ML15069A225

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


Text

'? EntergyEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360John A. Dent, Jr.Site Vice President February 27, 2015U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station's Fourth Six-Month Status Report in Responseto March 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (Order Number EA-12-049)

Pilgrim Nuclear Power StationDocket No. 50-293License No. DPR-35LETTER NUMBER 2.15.005

REFERENCE:

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents",

dated March 12, 2012 (PNPS Letter 1.12.013)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events, Revision 0,dated August 29, 2012 (ML 12229A174)
3. Nuclear Energy Institute (NEI) 12-06, Revision 0, "Diverse and FlexibleCoping Strategies (FLEX) Implementation Guide", dated August 20124. Pilgrim Nuclear Power Station Letter to NRC, "Initial Status Report inResponse to March 12, 2012, Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)",

dated October 29, 2012 (PNPSLetter 2.12.072)

5. Pilgrim Nuclear Power Station Letter to NRC, "Overall Integrated PlanReport 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 February28, 2013 (PNPS Letter 2.13.012)

6. NRC Order Number EA-12-050, "Order to Modify Licenses With RegardTo Reliable Hardened Containment Vents", dated March 12, 2012 (PNPSLetter 1.12.014)

,ký 5 (0 Lý7rýý PNPS Letter 2.15.005Page 2 of 47. NRC Order Number EA-13-109, "Order to Modify Licenses With RegardTo Reliable Hardened Containment Vents Capable of Operation UnderSevere Accident Conditions",

dated June 6, 2013 (PNPS Letter 1.13.028)

8. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear PowerStation's First Six-Month Status Report in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049)"

dated August 28, 2013 (PNPS Letter 2.13.069)

9. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear PowerStation's Second Six-Month Status Report in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049)"

dated February 28, 2014 (PNPS Letter 2.14.011)

10. Pilgrim Nuclear Power Station Letter to NRC, "Pilgrim Nuclear PowerStation's Third Six-Month Status Report in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (OrderNumber 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 anorder (Reference

1) to Entergy.

Reference 1 was immediately effective and directs Entergy todevelop, 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 thefinal 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 providedthe Pilgrim Station initial status report regarding mitigation strategies.

Reference 5 provided thePilgrim Overall Integrated Plan.Reference 1 requires submission of a status report at six-month intervals following submittal ofthe overall integrated plan. Reference 3 provides direction regarding the content of the statusreports.

Reference 8 provided the first six-month status report. Reference 9 provided thesecond six-month status report. Reference 10 provided the third six-month status report. Thepurpose 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 sincethe last status report, including any changes to the compliance method, schedule, or need forrelief 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 toReference 6, NRC Order EA-12-050.

Reference 7, NRC Order EA-13-109, dated June 6, 2013, PNPS Letter 2.15.005Page 3 of 4rescinds the requirements of NRC Order EA-12-050.

Compliance with the requirements of NRCOrder EA-12-050, including applicable schedule deadlines for submittals or implementation, isno longer required.

The industry, through NEI and the owners' group, is addressing the newrequirements provided in NRC Order EA-1 3-109 on the schedule outlined in NRC Order EA-13-109. 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 isotherwise not changing from what is already required and being prepared for the FLEX StrategyContainment 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 February27, 2015.Sincerely, John A. Dent Jr.JAD/rmb

Attachment:

Pilgrim Nuclear Power Station's Fourth Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049) cc: Mr. Daniel H. DormanRegional Administrator, Region 1U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission

Director, Office of Nuclear Reactor Regulation One White Flint North11555 Rockville PikeWashington, DC 20555-0001 Ms. Nadiyah Morgan, Project ManagerOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2AWashington, DC 20555 PNPS Letter 2.15.005Page 4 of 4Mr. John Giarrusso Jr.Planning, Preparedness

& Nuclear Section ChiefMass. Emergency Management Agency400 Worcester RoadFramingham, MA 01702U. S. Nuclear Regulatory Commission Attn: Robert J. Fretz Jr.OWFN, Mailstop

