ML15069A225

Station'S Fourth 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)

ML15069A225
Person / Time
Site:	Pilgrim
Issue date:	02/27/2015
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML15069A225 (21)

Text

'? Entergy Entergy Nuclear Operations, Inc.

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

Site Vice President February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station's Fourth 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 LETTER NUMBER 2.15.005

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-12-049)", 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)

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PNPS Letter 2.15.005 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)

8. Pilgrim Nuclear Power Station Letter to NRC, "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)" dated August 28, 2013 (PNPS Letter 2.13.069)

9. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's 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 (PNPS Letter 2.14.011)

10. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's 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)" dated August 28, 2014 (PNPS Letter 2.14.061)

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 Attachment 2 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. Reference 8 provided the first six-month status report. Reference 9 provided the second six-month status report. Reference 10 provided the third six-month status report. The purpose of this letter is to provide the fourth 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,

PNPS Letter 2.15.005 Page 3 of 4 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-1 3-109 on the schedule outlined in NRC Order EA 109. Because of the new order (NRC Order EA-13-109), there will be additional independent instrumentation improvements made to the hardened containment vent, but the wetwell vent is otherwise not changing from what is already required and being prepared for the FLEX Strategy Containment Venting.

Should you have any questions concerning the content of this letter, please contact Mr. Everett (Chip) Perkins Jr. at (508) 830-8323.

This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 27, 2015.

Sincerely, John A. Dent Jr.

JAD/rmb

Attachment:

Pilgrim Nuclear Power Station's Fourth 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. Daniel H. Dorman 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 Ms. Nadiyah Morgan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555

PNPS Letter 2.15.005 Page 4 of 4 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 # 4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Robert L. Dennig OWFN, Mailstop # 10E1 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 2.15.005 PILGRIM NUCLEAR POWER STATION'S FOURTH 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 to PNPS Letter 2.15.005 Attachment Pilgrim Nuclear Power Station's Fourth 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 last status report (Reference 10), 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 July 31, 2014, and are current as of January 31, 2015.

• Third Six-Month Status Report - August 2014

• Procedure Changes Training Material Complete - October 2014

• Fourth Six-Month Status Report - Complete with submission of this document in February 2015.

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.

• No new additions or changes to target completion dates for this report.

Target Revised Milestone Completion Activity Status Target Date* Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Submit Six-Month Status Report August 2013 Complete Submit Six-Month Status Report February 2014 Complete Page 1 of 16

Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Target Revised Milestone Completion Activity Status Target Date* Completion Date Modifications Approved for February 2014 Complete Implementation Develop Training Plan March 2014 Complete Submit Six-Month Status Report August 2014 Complete Procedure Changes Training Material October 2014 Complete Complete Submit Six-Month Status Report February 2015 Complete Implement Training (Schedule LORT March 2015 Started Plan to Support Implementation)

Modification Implementation Complete May 2015 In Progress Demonstration / Functional Test May 2015 Not Started Submit Post Outage 60-day Report July 2015 Not Started Submit Six-Month Status Report August 2015 Not Started Submit Completion Report December 2015 J Not Started I

• Target Completion Date is the last submitted date from either the Overall Integrated Plan or previous Six-month Status Report.

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 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 Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan (OIP) and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes the FLEX related NRC Audit Visit Open Items, which includes open items on previously issued Audit Questions and new Safety Evaluation (SE) Open Items that were not closed during the October 2014 NRC Audit Visit as documented in the NRC's Report for the PNPS Onsite Audit (Reference 11). A fifth table includes a listing of all Audit Questions and their status.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Note that during the October 2014 NRC Audit Visit (documented in Reference 11 of this attachment), the NRC utilized a spreadsheet entitled Pilgrim Nuclear Plant, SE Item Tracker to maintain a status of Open Items associated with development of the NRC's Safety Evaluation.

