAL-U2U PAL-020 Closed*
Closed*
PAL-02i PAL-021 Updated response available on the ePortal PAL-U22 PAL-022 Closed*
Closed*
PAL-U23 PAL-023 Updated response available on the ePortal (ISE (I SE Page 12 of Page 12 of 16 16
Audit Audit Completion or Completion or Target Target Status Status Question Question Date Date Confirmatory Item Confirmatory 3.2.4.2.A)
Item 3.2.4.2.A)
PAL-024 PAL-024 Closed*
Closed*
Updated response Updated response available available on the ePortal on the ePortal (ISE (ISE PAL-025 PAL-025 Confirmatory Item Confirmatory Item 3.2.4.2.8) 3.2.4.2.B)
PAL-026 PAL-026 Updated response Updated response available available on the ePortal on the ePortal available on the Updated response available the ePortal (I(ISE SE PAL-027 PAL-027 Item 3.2.1.5.8)
Confirmatory Item 3.2.1.5.B)
PAL-028 Updated response available on the ePortal Updated Updated response available on the ePortal (ISE PAL-030 Confirmatory Item 3.2.1.6.A)
Updated response available on the ePortal (ISE PAL-033 3.2.4.1O.A)
Confirmatory Item 3.2.4.1 O.A)
Updated response available on the ePortal (ISE PAL-035 Confirmatory Item 3.2.1.5.8) 3.2.1 .5.B)
PAL-036 Updated response available on the ePortal PAL-037 Updated response available on the ePortal PAL-039 Closed*
Closed*
PAL-040 Updated response available on the ePortal Updated response available on the ePortal (ISE PAL-041 3.2.1.9.B)
Open Item 3.2.1.9.8)
Updated response available on the ePortal (ISE PAL-043 Confirmatory Item 3.2.1.F)
Updated response available on the ePortal (ISE (I SE PAL-044 Confirmatory Item Item 3.2.4.7.A) 3.2.4.7 .A)
Updated response available on the ePortal (ISE (I SE PAL-045 Confirmatory Item 3.2.4.7.B) 3.2.4.7.8)
PAL-046 PAL-046 Updated response available available on the ePortal Updated Updated response available on the ePortal (ISE PAL-047 Confirmatory Confirmatory Item Item 3.2.1 .C) 3.2.1.C)
Updated Updated response available available on the ePortal on the ePortal (ISE (ISE PAL-048 PAL-048 Confirmatory Item 3.2.1.D)
Confirmatory Item 3.2.1.0)
PAL-049 Updated Updated response available available on on the the ePortal ePortal Updated response available Updated available on on the ePortal ePortal (ISE (ISE PAL-050 PAL-050 Confirmatory Item Item 3.2.3.A) 3.2.3.A)
In In progress progress - This This AQAQ response response will will be be updated updated PAL-051 PAL-051 Feb Feb 2015 2015 when information is available when information is available Updated Updated response response available available on on the the ePortal ePortal (ISE (ISE PAL-053 PAL-053 Confirmatory Item 3.2.3.A)
Confirmatory Item 3.2.3.A)
Page 13 Page 13 ofof 16 16
Audit Completion or Target Status Question Date PAL-054 PAL-OS4 response available on the ePortal Updated response Updated response available on the ePortal (ISE PAL-055 PAL-OSS Item 3.2.1.E)
Confirmatory Item PAL-056 PAL-OS6 Closed*
Closed*
PAL-057 PAL-OS7 Updated response available on the ePortal Closed indicates
- Closed indicates that that the ENO response the END response is is complete.
complete.
7 Potential Interim Staff Evaluation Impacts The following items have been identified which have potential impact to the Interim Staff (ISE) except for those identified in Section 6.
Evaluation (lSE)
ISE/TER, Section 3.0, Page 5, second paragraph, the ISE states, "A
- 1. ISElTER, A portable FLEX generator will be connected to the existing plant electrical distribution system system..
..... Another FLEX diesel generator will power one of the installed plant charging charging..... "
The current strategy uses only one FLEX generator. This FLEX generator is sufficiently sized to carry all the loads that are planned for use in the Phase 2 FLEX strategy.
ISE/TER Section 3.1.1.2, Page 8, second paragraph, the TER states "On
- 2. ISEITER On page 26 of the Integrated Plan, the licensee identified the connection point for the strategy to refill the condensate storage tank (CST) as being being...
... " The Phase 2 core cooling strategy has changed such that the CST refill will not be used. Instead, inventory for feeding the steam generators in Phase 2 will be provided directly to the main feed water (MFW) system piping or the auxiliary feed water (AFW) system piping via hose connections, thereby bypassing the CST. The source of water for Phase 2 SG makeup will be directly from Lake Michigan using a portable FLEX pump staged on the west side of the Intake Structure.