  1. 4A15A11555 Rockville PikeRockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Robert L. DennigOWFN, Mailstop
  1. 10E111555 Rockville PikeRockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Ms. Jessica A. Kratchman OWFN, Mailstop
  1. 9D211555 Rockville PikeRockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Eric E. BowmanOWFN, Mailstop
  1. 12D2011555 Rockville PikeRockville, MD 20852-2378 NRC Resident Inspector Pilgrim Nuclear Power Station ATTACHMENT ToPNPS Letter 2.15.005PILGRIM NUCLEAR POWER STATION'S FOURTH SIX-MONTH STATUS REPORT IN RESPONSE TOMARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-12-049)

Attachment toPNPS Letter 2.15.005Attachment Pilgrim Nuclear Power Station's Fourth Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying LicensesWith Regard to Requirements for Mitigation Strategies forBeyond-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 changesto 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 ofJanuary 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 inFebruary 2015.3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the Overall Integrated Plan. It provides theactivity status of each item, and whether the expected completion date has changed.

The datesare 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 RevisedMilestone Completion Activity Status TargetDate* Completion DateSubmit 60 Day Status Report October 2012 CompleteSubmit Overall Integrated February 2013 CompleteImplementation PlanSubmit Six-Month Status Report August 2013 CompleteSubmit Six-Month Status Report February 2014 CompletePage 1 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015Target RevisedMilestone Completion Activity Status TargetDate* Completion DateModifications Approved for February 2014 CompleteImplementation Develop Training Plan March 2014 CompleteSubmit Six-Month Status Report August 2014 CompleteProcedure Changes Training Material October 2014 CompleteCompleteSubmit Six-Month Status Report February 2015 CompleteImplement Training (Schedule LORT March 2015 StartedPlan to Support Implementation)

Modification Implementation Complete May 2015 In ProgressDemonstration

/ Functional Test May 2015 Not StartedSubmit Post Outage 60-day Report July 2015 Not StartedSubmit Six-Month Status Report August 2015 Not StartedSubmit 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 MethodThere 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 requiredat this time.6 Open Items from Overall Integrated Plan and Interim StaffEvaluation The following tables provide a summary and status of any open items documented in theOverall Integrated Plan (OIP) and any open items or confirmatory items documented in theInterim Staff Evaluation (ISE). A fourth table includes the FLEX related NRC Audit Visit OpenItems, which includes open items on previously issued Audit Questions and new SafetyEvaluation (SE) Open Items that were not closed during the October 2014 NRC Audit Visit asdocumented in the NRC's Report for the PNPS Onsite Audit (Reference 11). A fifth tableincludes a listing of all Audit Questions and their status.Page 2 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015Note that during the October 2014 NRC Audit Visit (documented in Reference 11 of thisattachment),

the NRC utilized a spreadsheet entitled Pilgrim Nuclear Plant, SE Item Tracker tomaintain 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 OpenItem. 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 thisattachment) did not utilize the SE Tracker Audit Item Numbers and did not address all of the SETracker Items that were closed during the Onsite Audit Visit. The Audit Item Numbers utilizedbelow are in some cases from the SE Tracker spreadsheet and in some cases from the NRC'sReport for the PNPS Onsite Audit (Reference 11); the source of the Audit Item Numbers havebeen identified.

Additionally, in the Status columns of the following tables, the phrase "This item was closedduring [following]

the October 2014 NRC Audit Visit" indicates that since the item is not listed asan Open Item in the NRC's Report for the PNPS Onsite Audit Report (Reference 11 of thisattachment) the item is considered closed.Overall Integrated Plan Open Item Status1. Beyond-design-basis external event impact on Entergy has determined that norequirements in existing licensing documents will be FSAR changes are required todetermined based on input from the industry groups and reflect FLEX.direction from the NRC. This item was closed following the October 2014 NRC AuditVisit (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 AuditVisit (SE Tracker Audit Items 2-C and 4-E).Interim Staff Evaluation Open Items Status3.2.1.4.A

-On pages 16, 23, and 63 of the Integrated Plan The PNPS ISE Open andregarding Portable Equipment to Maintain Core Cooling, the Confirmatory Items arelicensee describes the use of portable pumps to provide addressed in a single documentRPV injection.

