ML13247A411

Station'S First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Stratgies for Beyond-Design-Basis External Events

ML13247A411
Person / Time
Site:	Pilgrim
Issue date:	08/28/2013
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk
References
EA-12-049
Download: ML13247A411 (8)

Text

uF Entergy Entergy Nuclear Operations, Inc.

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

Site Vice President August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station'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)

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35

REFERENCE:

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 (PNPS Letter 1.12.013)

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 (ML12229A174)

3. Nuclear Energy Institute (NEI) 12-06, Revision 0, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", dated August 2012

4. Pilgrim Nuclear Power Station Letter to NRC, "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-1 2-049)",

dated October 29, 2012 (PNPS Letter 2.12.072)

5. Pilgrim Nuclear Power Station Letter to NRC, "Overall Integrated Plan 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, 2013 (PNPS Letter 2.13.012)

6. NRC Order Number EA-12-050, "Order to Modify Licenses With Regard To Reliable Hardened Containment Vents", dated March 12, 2012 (PNPS Letter 1.12.014) 14(6(~

PNPS Letter 2.13.069 Page 2 of 4

7. NRC Order Number EA-13-109, "Order to Modify Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions", dated June 6, 2013 (PNPS Letter 1.13.028)

LETTER NUMBER 2.13.069

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. Specific requirements are outlined in of Reference 1.

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 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Pilgrim Station initial status report regarding mitigation strategies. Reference 5 provided the Pilgrim 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 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.

The FLEX strategies in the Overall Implementation Plan currently rely on the current conceptual design of the reliable hardened vent (RHV) system that was developed in response to Reference 6, NRC Order EA-12-050. Reference 7, NRC Order EA-13-109, dated June 6, 2013, rescinds the requirements of NRC Order EA-12-050. Compliance with the requirements of NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required. The industry, through NEI and the owners' group, is addressing the new requirements provided in NRC Order EA 109 on the schedule outlined in NRC Order EA-1 3-109. Because of the new order (NRC Order EA-1 3-109), the design of the hardened containment vent is being reevaluated.

Any design changes resulting from the revised hardened vent order will be reflected in a future six month update.

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

Joseph R. Lynch at (508) 830-8403.

PNPS Letter 2.13.069 Page 3 of 4 This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.

Sincerely, ohnA.Dent Jr.

JAD/rmb

Attachment:

Pilgrim Nuclear Power Station'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) cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Washington, DC 20555-0001 Mr. Richard V. Guzman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 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.

OWFN, Mailstop # 4A1 5A 11555 Rockville Pike Rockville, MD 20852-2378

PNPS Letter 2.13.069 Page 4 of 4 U. S. Nuclear Regulatory Commission Attn: Robert L. Dennig OWFN, Mailstop # 1OE1 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Ms. Jessica A. Kratchman OWFN, Mailstop # 9D2 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Eric E. Bowman OWFN, Mailstop # 12D20 11555 Rockville Pike Rockville, MD 20852-2378 NRC Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT To PNPS Letter 2.13.069 PILGRIM NUCLEAR POWER STATION'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)

Attachment Pilgrim Nuclear Power Station'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) 1 Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Pilgrim Nuclear Power Station (PNPS), documenting 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.

• Validation Demonstration/Functional Test: The demonstrations/functional tests will be completed during and following the FLEX modification implementation outage.

The revised milestone target completion dates do not impact the order implementation date.

Target Revised Milestone Completion Activity Target Date Status Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Submit 6 Month Status Report August 2013 Complete Submit 6 Month Status Report February 2014 Not Started Modifications Approved for February 2014 Not Started Implementation Develop Training Plan March 2014 Not Started Submit 6 Month Status Report August 2014 Not Started Page 2 of 4

PNPS's First Six Month Status Report for the Implementation of FLEX August 28, 2013 Target Revised Completion Activity Target Milestone Date Status Completion Date_ _Date Procedure Changes Training Material October 2014 Not Started Complete Submit 6 Month Status Report February 2015 Not Started Implement Training (Schedule LORT March 2015 Not Started Plan to Support Implementation)

Modification Implementation Complete May 2015 Not Started Demonstration / Functional Test June 2015 Not Started Submit 6 Month Status Report August 2015 Not Started Submit Completion Report December 2015 Not Started 4 Changes to Compliance Method The FLEX strategies in the Overall Implementation Plan currently rely on the current conceptual design of the reliable hardened vent (RHV) system that was developed in response to Reference 3, NRC Order EA-12-050. Reference 4, NRC Order EA-13-109, dated June 6, 2013, rescinds the requirements of NRC Order EA-12-050. Compliance with the requirements of NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required. The industry, through NEI and the owners' group, is addressing the new requirements provided in NRC Order EA-13-109 on the schedule outlined in NRC Order EA-13-109. Because of the new order (NRC Order EA-1 3-109), the design of the hardened containment vent is being reevaluated. Any design changes resulting from the revised hardened vent order will be reflected in a future six month update.

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 PNPS 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 Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status None.

Draft Safety Evaluation Open Item Status None.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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PNPS's First Six Month Status Report for the Implementation of FLEX August 28, 2013 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Pilgrim Nuclear Power Station's "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.

3. NRC Order Number EA-12-050, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents, dated March 12, 2012.

4. NRC Order Number EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

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