ML16250A017
| ML16250A017 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/18/2016 |
| From: | Dent J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.16.046 | |
| Download: ML16250A017 (6) | |
Text
~Entergy Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.
Site Vice President August 18, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Request for Deferral of Actions Related to Beyond-Design-Basis External Events Seismic Actions - Commitment Changes Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35 LETTER NUMBER: 2.16.046
REFERENCES:
- 1. Pilgrim's Expedited Seismic Evaluation Process Report (CEUS Sites), Response to NRC Request for Information Pursuant to 1O CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated December 16, 2014 (ML14357A061)
- 2. Notification of Permanent Cessation of Power Operations, dated November 10, 2015 (ML15328A053)
- 3. Pilgrim Nuclear Power Station-Staff Review of Interim Evaluation Associated with Reevall!ated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1, dated June 16, 2015 (ML 151.54A975)
- 4. Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f)
Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident (ML12056A046 and ML12053A340)
- 5. Entergy's Seismic Hazard and Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 1OCFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 31, 2014 (ML14092A023)
- 6. Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Seismic Hazard Re-evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident (ML14111A147)
Entergy Nuclear Operations, Inc. Letter No. 2.16.046 Pilgrim Nuclear Power Station Page 2 of 3
- 7. Final Determination of Licensee Seismic Probabilistic Risk Assessment Under the Request for Information Pursuant to Title 10 of the Code of Federal Regulations (CFR) 50.54(f)
Regarding Recommendation 2.1 "Seismic" of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated October 27, 2015 (ML15194A015)
- 8. NSIR/DPR-ISG-02 Interim Staff Guidance Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants
Dear Sir or Madam:
The purpose of this letter is to inform the U. S. Nuclear Regulatory Commission (NRC) Staff of commitment changes, as well as to request deferral of actions related to Beyond-Design-Basis External Events (BDBEE) seismic actions for Pilgrim Nuclear Power Station (PNPS).
In Reference 1, PNPS made two commitments related to modifying the Vital Motor Generator (MG) Set EG-23 anchorage. Upon further review, PNPS has determined that Vital MG Set EG-23 modification is not required to perform the PNPS FLEX strategy. During an Extended Loss of AC Power Event (ELAP), PNPS will enter Emergency Operating Procedures (EOPs) and there will be other instrumentation, beyond that supported by Vital MG Set EG-23, which provides indication for plant operators to use without leaving the control room. Therefore, the Vital MG Set EG-23 is not required for FLEX implementation during an ELAP and should not be subject to the Expedited Seismic Evaluation Program review for modification.
Other alternate indications in the control room are already available should the Vital MG Set EG-23 fail. These alternates are already documented in PNPS' FLEX strategy procedures. As such, the two commitments made in Reference 1 are being canceled as allowed by the PNPS Commitment Management Process.
Additionally, PNPS is informing the NRC that, in light of Reference 2, the decision to permanently shut down and defuel in 2019, seismic activities being performed to meet the NRC 10 Code of Federal Regulation 50.54(f) request for information and any related commitments planned between now and the 2019 Cessation of Power Operations are requested to be deferred. With the limited operating time left, there is insufficient time to complete evaluations, design and approve changes to the plant, and then implement those changes such that a meaningful improvement to safety is achieved prior to the defueling of the plant.
The details of these planned activities, as well as additional information are contained in the Attachment.
If you have any questions or require additional information, please contact Everett P. Perkins, Jr. at (508) 830-8323.
There are no regulatory commitments contained in this letter.
Entergy Nuclear Operations, Inc. Letter No. 2.16.046 Pilgrim Nuclear Power Station Page 3 of 3 Sincerely, ohn A. Dent, Jr.
Site Vice President JAD/rb
Attachment:
Pilgrim Nuclear Power Station - Request for Deferral of Actions Related to Beyond-Design-Basis External Events Seismic Actions - Commitment Changes (2 Pages) cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555 Office of Nuclear Reactor Regulation Japan Lessons Learned Division U.S. Nuclear Regulatory Commission Mail Stop 13 C5 Washington, DC 20555 NRG Senior Resident Inspector Pilgrim Nuclear Power Station
ATTACHMENT Letter Number 2.16.046 Pilgrim Nuclear Power Station Request for Deferral of Actions Related to Beyond-Design-Basis External Events Seismic Actions - Commitment Changes (2 Pages)
Entergy Nuclear Operations, Inc. Letter No. 2.16.046 Pilgrim Nuclear Power Station Page 1 of 2 Attachment On March 12, 2012 the NRC issued Reference 4 requesting information under 10 Code of Federal Regulations 50.54(f) regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident. The 50.54(f) response required a list of actions associated with Recommendation 2.1 Seismic.