The SE Tracker numbered each item with an Audit Item No. based on the category of the Open Item. The categories were:

A. ISE Open and Confirmatory Items (Audit Item x-A)

B. Audit Questions (Audit Item x-B)

C. Licensee OIP Open Items (Audit Item x-C)

D. Order 051 SFPI ISE RAIs (Audit Item x-D)

E. Combined SE Template Technical Review Gaps (Audit Item x-E)

The open items in the NRC's Report for the PNPS Onsite Audit (Reference 11 of this attachment) did not utilize the SE Tracker Audit Item Numbers and did not address all of the SE Tracker Items that were closed during the Onsite Audit Visit. The Audit Item Numbers utilized below are in some cases from the SE Tracker spreadsheet and in some cases from the NRC's Report for the PNPS Onsite Audit (Reference 11); the source of the Audit Item Numbers have been identified.

Additionally, in the Status columns of the following tables, the phrase "This item was closed during [following] the October 2014 NRC Audit Visit" indicates that since the item is not listed as an Open Item in the NRC's Report for the PNPS Onsite Audit Report (Reference 11 of this attachment) the item is considered closed.

Overall Integrated Plan Open Item Status

1. Beyond-design-basis external event impact on Entergy has determined that no requirements in existing licensing documents will be FSAR changes are required to determined based on input from the industry groups and reflect FLEX.

direction from the NRC. This item was closed following the October 2014 NRC Audit Visit (SE Tracker Audit Item 1-C).

2. Structure, content and details of the Regional Response This item was closed following Center playbook will be determined, the October 2014 NRC Audit Visit (SE Tracker Audit Items 2-C and 4-E).

Interim Staff Evaluation Open Items Status 3.2.1.4.A - On pages 16, 23, and 63 of the Integrated Plan The PNPS ISE Open and regarding Portable Equipment to Maintain Core Cooling, the Confirmatory Items are licensee describes the use of portable pumps to provide addressed in a single document RPV injection. No technical basis or a supporting analysis that has been uploaded to the was provided for the diesel-driven FLEX pump capabilities ePortal.

Page 3 of 16

Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 considering the pressure within the RPV and the loss of This item was statused as Open pressure along with details regarding the FLEX pump supply as documented in Reference 11.

line routes, length of hoses runs, connecting fittings, and (SE Tracker Audit Item 12-A, elevation changes to show that the pump is capable of NRC Audit Report Audit Item injecting water into the RPV with a sufficient rate to maintain ISE 01 3.2.1.4.A).

and recover core inventory for both the primary and alternate flow paths.

Interim Staff Evaluation Confirmatory Items Status 3.1.1 .1 .A - The Integrated Plan does not specify The PNPS ISE Open and procedures and programs will provide for securing large Confirmatory Items are portable equipment to protect them during a seismic event or addressed in a single document to ensure unsecured and/or non-seismic components do not that has been uploaded to the damage the equipment as is specified in NEI 12-06, Section ePortal.

5.3.1, considerations 2 and 3. This item was closed following the October 2014 NRC Audit Visit (SE Tracker Audit Item 1-A) as documented in Reference 11.

3.1.1.2.A - The licensee identified that access to at least This item was closed during the one connection point for the equipment will require access October 2014 NRC Audit Visit through routes that are not FSAR Seismic Class I, however (SE Tracker Audit Item 2-A).

they have been evaluated and the potential for large scale See Reference 11.

debris field that would prevent access to the equipment needed to be repowered is not present. Their evaluation should be validated during the site audit.

3.1.1.3.A - The licensee was requested to provide This item was closed during the additional information concerning coping strategies for the October 2014 NRC Audit Visit failure of seismically qualified electrical equipment that can (SE Tracker Audit Item 3-A).

be affected by beyond-design-basis seismic events as See Reference 11.

discussed in NEI 12-06, Section 5.3.3 consideration 1.

3.1.3.1.A - The storage of the FLEX equipment is in sea This item was closed during the vans. The licensee is in the process of performing a October 2014 NRC Audit Visit calculation to demonstrate conformance with NEI 12-06, (SE Tracker Audit Item 4-A).

Section 7.3.1 .b, bullet 4 related to adequate tie down of the See Reference 11.

sea vans. Evaluation of the completed calculation must be completed to determine if it demonstrates conformance to guidance in NEI 12-06, Section 7.3.1.b, bullet 4.