No technical basis or a supporting analysis that has been uploaded to thewas provided for the diesel-driven FLEX pump capabilities ePortal.Page 3 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015considering the pressure within the RPV and the loss of This item was statused as Openpressure 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 Iteminjecting 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 Status3.1.1 .1 .A -The Integrated Plan does not specify The PNPS ISE Open andprocedures and programs will provide for securing large Confirmatory Items areportable equipment to protect them during a seismic event or addressed in a single documentto ensure unsecured and/or non-seismic components do not that has been uploaded to thedamage 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 AuditVisit (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 theone connection point for the equipment will require access October 2014 NRC Audit Visitthrough 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 theadditional information concerning coping strategies for the October 2014 NRC Audit Visitfailure 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 thevans. The licensee is in the process of performing a October 2014 NRC Audit Visitcalculation 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 becompleted to determine if it demonstrates conformance toguidance 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 wasthat there are existing plant procedures that address considered closed during thehurricanes.

The procedures need to be evaluated for October 2014 NRC Audit Visitconformance to NEI 12-06, considerations 1, 2, and 5. (SE Tracker Audit Item 5-A),however, Reference 11 indicates the item is open. ResponsePage 4 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for theFebruary 27, 2015Implementation of FLEXInterim Staff Evaluation Confirmatory Items Statusavailable on the ePortal (FWParking Locations for FLEXpickup trucks.msg) 3.2.1.1.A

-From the June 2013 position paper, This item was closed during thebenchmarks must be identified and discussed which October 2014 NRC Audit Visitdemonstrate 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 theActive Fuel (TAF) and the cool down rate must be within October 2014 NRC Audit Visittechnical 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 theSections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position October 2014 NRC Audit Visitpaper. (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 thejustify the subset of key modeling parameters cited from October 2014 NRC Audit VisitTables 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 1020236).

This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected tosubstantially affect the ELAP analysis performed for thatlicensee's plant.3.2.1.1.E

-The specific MAAP4 analysis case that was This item was closed during theused to validate the timing of mitigating strategies in the October 2014 NRC Audit Visitintegrated 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 plotof the collapsed vessel level to confirm that TAF is notreached (the elevation of the TAF should be provided) and aplot of the temperature cool down to confirm that the cooldown is within tech spec limits.3.2.1.2.A

-The following is requested:

This item was closed during the1. Justification for the assumptions made regarding October 2014 NRC Audit Visitprimary 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 toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for theFebruary 27, 2015Implementation of FLEXInterim Staff Evaluation Confirmatory Items Statusor assumed to be single-phase liquid, two-phase

mixture, or steam at the donor cell and discuss howmixing of the leakage flow with the drywellatmosphere is modeled.3.2.1.5.A

-The integrated plan does not identify non- This item was closed during thepowered local instrumentation other than Containment October 2014 NRC Audit Visitpressure 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.

Thelicensee needs to identify the instrumentation that will beused to monitor portable FLEX electrical power equipment.

3.2.4.2.A

-The licensee was requested to provide the This item was closed during themaximum calculated MCR temperature and a detailed October 2014 NRC Audit Visitsummary of the analysis used to determine the temperature (SE Tracker Audit Item 14-A).and the procedure for control of MCR temperature.

Thelicensee response was that existing procedure 2.4.149addresses "Loss of MCR H&V". The procedure is symptomdriven, containing temperature limits to perform actions, andit is not time driven. Pilgrim will provide the referenced "GOTHIC" evaluation.

Evaluation of the "GOTHIC" analysisis needed to evaluate the MCR temperature.

3.2.4.4.A

-The licensee needs to provide complete details This item was closed during theof 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 theassessment in letters dated October 31, 2012 and February October 2014 NRC Audit Visit21, 2013 (Agencywide Documents Access and Management (SE Tracker Audit Item 16-A).System (ADAMS) Accession Nos. ML12321A051 and See Reference 11.ML1 3058A032) in response to the NRC letter dated March12, 2012, 50.54(f) request for information letter. The NRCstaff provided its evaluation on May 21, 2013 (ADAMSAccession No. ML1 3127A1 79). The NRC staff hasdetermined that the assessment for communications isreasonable, and the analyzed existing

systems, proposedenhancements, and interim measures will help to ensurethat communications are maintained.

