ML17212A616

Station'S Sixth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order No. EA-13-109)

ML17212A616
Person / Time
Site:	Pilgrim
Issue date:	06/30/2017
From:	Brian Sullivan Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.17.046, EA-13-109
Download: ML17212A616 (8)

Text

• =:'=!Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President June 30, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station's Sixth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

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

REFERENCES:

1. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions,"

dated June 6, 2013 (Accession No. ML13143A334)

2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML133048836)

3. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109), Rev O" (Accession No. ML14128A219)

4. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013

5. Entergy's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109),

dated June 30, 2014

6. Notification of Permanent Cessation of Power Operations dated November 10, 2015 (Accession No. ML15328A053) (PNPS letter 2.15.080)

7. Pilgrim Nuclear Power Station's Third Six-Month Status Report, Phase 2 Overall Integrated Plan, and Responses to Phase 1 Interim Staff Evaluation Open Items in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) (Accession No. ML15358A042) (PNPS Letter 2.15.082)

Entergy Nuclear Operations, Inc. Letter No. 2.17.046 Pilgrim Nuclear Power Station Page 2 of 3

8. Pilgrim Nuclear Power Station's Request for Extension to Comply with NRC Order EA-13-109, Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Accession No. ML15358A042) dated June 24, 2016 (PNPS Letter 2.16.028)

9. Pilgrim Nuclear Power Station - Relaxation of the Schedule Requirements for Order EA-13-109: Order Modifying Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Accession No. ML17032A050) dated April 17, 2017 (PNPS Letter 1.17.024)

LETTER NUMBER: 2.17.046

Dear Sir or Madam:

On June 6, 2013, the U. S. Nuclear Regulatory Commission (NRC) issued an order (Reference

1) to Entergy Nuclear Operations, Inc. (Entergy). Reference 1 was immediately effective and directs Entergy to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of Reference 1. Reference 1 required submission of Phase 1 and Phase 2 overall integrated plans pursuant to Section IV, Condition D. Reference 3 endorses industry guidance document NEI 13-02, Revision O (Reference 4) with clarifications and exceptions identified in Reference 2. References 5 and 7 provided the Entergy Phase 1 and Phase 2 overall integrated plans.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. References 2 and 4 provide direction regarding the content of the status reports. The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition D, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached status 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.

Per Reference 6, Entergy plans to permanently cease operation of PNPS no later than June 1, 2019. The Hardened Containment Vent System Phase 1 and Phase 2 strategies documented in this submittal were accurate descriptions of the planned modifications and/or strategies to satisfy the requirements of NRC Order EA-13-109. However, based on Reference 6, an alternative approach to the containment hardened vent Phase 1 and Phase 2 requirements was submitted to the NRC with a request for extension of Order EA-13-109 due date via Reference 8 to late-year 2019 to allow NRC approval of Order rescission. The NRC Staff relaxed the requirement of the order for full implementation of Phase 1 requirements until December 31, 2019 via Reference 9 on April 17, 2017.

If you have any questions or require additional information, please contact Mr. Everett Perkins, Jr. at (508) 830-8323.

There are no regulatory commitments contained in this letter.

Entergy Nuclear Operations, Inc. Letter No. 2.17.046 Pilgrim Nuclear Power Station Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct; executed on June 30, 2017.

Sincerely,

~

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Brian R. ullivan Site Vice President BRS/rb

Attachment:

Pilgrim Nuclear Power Station's Sixth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Bouleva_rd, Suite 100 King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 Mr. John Lamb, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555 Mr. John Giarrusso Jr.

Planning, Nuclear and Preparedness Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 NRC Resident Inspector Pilgrim Nuclear Power Station

ATTACHMENT To PNPS Letter 2.17 .046 Pilgrim Nuclear Power Station's Sixth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

(4 pages)

Attachment PNPS Letter 2.17.046 Pilgrim Nuclear Power Station's Sixth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) 1 Introduction In Reference 8, Pilgrim Nuclear Power Station (PNPS) informed the NRC of its intent to permanently cease power operations. PNPS has submitted an alternate plan in lieu of complying with the requirements of EA-13-109 to the NRC with a request for a due date extension of Order EA-13-109 via Reference 9 to late-year 2019 to allow NRC approval of Order rescission. The NRC Staff relaxed the requirement of the order for full implementation of Phase 1 requirements until December 31, 2019 via Reference 10 on April 17, 2017.

The information provided is basically unchanged except, for reflection of use of the alternate approach, from the prior six month update. PNPS is no longer pursuing any design or modifications related directly to this plan. However, to meet the regulatory requirement to provide six month updates, PNPS is submitting this update.