3.1.3.2.A - During the audit process, the licensee identified Complete. This item was that there are existing plant procedures that address considered closed during the hurricanes. The procedures need to be evaluated for October 2014 NRC Audit Visit conformance to NEI 12-06, considerations 1, 2, and 5. (SE Tracker Audit Item 5-A),

however, Reference 11 indicates the item is open. Response Page 4 of 16

Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Interim Staff Evaluation Confirmatory Items Status available on the ePortal (FW Parking Locations for FLEX pickup trucks.msg) 3.2.1.1.A - From the June 2013 position paper, This item was closed during the benchmarks must be identified and discussed which October 2014 NRC Audit Visit demonstrate that the Modular Accident Analysis Program (SE Tracker Audit Item 6-A).

(MAAP) 4 is an appropriate code for the simulation of an See Reference 11.

Extended Loss of AC Power (ELAP) event at your facility.

3.2.1.1 .B - The collapsed level must remain above Top of This item was closed during the Active Fuel (TAF) and the cool down rate must be within October 2014 NRC Audit Visit technical specification limits. (SE Tracker Audit Item 7-A).

See Reference 11.

3.2.1.1 .C - MAAP4 must be used in accordance with This item was closed during the Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position October 2014 NRC Audit Visit paper. (SE Tracker Audit Item 8-A).

See Reference 11.

3.2.1.1.D - In using MAAP4, the licensee must identify and This item was closed during the justify the subset of key modeling parameters cited from October 2014 NRC Audit Visit Tables 4-1 through 4-6 of the "MAAP4 Application (SE Tracker Audit Item 9-A).

Guidance, Desktop Reference for Using MAAP4 Software, See Reference 11.

Revision 2" (Electric Power Research Institute Report 1 020236). This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant.

3.2.1.1.E -The specific MAAP4 analysis case that was This item was closed during the used to validate the timing of mitigating strategies in the October 2014 NRC Audit Visit integrated plan must be identified and should be available on (SE Tracker Audit Item 10-A).

the ePortal for NRC staff to view. Alternately, a comparable See Reference 11.

level of information may be included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within tech spec limits.

3.2.1.2.A -The following is requested: This item was closed during the

1. Justification for the assumptions made regarding October 2014 NRC Audit Visit primary system leakage from the recirculation pump (SE Tracker Audit Item 11 -A).

seals and other sources. See Reference 11.

2. Assumed pressure-dependence of the leakage rate.

3. Clarification on whether the leakage was determined Page 5 of 16

Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Interim Staff Evaluation Confirmatory Items Status or assumed to be single-phase liquid, two-phase mixture, or steam at the donor cell and discuss how mixing of the leakage flow with the drywell atmosphere is modeled.

3.2.1.5.A - The integrated plan does not identify non- This item was closed during the powered local instrumentation other than Containment October 2014 NRC Audit Visit pressure and RPV level and pressure. The integrated plan (SE Tracker Audit Item 13-A).

identifies that phase 2 equipment will have installed local See Reference 11.

instrumentation needed to operate the equipment. The licensee needs to identify the instrumentation that will be used to monitor portable FLEX electrical power equipment.

3.2.4.2.A - The licensee was requested to provide the This item was closed during the maximum calculated MCR temperature and a detailed October 2014 NRC Audit Visit summary of the analysis used to determine the temperature (SE Tracker Audit Item 14-A).

and the procedure for control of MCR temperature. The licensee response was that existing procedure 2.4.149 addresses "Loss of MCR H&V". The procedure is symptom driven, containing temperature limits to perform actions, and it is not time driven. Pilgrim will provide the referenced "GOTHIC" evaluation. Evaluation of the "GOTHIC" analysis is needed to evaluate the MCR temperature.

3.2.4.4.A - The licensee needs to provide complete details This item was closed during the of portable lighting. October 2014 NRC Audit Visit (SE Tracker Audit Item 15-A).

See Reference 11.

3.2.4.4.B - The licensee provided its communications This item was closed during the assessment in letters dated October 31, 2012 and February October 2014 NRC Audit Visit 21, 2013 (Agencywide Documents Access and Management (SE Tracker Audit Item 16-A).

System (ADAMS) Accession Nos. ML12321A051 and See Reference 11.

ML13058A032) in response to the NRC letter dated March 12, 2012, 50.54(f) request for information letter. The NRC staff provided its evaluation on May 21, 2013 (ADAMS Accession No. ML13127A179). The NRC staff has determined that the assessment for communications is reasonable, and the analyzed existing systems, proposed enhancements, and interim measures will help to ensure that communications are maintained. This has been identified for confirmation that upgrades to the site's communications systems have been completed.

