ML14253A189

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)

ML14253A189
Person / Time
Site:	Pilgrim
Issue date:	08/28/2014
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.14.061, EA-12-049
Download: ML14253A189 (15)

Text

SEntergy Entergy Nuclear Operations, Inc.

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

Site Vice President August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

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)

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER 2.14.061

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)

PNPS Letter 2.14.061 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)

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. The purpose of this letter is to provide the third 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-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

PNPS Letter 2.14.061 Page 3 of 4 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 August 28, 2014.

Sincerely,

Attachment:

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) 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 Ms. Nadiyah Morgan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555

PNPS Letter 2.14.061 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 2.14.061 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)

Attachment to PNPS Letter 2.14.061 Attachment 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) 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 January 31, 2014, and are current as of July 31, 2014.

• Second Six-Month Status Report - February 2014

• 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.

• 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 Modifications Approved for February 2014 Complete Implementation Page 1 of 10

Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Target Revised Completion Activity Status Target Milestone Date* Completion Date Develop Training Plan March 2014 Complete Submit Six-Month Status Report August 2014 Complete Procedure Changes Training Material October 2014 In Progress Complete Submit Six-Month Status Report February 2015 Not Started Implement Training (Schedule LORT March 2015 Not Started Plan to Support Implementation)

Modification Implementation Complete May 2015 In Progress Demonstration / Functional Test June 2015 Not Started Submit Six-Month Status Report August 2015 Not Started Submit Completion Report December 2015 Not Started

• 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 and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes a listing of Audit Questions and their status.

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.

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Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Overall Integrated Plan Open Item Status

2. Structure, content and details of the Regional Response Not Started Center playbook will be determined.

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.

considering the pressure within the RPV and the loss of pressure along with details regarding the FLEX pump supply line routes, length of hoses 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.

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.

3.1.1.2.A - The licensee identified that access to at least The PNPS ISE Open and one connection point for the equipment will requires access Confirmatory Items are through routes that are not FSAR Seismic Class I, however addressed in a single document they have been evaluated and the potential for large scale that has been uploaded to the debris field that would prevent access to the equipment ePortal.

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 The PNPS ISE Open and additional information concerning coping strategies for the Confirmatory Items are failure of seismically qualified electrical equipment that can addressed in a single document be affected by beyond-design-basis seismic events as that has been uploaded to the discussed in NEI 12-06, Section 5.3.3 consideration 1. ePortal.

3.1.3.1 .A - The storage of the FLEX equipment is in sea The PNPS ISE Open and vans. The licensee is in the process of performing a Confirmatory Items are calculation to demonstrate conformance with NEI 12-06, addressed in a single document Section 7.3.1.b, bullet 4 related to adequate tie down of the that has been uploaded to the Page 3 of 10

Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Confirmatory Items Status sea vans. Evaluation of the completed calculation must be ePortal.

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 The PNPS ISE Open and that there are existing plant procedures that address Confirmatory Items are hurricanes. The procedures need to be evaluated for addressed in a single document conformance to NEI 12-06, considerations 1, 2, and 5. that has been uploaded to the ePortal.

3.2.1.1.A- From the June 2013 position paper, The PNPS ISE Open and benchmarks must be identified and discussed which Confirmatory Items are demonstrate that the Modular Accident Analysis Program addressed in a single document (MAAP) 4 is an appropriate code for the simulation of an that has been uploaded to the Extended Loss of AC Power (ELAP) event at your facility. ePortal.

3.2.1.1 .B - The collapsed level must remain above Top of The PNPS ISE Open and Active Fuel (TAF) and the cool down rate must be within Confirmatory Items are technical specification limits. addressed in a single document that has been uploaded to the ePortal.

3.2.1.1 .C - MAAP4 must be used in accordance with The PNPS ISE Open and Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position Confirmatory Items are paper. addressed in a single document that has been uploaded to the ePortal.

3.2.1.1.D - In using MAAP4, the licensee must identify and The PNPS ISE Open and justify the subset of key modeling parameters cited from Confirmatory Items are Tables 4-1 through 4-6 of the "MAAP4 Application addressed in a single document Guidance, Desktop Reference for Using MAAP4 Software, that has been uploaded to the Revision 2" (Electric Power Research Institute Report 1 ePortal.

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 The PNPS ISE Open and used to validate the timing of mitigating strategies in the Confirmatory Items are integrated plan must be identified and should be available on addressed in a single document the ePortal for NRC staff to view. Alternately, a comparable that has been uploaded to the level of information may be included in the supplemental ePortal.

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.

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Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Confirmatory Items Status 3.2.1.2.A -The following is requested: The PNPS ISE Open and

1. Justification for the assumptions made regarding Confirmatory Items are primary system leakage from the recirculation pump addressed in a single document seals and other sources. that has been uploaded to the

2. Assumed pressure-dependence of the leakage rate. ePortal.

3. Clarification on whether the leakage was determined 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- The PNPS ISE Open and powered local instrumentation other than Containment Confirmatory Items are pressure and RPV level and pressure. The integrated plan addressed in a single document identifies that phase 2 equipment will have installed local that has been uploaded to the instrumentation needed to operate the equipment. The ePortal.