This has beenidentified for confirmation that upgrades to the site'scommunications systems have been completed.

3.2.4.5.A

-The Integrated Plan does not identify This item was closed during theprocedures/guidance with regard to the access to the October 2014 NRC Audit VisitProtected Area and internal locked areas. During the audit (SE Tracker Audit Item 17-A).process, the licensee identified existing security doors thatprovide egress capability and have key access in the eventPage 6 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015Interim Staff Evaluation Confirmatory Items Statusof a power loss. Operations and Security are currently researching

options, the intention is to include it in theEmergency procedures addressing DDBEE perimeters, thesite declaration of 50.54(x),

and recognizing resource needs,including

Security, and compensatory measures based onthe event.3.2.4.8.A

-During the audit process, the licensee was The PNPS ISE Open andrequested to provide electrical Single Line Diagrams Confirmatory Items areshowing the proposed connections of Phase 2 and 3 addressed in a single documentelectrical equipment to permanent plant equipment.

The that has been uploaded to thelicensee 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 Auditcomplete 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 theEngineering Changes are being developed to support the October 2014 NRC Audit VisitFLEX 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 andadditional cable lengths are being incorporated into thePilgrim design calculations (load flow, short circuit andcoordination.)

The FLEX diesel generator sizes need to beverified 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 thethat at one hour, the ELAP decision is made and deep dc October 2014 NRC Audit Visitload 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 requiredloads for the mitigating strategies to maintain core cooling,containment, and spent fuel pool cooling.

During the auditprocess, the licensee responded that the dc load flowprofiles are being developed as part of a new electrical battery FLEX extended operation load flow and batterysizing study PS258.3.2.4.10.B

-The licensee was requested to provide a This item was closed during thedetailed discussion on the loads that will be shed from the dc October 2014 NRC Audit Visitbus, the equipment location (or location where the required (SE Tracker Audit Item 21-A).action needs to be taken). During the audit process, thelicensee responded by identifying that a tentative list of loadsproposed to isolate, isolation time and panel locations areavailable and provided in the ePortal.

The licensee willfinalize the load-shed list after a review by Operations.

Page 7 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015Interim Staff Evaluation Confirmatory Items Status3.2.4.A -The licensee's plans for the use of off-site The PNPS ISE Open andresources did not address considerations 2 through 10 of Confirmatory Items areNEI 12-06, Section 12.2. addressed in a single documentthat has been uploaded to theePortal.This item was closed following the October 2014 NRC AuditVisit (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 InputAudit Item Item Description i StatusReference NeededISE 01 3.2.1.4.A (SE TrackerAudit Item 12-A)Pages 16, 23, and 63 of theIntegrated Plan [NRC OrderEA-12-049, dated February28, 2013, (ADAMSAccession No. ML13063A063)],

regarding Portable Equipment toMaintain Core Cooling,Entergy describes the use ofpotable pumps to providereactor pressure vesselinjection.

No technical basisor supporting analysis wasprovided for the dieseldriven FLEX pumpcapabilities considering thepressure within the RPV andthe loss of pressure alongwith details regarding theFLEX pump supply lineroutes, length of hose runs,connecting

fittings, andelevation changes to showthat the pump is capable ofinjecting water into the RPVwith a sufficient rate tomaintain and recover coreinventory for both theprimary and alternate flowpaths.Entergy has actionto provide therevised hydraulic calculations andanalysis thatdemonstrate thatthe portable pumphas sufficient netpositive suctionhead.Hydraulic calculation has been revised andavailable on the ePortal(Calc M1384 EC45558ECN54090.pdf).

Page 8 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015October 2014 NRC Audit Visit FLEX Related Open Items (Reference 11)Audit Item Item Description Licensee InputReference NeededAQ 60 Describe plans for supplying Entergy to provide Response is available (SE Tracker fuel oil to FLEX equipment NRC staff of on the ePortal (AnswerAudit 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 fuelquality will be assured ifstored for extended periodsof 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 isAudit Item 53-B) phases 2 and 3. The staff pump. Entergy has in progress.

requested information on not completed thisthe 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 forelectrical equipment to electrical switchgear HPCI/RCIC Pumpensure the equipment can room. Rooms, Switchgear perform as expected during Rooms, Main Controla loss of ventilation as a Room and Batteryresult of ELAP (Primary Rooms are in progress.