3.2.4.5.A - The Integrated Plan does not identify This item was closed during the procedures/guidance with regard to the access to the October 2014 NRC Audit Visit Protected Area and internal locked areas. During the audit (SE Tracker Audit Item 17-A).

process, the licensee identified existing security doors that provide egress capability and have key access in the event Page 6 of 16

Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Interim Staff Evaluation Confirmatory Items Status of a power loss. Operations and Security are currently researching options, the intention is to include it in the Emergency procedures addressing DDBEE perimeters, the site declaration of 50.54(x), and recognizing resource needs, including Security, and compensatory measures based on the event.

3.2.4.8.A - During the audit process, the licensee was The PNPS ISE Open and requested to provide electrical Single Line Diagrams Confirmatory Items are showing the proposed connections of Phase 2 and 3 addressed in a single document electrical equipment to permanent plant equipment. The that has been uploaded to the licensee responded that Engineering Change markup of the ePortal.

One-Line Diagrams E13 and E14Shl (EC45555 & This item was closed following EC45556), will be posted to the ePortal. The NRC staff will the October 2014 NRC Audit complete the review after they are posted. Visit (SE Tracker Audit Item 18-A) as documented in Reference 11.

3.2.4.8.B - During the audit process, the licensee identified This item was closed during the Engineering Changes are being developed to support the October 2014 NRC Audit Visit FLEX project which requires electrical studies to be (SE Tracker Audit Item 19-A).

performed. This includes the electrical diesel loading and See Reference 11.

load flow studies. The addition of the transfer switches and additional cable lengths are being incorporated into the Pilgrim design calculations (load flow, short circuit and coordination.) The FLEX diesel generator sizes need to be verified after the loading calculations are finalized.

3.2.4.1 0.A - Attachment 1 A of the Integrated Plan notes This item was closed during the that at one hour, the ELAP decision is made and deep dc October 2014 NRC Audit Visit load shedding begins at one hour (item 3), and at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (SE Tracker Audit Item 20-A).

the dc load shed is complete (item 4). The licensee was See Reference 11.

requested to provide the dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool cooling. During the audit process, the licensee responded that the dc load flow profiles are being developed as part of a new electrical battery FLEX extended operation load flow and battery sizing study PS258.

3.2.4.10.B - The licensee was requested to provide a This item was closed during the detailed discussion on the loads that will be shed from the dc October 2014 NRC Audit Visit bus, the equipment location (or location where the required (SE Tracker Audit Item 21-A).

action needs to be taken). During the audit process, the licensee responded by identifying that a tentative list of loads proposed to isolate, isolation time and panel locations are available and provided in the ePortal. The licensee will finalize the load-shed list after a review by Operations.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Interim Staff Evaluation Confirmatory Items Status 3.2.4.A - The licensee's plans for the use of off-site The PNPS ISE Open and resources did not address considerations 2 through 10 of Confirmatory Items are NEI 12-06, Section 12.2. addressed in a single document that has been uploaded to the ePortal.

This item was closed following the October 2014 NRC Audit Visit (SE Tracker Audit Item 22-A) as documented in Ref. 11.

October 2014 NRC Audit Visit FLEX Related Open Items (Reference 11)

Audt Iem icensee Input Audit Item Item Description i Status Reference Needed ISE 01 3.2.1.4.A Pages 16, 23, and 63 of the Entergy has action Hydraulic calculation (SE Tracker Integrated Plan [NRC Order to provide the has been revised and Audit Item 12-A) EA-12-049, dated February revised hydraulic available on the ePortal 28, 2013, (ADAMS calculations and (Calc M1384 EC45558 Accession No. ML analysis that ECN54090.pdf).