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 The PNPS ISE Open and maximum calculated MCR temperature and a detailed Confirmatory Items are summary of the analysis used to determine the temperature addressed in a single document and the procedure for control of MCR temperature. The that has been uploaded to the licensee response was that existing procedure 2.4.149 ePortal.

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 The PNPS ISE Open and of portable lighting. Confirmatory Items are addressed in a single document that has been uploaded to the ePortal.

3.2.4.4.B - The licensee provided its communications The PNPS ISE Open and assessment in letters dated October 31, 2012 and February Confirmatory Items are 21, 2013 (Agencywide Documents Access and Management addressed in a single document System (ADAMS) Accession Nos. ML12321A051 and that has been uploaded to the ML13058A032) in response to the NRC letter dated March ePortal.

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 Page 5 of 10

Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Confirmatory Items Status 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 The PNPS ISE Open and procedures/guidance with regard to the access to the Confirmatory Items are Protected Area and internal locked areas. During the audit addressed in a single document process, the licensee identified existing security doors that that has been uploaded to the provide egress capability and have key access in the event ePortal.

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 &

EC45556), will be posted to the ePortal. The NRC staff will complete the review after they are posted.

3.2.4.8.B - During the audit process, the licensee identified The PNPS ISE Open and Engineering Changes are being developed to support the Confirmatory Items are FLEX project which requires electrical studies to be addressed in a single document performed. This includes the electrical diesel loading and that has been uploaded to the load flow studies. The addition of the transfer switches and ePortal.

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 The PNPS ISE Open and that at one hour, the ELAP decision is made and deep dc Confirmatory Items are 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 /> addressed in a single document the dc load shed is complete (item 4). The licensee was that has been uploaded to the requested to provide the dc load profile with the required ePortal.

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 The PNPS ISE Open and detailed discussion on the loads that will be shed from the dc Confirmatory Items are Page 6 of 10

Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Confirmatory Items Status bus, the equipment location (or location where the required addressed in a single document action needs to be taken). During the audit process, the that has been uploaded to the licensee responded by identifying that a tentative list of loads ePortal.

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.

3.4.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.

Audit Questions Status Completion or Target Date PNPS-002 Closed*

PNPS-003 Closed* (See ISE Confirmatory Item 3.1.1.2.A response)

PNPS-004 Closed*

PNPS-006 Closed*

PNPS-007 Closed*

PNPS-008 Closed* (See ISE Confirmatory Item 3.1.3.2.A response)

PNPS-009 Closed* (See ISE Confirmatory Item 3.1.3.1.A response)

PNPS-010 Closed*

PNPS-01 1 Closed*

PNPS-012 Closed*

PNPS-014 Closed*

Closed* (See ISE Confirmatory PNPS-015 Items 3.2.1.1.A and 3.2.1.1.E responses PNPS-016 Closed* (See ISE Confirmatory Item 3.2.1.1.C response)

Closed* (See ISE Confirmatory PNPS-017 Items 3.2.1.1 .B and 3.2.1.1 .D responses)

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Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Audit Questions Status Completion or Target Date PNPS-018 Closed*

PNPS-019 Closed* (See ISE Confirmatory Item 3.2.1.1.A)

PNPS-020 Closed*

PNPS-021 Closed*

PNPS-022 Closed*

PNPS-024 Closed*

PNPS-025 Closed*

PNPS-026 Updated response available on the ePortal PNPS-027 Closed*

PNPS-030 Closed*

PNPS-032 Closed*

Closed* (See ISE Confirmatory Item 3.2.4.2.A)

PNPS-034 Closed*

PNPS-035 Closed*

PNPS-036 Closed*

PNPS-037 Closed*

PNPS-038 Closed*

Closed* (See ISE Confirmatory PNPS-039 Items 3.2.4.4.A and 3.2.4.4.B responses)

PNPS-040 Closed* (See ISE Confirmatory Item 3.2.4.5.A response)

PNPS-042 Closed*

PNPS-043 Closed*

PNPS-044 Closed*

PNPS-046 Closed*

Closed* (See ISE Confirmatory Item PNPS-047 34A 3.4.A)

PNPS-049 Closed*

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Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Audit Questions Status Completion or Target Date PNPS-053 Closed*

PNPS-054 Closed* (See ISE Confirmatory Item 3.2.4.10.A response)

PNPS-055 Closed* (See ISE Confirmatory Item 3.2.4.10.B)

PNPS-056 Closed*

Closed* (See ISE Confirmatory Item 3.2.4.8.B)

PNPS-058 Closed*

PNPS-059 Closed*

PNPS-060 Closed*

PNPS-065 Updated response available on ePortal PNPS-066 Closed* (See ISE Confirmatory Item 3.2.4.8.A)

PNPS-067 Closed*

PNPS-068 Closed*

PNPS-070 Closed*

PNPS-071 Closed*

• Closed indicates that Entergy's response is complete.

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 9).

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.

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Attachment to PNPS Letter 2.14.061 PNPS's Third Six Month Status Report for the Implementation of FLEX August 28, 2014

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.

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)

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