ML13346A013

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML13346A013
Person / Time
Site:	Pilgrim
Issue date:	11/26/2013
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13346A013 (6)

Text

Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.

November 26, 2013 Site Vice President U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCES:

1. NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated March 12, 2012 (ADAMS Accession No. ML12053A340)

2. Entergy Letter to NRC, "Flooding Walkdown Report - Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from Fukushima Dai-ichi Accident, dated November 27, 2012 (PNPS Letter 2.12.076)

LETTER NUMBER 2.13.086

Dear Sir or Madam:

On March 12, 2012, the NRC issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 4 of Reference 1 requested each licensee perform flood protection walkdowns and report the results within 180 days of NRC endorsement of flooding walkdown guidelines NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features", Rev. 0-A.

Entergy completed the flood protection walkdowns at Pilgrim Nuclear Power Station and submitted the results via Reference 2. Reference 2 identified where restricted access prevented walkdown of certain flood protection features. Walkdowns of the restricted access items have been completed and the results are provided in the table attached to this letter.

This submittal closes all the open items identified in Reference 2.

The attached table provides a list of the restricted access items inspected, their respective disposition, and any action planned or taken. As a result of the inspections:

There were no additional deficiencies found in the supplemental walkdown. One observed condition did not meet the NEI 12-07 acceptance criteria and was entered into the Corrective Action Program but was determined to not be a deficiency as defined in NEI 12-07. A_')c.p

PNPS Letter 2.13.086 Page 2 of 3

• No temporary measures were required as a result of the completed inspections.

• Available physical margins (APMs) were collected and documented in the walkdown record forms for each applicable item inspected.

• All restricted items inspected were within the plant maintenance and monitoring programs unless identified as a deficiency in Table 1 of the attachment.

• Two of the restricted access items (Table #2 of Section 7.4 of the Flooding Report) and one of the inaccessible items (Table #3 of Section 7.4 of the Flooding Report) were reclassified to not be flooding features.

• One of the inaccessible items in Table #3 of Section 7.4 of the Flooding Report was determined to be accessible from a manhole. Inspection was completed satisfactory.

This letter contains no new regulatory commitments.

Should you have any questions concerning the content of this letter, please contact Mr.

Joseph R. Lynch, Manager, Regulatory Assurance at (508) 830-8403.

I declare under penalty of perjury that the foregoing is true and correct; executed on November 26, 2013.

Sincerely, John A. Dent Jr.

Site Vice President JAD/rmb

Attachment:

Pilgrim Nuclear Power Station (PNPS) Resolution of Open Items cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852-2378 Ms. Nadiyah Morgan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555

PNPS Letter 2.13.086 Page 3 of 3 Mr. John Giarrusso Jr.

Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 U. S. Nuclear Regulatory Commission ATTN: Robert J. Fretz Jr.

Mail Stop OWFN/4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert L. Dennig Mail Stop OWFN/1OE1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT to PNPS Letter 2.13.086 PILGRIM NUCLEAR POWER STATION (PNPS)

RESOLUTION OF OPEN ITEMS

Attachment PNPS Letter 2.13.086 Page 1 of 2 RESOLUTION OF OPEN ITEMS Report D t en or Planned Feature Description Ref (yes/no "Deficiency Description ActionsT Ref (y....sscrit Observed conditions that Inspection completed and WO written to repair Section did not meet the NEI 12-07 degraded seal conditions. The path that the Duct bank in the NW corner of the B 7.4 No acceptance criteria were minimal leakage will take due to one degraded RBCCW room, located -18" from entered into the CAP and seal and small head migrates to the torus the north wall Table #2 were determined to not be compartment that may hold up to 70,000 gal of deficiencies as defined in water bounded by internal flooding analysis.

NEI 12-01.

Section Conduits in the Condenser Bay, No None Inspection completed satisfactorily.

Turbine Building, Area 8 Table #2 The conduits penetrating at J1 22 are Section continuous, do not transit through manholes, Start-up Transformer (SUT E3) 7.4 No and terminate in an elevated, gasketed cabinet J122 Duct Bank located in the Not applicable, see actions encased in a weather tight concrete building in Monitor Tank Room Table #2 taken. the switchyard. Therefore, the penetrations conduits to cable seals at J122 are not to be credited as a flood protection feature.

Upon detailed review and scrutiny of external conduit pathway it has been determined that Section conduits running South from J653 do not Shut-down Transformer (SUT E3) 7.4 No Not applicable, see actions transit through manholes. They are encased in J653 Duct Bank located in the taken.conduits and gasketed junction boxed Monitor Tank Room Table #2 throughout their run, ending above the flood level. Therefore the penetrations conduits to cable seals at J653 are not to be credited as a flood protection feature.

Attachment PNPS Letter 2.13.086 Page 2 of 2 R.* p rt' D eficie ncy " - - -- .k A o Plan ned Feature Description Deficiency Description Actions Taken or Planned i Rf (yes/ino),

Reclassified Inaccessible Features Conduits terminating in A8 were also Section scrutinized and identified to terminate in the 7.4 No Not applicable, see actions main transformer above flood height with no Monitor Tank Room A-8 duct bank taken. passage through a manhole. The cables are Table #3 contained within the conduits; the conduit to cable seals are no longer identified as flood features.

In completing detailed reviews and applying eSection additional scrutiny of external conduit Seals in conduits from Screen Secn pathways and restrictions of features classified house, located in B-RBCCW room No None as restricted, the seals in conduits from the 7.4le Ne Screen house were able to be inspected Table #3 externally with additional security precautions from the manhole. Seals were identified to be in acceptable condition.