13063A063)], regarding demonstrate that Portable Equipment to the portable pump Maintain Core Cooling, has sufficient net Entergy describes the use of positive suction potable pumps to provide head.

reactor pressure vessel injection. No technical basis or supporting analysis was provided for the diesel driven FLEX pump capabilities considering the pressure within the RPV and the loss of pressure along with details regarding the FLEX pump supply line routes, length of hose runs, connecting fittings, and elevation changes to show that the pump is capable of injecting water into the RPV with a sufficient rate to maintain and recover core inventory for both the primary and alternate flow paths.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 11)

Audit Item Item Description Licensee Input Reference Needed AQ 60 Describe plans for supplying Entergy to provide Response is available (SE Tracker fuel oil to FLEX equipment NRC staff of on the ePortal (Answer Audit Item 48-B) (i.e., fuel oil storage tank procedure to refuel to 48-B.docx).

volume, supply pathway, Phase 3 equipment.

etc.). Also, explain how fuel quality will be assured if stored for extended periods of time.

AQ 69 Entergy plans to use ground NRC staff waiting In progress.

(SE Tracker water well pumps during for shaker test on Shaker test on pump is Audit Item 53-B) phases 2 and 3. The staff pump. Entergy has in progress.

requested information on not completed this the seismic qualification of test.

the pumps.

RAI SE No. 5 The NRC staff needs to Entergy to finalize In Progress.

(SE Tracker review the ventilation their ventilation Loss of ventilation Audit Item 9-E) analysis for areas containing analysis on the evaluations for electrical equipment to electrical switchgear HPCI/RCIC Pump ensure the equipment can room. Rooms, Switchgear perform as expected during Rooms, Main Control a loss of ventilation as a Room and Battery result of ELAP (Primary Rooms are in progress.

Areas will included HPCI/RCIC Pump Rooms, Switchgear Rooms, Main Control Room, and Battery Rooms).

RAI SE No. 6 As described in Item 5 on Entergy to confirm Evaluation of SRV tail (SE Tracker page 8 of the integrated whether it has pipes and supports and Audit Item 10-E) plan, confirm that the evaluated the issue the quenchers is stresses associated with previously and available on the ePortal passing liquid phase water consider whether (PNPS Audit Item 10-E through the SRV tail pipe, additional review Liquid Phase Water including those on the tail from structural through SRV Tail Pipe pipe, the tail pipe supports, experts is necessary 12-15-2014.docx).

the quencher and the to assist in review.

quencher supports are evaluated with acceptable results.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 11)

Audit Item Item Description Licensee Input Status Reference Needed RAI SE No. 7 Extended loss of alternating Entergy developing Response is available (SE Tracker current during low power procedures. on the ePortal (Open Audit Item 11-E) modes. Audit Item 11-E Response 06-2014.docx)

RAI SE No. 8 Flex support guidelines for Entergy to develop Response is available (SE Tracker transitioning from Phase 2 procedures to use on the ePortal (Answer Audit Item 12-E) to Phase 3. equipment from the to 12-E.docx)

Regional Response Center.

RAI SE No. 9 Diesel 'N' Storage - Entergy Generic issue, NRC Response available on (SE Tracker believes one 86 KW diesel staff is evaluating the ePortal (FW Audit Audit Item 13-E) generator is sufficient as 'N' this battery. Item 13E.msg) if the 250 volt battery lasts 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

Audit Questions Status Completion or Target Date PNPS-002 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 1-B) 11.

PNPS-003 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (Associated with Audit Item 2-B) ISE Confirmatory Item 3.1.1.2.A)

PNPS-004 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 3-B) 11.

PNPS-006 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 4-B)

PNPS-007 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 5-B) 11.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Audit Quest Questions Status Completion or Target Date PNPS-008 In Progress. The associated ISE Cl was March 2015 (SE Tracker considered closed during the October Audit Item 6-B) 2014 NRC Audit Visit, however, Reference 11 indicates the ISE Cl is open (associated with ISE confirmatory Item 3.1.3.2.A). This AQ response will be updated when information is available.

PNPS-009 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 7-B) ISE Confirmatory Item 3.1.3.1.A) See Reference 11.

PNPS-010 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 8-B) 11.

PNPS-01 1 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 9-B)

PNPS-012 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 10-B) 11.