PNPS developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Phase 1 OIP and the previous Six Month Status Reports, 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 OIP (Reference 1),

and are current as of June 28, 2017.

• The Overall Integrated Plan was issued on June 30, 2014.

• The First Six Month Status Report was issued on December 16, 2014.

• The Interim Staff Evaluation (ISE) was received on March 24, 2015.

• The Second Six Month Status Report was issued on June 30, 2015.

• The Third Six Month Status Report was issued on December 17, 2015.

• The Fourth Six Month Status Report was issued on June 29, 2016.

• The Fifth Six Month Status Report was issued on December 16, 2016

• The Sixth Six Month Status Report was issued on June 30, 2017 (This submittal).

3 Milestone Schedule Status The following provides an update to Part 5 of the OIP. 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.

Target Milestone Activity Status Comments Completion Date Complete HCVS Gap Analysis June 2014 Complete Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Status Report December 2014 Complete Submit 6 Month Status Report June 2015 Complete Simultaneous Submit 6 Month Status Report December 2015 Complete with Phase 2 OIP Design Engineering On-site/Complete July 2016 Not Started Suspended Submit 6 Month Status Report June 2016 Complete Operations Procedure Changes Developed December 2016 Complete See Note*

Site Specific Maintenance Procedure December 2016 Not Started Suspended*

Developed Submit 6 Month Status Report December 2016 Complete Training Complete December 2016 Complete See Note*

Implementation Outage March 2017 Complete See Note*

Procedure Changes Active March 2017 Complete See Note*

Walk Through Demonstration/Functional Test March 2017 Not Started Suspended*

Submit Completion Report June 2017 Not Started Suspended Submit 6 Month Status Report June 2017 Complete Submit 6 Month Status Report December 2017 Not Started Submit 6 Month Status Report June 2018 Not Started Submit 6 Month Status Report December 2018 Not Started Submit 6 Month Status Report June 2019 Not Started

• Operations Procedure updates were incorporated to implement the alternate FLEX Severe Accident Strategy actions, along with modifications consistent with the PNPS Request for Extension to Comply with NRG Order EA-13-109 and the FLEX Strategy that utilizes Wetwell Venting and Severe Accident Water Addition and Management Strategies to mitigate all Beyond-Design-Basis conditions to meet the primary objectives of NRG Order EA-13-109.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation As noted in Reference 8, Entergy plans to permanently cease operation of PNPS no later than June 1, 2019. The HCVS Phase 1 and Phase 2 strategies documented in this submittal were accurate descriptions of the current modifications and/or strategies to satisfy the requirements of NRG Order EA-13-109. However, based on Reference 6, an alternative approach to the containment hardened vent Phase 1 and Phase 2 was submitted to the NRG with a request for extension of the Order EA-13-109 due date via Reference 9 to mid-year 2019 to allow NRG approval of Order rescission.

Via Reference 10, the NRG Staff relaxed the requirement of the order for full implementation of Phase 1 requirements until December 31, 2019 via Reference 10 on April 17, 2017.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation PNPS has received the Interim Staff Evaluation (ISE) with Open Items identified (Reference 7).

These open items have been addressed in Attachment 2 to the Third 6-month status report submittal dated December 17, 2015 via PNPS Letter 2.15.082.

7 Interim Staff Evaluation Impacts There are no potential impacts to the Phase 1 Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the Phase 1 OIP described in this enclosure.

1. Pilgrim's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014

2. NRG 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

3. NEI 13-02, "Industry Guidance for Compliance with NRG Order EA-13-109, To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML133048836)

5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. ML14128A219)

6. Nuclear Regulatory Commission Audits of Licensee Responses to Phase 1 of Order EA 109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Accession No. ML14126A545)

7. Nuclear Regulatory Commission Interim Staff Evaluation dated March 24, 2015, "Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents). (Accession No. ML15043A754) (PNPS Letter 1.15.016)

8. Notification of Permanent Cessation of Power Operations dated November 10, 2015 (Accession No. ML15328A053) (PNPS Letter 2.15.080)

9. Pilgrim Nuclear Power Station's Request for Extension to Comply with NRC Order EA 109, Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions dated June 24, 2016 (PNPS Letter 2.16.028)

10. Pilgrim Nuclear Power Station - Relaxation of the Schedule Requii-ements for Order EA 109: Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Accession No. ML17032A050) dated April 17, 2017 (PNPS L~tter 1.17.024)