Areas will includedHPCI/RCIC Pump Rooms,Switchgear Rooms, MainControl Room, and BatteryRooms).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 andAudit Item 10-E) plan, confirm that the evaluated the issue the quenchers isstresses associated with previously and available on the ePortalpassing liquid phase water consider whether (PNPS Audit Item 10-Ethrough the SRV tail pipe, additional review Liquid Phase Waterincluding those on the tail from structural through SRV Tail Pipepipe, the tail pipe supports, experts is necessary 12-15-2014.docx).

the quencher and the to assist in review.quencher supports areevaluated with acceptable results.Page 9 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015October 2014 NRC Audit Visit FLEX Related Open Items (Reference 11)Audit Item Item Description Licensee Input StatusReference NeededRAI SE No. 7 Extended loss of alternating Entergy developing Response is available (SE Tracker current during low power procedures.

on the ePortal (OpenAudit Item 11-E) modes. Audit Item 11-EResponse 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 (AnswerAudit Item 12-E) to Phase 3. equipment from the to 12-E.docx)

Regional ResponseCenter.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 AuditAudit Item 13-E) generator is sufficient as 'N' this battery.

Item 13E.msg)if the 250 volt battery lasts10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.AuditQuestions Status Completion or Target DatePNPS-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 withAudit 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.Page 10 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015AuditQuest Status Completion or Target DateQuestions PNPS-008 In Progress.

The associated ISE Cl was March 2015(SE Tracker considered closed during the OctoberAudit Item 6-B) 2014 NRC Audit Visit, however,Reference 11 indicates the ISE Cl isopen (associated with ISE confirmatory Item 3.1.3.2.A).

This AQ response will beupdated when information is available.

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

SeeReference 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 withAudit Item 13-B) ISE Confirmatory Items 3.2.1.1.A and3.2.1.1.E

)PNPS-016 This item was closed during the October N/A(SE Tracker 2014 NRC Audit Visit (associated withAudit 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 withAudit Item 15-B) ISE Confirmatory Items 3.2.1.1.B and3.2.1.1.D)

Page 11 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015AuditQuest Status Completion or Target DateQuestions 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 withAudit 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 withAudit Item 27-B) ISE Confirmatory Item 3.2.4.2.A)

Page 12 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015AuditQuest Status Completion or Target DateQuestions 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 withAudit Item 33-B) ISE Confirmatory Items 3.2.4.4.A and3.2.4.4.B)

PNPS-040 This item was closed during the October N/A(SE Tracker 2014 NRC Audit Visit (associated withAudit 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 asAudit Item 39-B) documented in Reference 11 (associated with ISE Confirmatory Item 3.4.A)Page 13 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015AuditQuest Status Completion or Target DateQuestions 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 withAudit 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 withAudit 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 withAudit 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 theNRC Audit ePortal.Report AuditItem 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 withAudit 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.Page 14 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 2015AuditQuest Status Completion or Target DateQuestions 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 whenNRC Audit information is available.

Report AuditItem 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 ImpactsEntergy has not identified any additional potential impacts to the Interim Staff Evaluation sincethe previous six month status report (Reference 10).8 References The following references support the updates to the Overall Integrated Plan described in thisenclosure.

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),"

datedFebruary 28, 2013.2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements forMitigation 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 HardenedContainment Vents, dated March 12, 2012.4. NRC Order Number EA-1 3-109, Order to Modify Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions, dated June 6,2013.Page 15 of 16 Attachment toPNPS Letter 2.15.005PNPS's Fourth Six Month Status Report for the Implementation of FLEXFebruary 27, 20155. 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 Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (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 OverallIntegrated 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 Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (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 Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (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 andEA-12-051 (TAC NOS. MF0777 and MF0778) dated January 26, 2015 (PNPS Letter1.15.003)

(ML14349A518)

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