PNPS-013 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 11 -B)

PNPS-014 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 12-B)

PNPS-015 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 13-B) ISE Confirmatory Items 3.2.1.1.A and 3.2.1.1.E )

PNPS-016 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 14-B) ISE Confirmatory Item 3.2.1.1.C)

PNPS-017 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 15-B) ISE Confirmatory Items 3.2.1.1.B and 3.2.1.1.D)

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Audit Quest Questions Status Completion or Target Date PNPS-018 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 16-B)

PNPS-019 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 17-B) ISE Confirmatory Item 3.2.1.1.A)

PNPS-020 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 18-B)

PNPS-021 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 19-B)

PNPS-022 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 20-B)

PNPS-024 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 21-B) 11.

PNPS-025 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 22-B) 11.

PNPS-026 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 23-B) 11.

PNPS-027 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 24-B) 11.

PNPS-030 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 25-B)

PNPS-032 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 26-B)

PNPS-033 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 27-B) ISE Confirmatory Item 3.2.4.2.A)

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Audit Quest Questions Status Completion or Target Date PNPS-034 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 28-B) 11.

PNPS-035 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 29-B) 11.

PNPS-036 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 30-B) 11.

PNPS-037 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 31-B) 11.

PNPS-038 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 32-B) 11.

PNPS-039 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 33-B) ISE Confirmatory Items 3.2.4.4.A and 3.2.4.4.B)

PNPS-040 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 34-B) ISE Confirmatory Item 3.2.4.5.A)

PNPS-042 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 35-B) 11.

PNPS-043 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 36-B) 11.

PNPS-044 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 37-B) 11.

PNPS-046 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 38-B)

PNPS-047 This item was closed following the N/A (SE Tracker October 2014 NRC Audit Visit as Audit Item 39-B) documented in Reference 11 (associated with ISE Confirmatory Item 3.4.A)

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Audit Quest Questions Status Completion or Target Date PNPS-049 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 40-B)

PNPS-053 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 41-B)

PNPS-054 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 42-B) ISE Confirmatory Item 3.2.4.10.A)

PNPS-055 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 43-B) ISE Confirmatory Item 3.2.4.10.B)

PNPS-056 This item was closed during the October NA/

(SE Tracker 2014 NRC Audit Visit.

Audit Item 44-B)

PNPS-057 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 45-B) ISE Confirmatory Item 3.2.4.8.B)

PNPS-058 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 46-B)

PNPS-059 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 47-B)

PNPS-060 This item was statused as Open (Audit March 2015 (SE Tracker Item 48-B) as documented in Reference Audit Item 48-B, 11. Updated Response available on the NRC Audit ePortal.

Report Audit Item AQ 60)

PNPS-065 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 49-B) 11.

PNPS-066 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit (associated with Audit Item 50-B) ISE Confirmatory Item 3.2.4.8.A)

PNPS-067 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit. See Reference Audit Item 51-B) 11.

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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Audit Quest Questions Status Completion or Target Date PNPS-068 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 52-B)

PNPS-069 In progress. This item was statused as March 2015 (SE Tracker Open as documented in Reference 11.

Audit Item 53-B, This AQ response will be updated when NRC Audit information is available.

Report Audit Item AQ 69)

PNPS-070 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 54-B)

PNPS-071 This item was closed during the October N/A (SE Tracker 2014 NRC Audit Visit.

Audit Item 55-B) 7 Potential Interim Staff Evaluation Impacts Entergy has not identified any additional potential impacts to the Interim Staff Evaluation since the previous six month status report (Reference 10).

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-1 3-109, 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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Attachment to PNPS Letter 2.15.005 PNPS's Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015

5. Pilgrim Nuclear Power Station Letter to NRC, "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)" dated August 28, 2013 (PNPS Letter 2.13.069).

6. NRC Letter, "Pilgrim Nuclear Power Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No.

MF0777)," dated December 16, 2013.

7. NRC Letter to NEI (ML13275A318), dated October 3, 2013.

8. "Use of Modular Accident Analysis Program (MAAP4) in Support of Post-Fukushima Applications," Report No. 3002001785, EPRI, June 2013 (ML13190A201).

9. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's 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 (PNPS Letter 2.14.011)

10. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear Power Station's 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)" dated August 28, 2014 (PNPS Letter 2.14.061)

11. Pilgrim Nuclear Power Station - 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. MF0777 and MF0778) dated January 26, 2015 (PNPS Letter 1.15.003) (ML14349A518)

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