- 3. ISEITER ISE/TER Section 3.1.1.2, Page 8, fourth paragraph, the TER states, ...regarding " ... regarding SFP cooling water, the available suction sources for all the above options are the safety injection and refueling water storage tank (SIRWT) and Lake Michigan." Michigan. The current strategy does not credit the SIRWT. The SFP makeup suction source will be directly from Lake Michigan using the FLEX portable transfer pump.
ISE/TER Section 3.2.1, Page 28, sixth paragraph, the TER states, "...a
- 4. ISEITER ... a design change is in the preliminary stages to modify the ADV backup nitrogen supply supply source from the High High Pressure System to bottled nitrogen.
nitrogen." The design change/modification selected, and which will allow for the remote manual operation of the ADVs, is the installation of backup nitrogen bottles to last through Phase 11 and connection point point for an air compressor to be connected to the Phase 2 FLEX generator.
- 5. ISEITER Section 3.2.1.9,
- 5. ISE/TER 3.2.1.9, Page 46, 46, last paragraph, the TER states, states, ...the
" ... the FLEX pump that can pump can bebe used used for both SFP makeup and both SEP and CST CST refill along... Phase 22 along ... " The Phase core cooling strategy strategy has changed such that the CST refill will not be used. used. Instead, Instead, Page 14 14 of of 16 16
inventory for feeding the steam generators in Phase 2 will be provided directly to the (MEW) system piping or the auxiliary feed water (AFW) main feed water (MFW) (AEW) system piping via hose connections, thereby bypassing the CST. The source of water for Phase 2 SG makeup will be be directly from Lake Michigan using a FLEX portable transfer pump.
ISE/TER Section 3.2.1.9, Page 47, first paragraph, the TER states, ".....
. . . Phase 2 core cooling strategy has changed such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided by the FLEX portable transfer pump directly to (MEW) system piping or the auxiliary feed water (AFW) the main feed water (MFW) (AEW) system via hose connections, thereby bypassing the CST.
ISE/TER Section 3.2.2, Page 49, second paragraph, the TER states, "Since
- 7. ISEITER Since the SFPSEP makeup and CST refill both have relatively relatively..... ." The Phase 2 core cooling strategy has changes such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided by the FLEX portable transfer pump directly to the (MEW) system piping or the auxiliary feed water (AFW) system via main feed water (MFW) hose connections, thereby bypassing the CST.
ISE/TER Section 3.2.2, Page 49, first paragraph, the TER states, The
- 8. ISEITER The available suction sources for all of the above options are the SIRWT and Lake Michigan." Michigan. The current strategy does not credit the SIRWT. The SFP SEP makeup suction source will be Lake Michigan using the FLEX portable transfer pump.
ISE/TER Section 3.2.4.7, Page 57, last paragraph, the TER states, "...core
- 9. ISEITER ... core cooling uses a portable FLEX transfer pump to refill the CST to prolong prolong...
... " The Phase 2 core cooling strategy has changes such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided by the FLEX portable transfer pump directly to the main feed water (MFW) (MEW) system piping or the auxiliary feed water (AFW)
(AEW) system via hose connections, thereby bypassing the CST.
ISE/TER Section 3.2.4.7, Page 58, fourth paragraph, the TER states, "...to
- 10. ISEITER ... to connect portable pumps to refill the CST.
CST." The Phase 2 core cooling strategy has changes such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided by the FLEX portable transfer pump directly to the main feed water (MFW)
(MEW) system piping or the auxiliary feed water (AFW) (AEW) system via hose connections, thereby bypassing the CST.
ISE/TER Section 3.2.4.7, Page 58, first paragraph, the TER states, ." ... .initiated
- 11. ISEITER . initiated at hour 24, the mobile water purification unit should be received from the RRC.. RRC ...." This timing was determined to be not required by the strategy as evaluated in EC EC 46465. EC 46465 determined that the use use of Lake Michigan for up to 120 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> has inconsequential impact impact on Steam Generator Generator fouling based on decay heat heat load load present. Palisades will accept a mobile purification unit as evaluated for its use in EC 46465 at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for use in a long term Phase 3 strategy. Therefore the purification units units will not be credited until will not until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the event.
hours after 15 of 16 Page 15 16
8 References The following references support the updates to the Overall IIntegrated ntegrated 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).
- 2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to 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 Events (Order Number EA-12-049), dated August 28,2013 28, 2013 (ADAMS Accession No. ML113241A234).
ML 3241 A234).
- 4. ENO 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 External Events (Order Number EA-12-049), dated February 28,2014 28, 2014 (ADAMS Accession No. ML114059A078).
ML 4059A078).
Pailsades Nuclear Plant -Interim
- 5. NRC letter, Palisades Interim Staff Evaluation Regarding Overall Integrated Plan in Response to Order EA-12-049 EA- 12-049 (Mitigation Strategies) (TAC No.
MFO768), dated February 10, 2014 (ADAMS Accession No. ML MF0768), ML13365A264).
13365A264).
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