On May 9, 2014 the NRC issued Reference 6. This letter indicated Pilgrim Nuclear Power Station (PNPS) screened in for seismic and would perform an Expedited Approach Evaluation, High Frequency Evaluation, and a Spent Fuel Pool Evaluation.
On October 27, 2015 the NRC issued Reference 7. This letter documented a Seismic Probabilistic Risk Assessment (SPRA) submittal date for PNPS of 12/31 /2017, as well as a limited scope Spent Fuel Pool Evaluation. The letter also indicated the High Frequency Evaluation would be included in the SPRA for those sites who had to perform SPRAs.
In summary, as a result of the original 1O CFR 50.54(f) request and subsequent related documents, PNPS is currently scheduled to perform a SPRA and Spent Fuel Pool Evaluation with a due date of December 31, 2017.
Additionally, working through Nuclear Energy Institute, a Mitigating Strategies Assessment for New Seismic Hazard Information [Seismic Mitigating Strategies Assessment (MSA) per NEI 12-06 Revision 2 Appendix G] will be required for completion at a currently unspecified date.
PNPS requests the extension of all these seismic related actions, (SPRA, High Frequency Evaluation, Seismic SFP Evaluation, and Seismic MSA) until December 31, 2019 which is beyond the anticipated submittal of the certification of Permanent Cessation of Power Operations. Upon submittal of the certification, PNPS will consider these actions to be no longer required.
Bases for Extension Seismic Probabilistic Risk Assessment To date PNPS has performed an interim seismic evaluation and provided the results to the NRC in March 2014. Based on the power plant studies (including PNPS), as well as the March 12, 2014, EPRI fleet wide study, the NRC concluded in the May 9, 2014 letter that " ... the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted."
Additionally, the bases for the SPRA is provided in the May 9, 2014 NRC letter. In the letter the NRC states:
Seismic Risk Evaluation - Longer-term seismic risk evaluation provides the most comprehensive information to make regulatory decisions, such as whether to amend a plant's design or licensing basis or make additional safety enhancements. These evaluations provide information to make risk-informed decisions. The staff will use this information in conjunction with the existing regulatory tools, such as backfit analysis, to decide on further regulatory actions. The longer-term seismic risk evaluations could be
Entergy Nuclear Operations, Inc. Letter No. 2.16.046 Pilgrim Nuclear Power Station Page 2 of 2 Attachment either a Seismic Margins Analysis or a Seismic Probabilistic Risk Assessment, depending on the magnitude of the exceedance.
Based on this statement and PNPS' scheduled SPRA completion due date, the evaluation is not warranted. The SPRA completion is scheduled for December 31, 2017, which is approximately 6-months into PNPS final operating cycle and after the final refueling outage. At that point, there will be only 18-months until final cessation of power operation. Considering the time required for NRC review of the SPRA, time for NRC action such as backfit analysis, time for the plant to identify, design, schedule, and implement modifications (if required) and no refueling outage available for potential modification implementation, there is simply insufficient time for the SPRA effort to result in any actual safety benefit to PNPS.
Spent Fuel Pool Seismic Evaluation For similar reasons the performance of the Spent Fuel Pool Seismic Evaluation is not warranted. PNPS understands that unlike the Reactor Pressure Vessel, the Spent Fuel Pool will not be immediately defueled. However, as indicated by Reference 8, a Spent Fuel Pool checklist or seismic evaluation is required to be performed as part of tt"le Emergency Planning exemption request. This criteria will provide reasonable safety assurance needed for the shutdown and defueled plant.
Conclusion In conclusion, PNPS is requesting the extension of the remaining actions to complete the response to Recommendation 2.1 Seismic, to December 31, 2019. Upon submittal of the certification of permanent cessation of power operation, the actions for completion of response to Recommendation 2.1 Seismic, as well as the Mitigating Strategies Assessment will no longer be required.