ML14253A189

Pilgrim - 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 A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.14.061, EA-12-049
Download: ML14253A189 (15)

Text

SEntergyEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360John A. Dent, Jr.Site Vice President August 28, 2014U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station's Third 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 2.14.061

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)

PNPS Letter 2.14.061Page 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)

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. 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 progressmade in implementing the requirements of Reference

1. The attached report provides anupdate of milestone accomplishments since the last status report, including any changes to thecompliance 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 toReference 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 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 is PNPS Letter 2.14.061Page 3 of 4otherwise 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 August28, 2014.Sincerely,

Attachment:

Pilgrim Nuclear Power Station's Third 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. William M. DeanRegional 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 2.14.061Page 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 2.14.061PILGRIM NUCLEAR POWER STATION'S THIRD 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 2.14.061Attachment Pilgrim Nuclear Power Station's Third 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 Overall Integrated Plan, including any changes to thecompliance 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 ofJuly 31, 2014.* Second Six-Month Status Report -February 2014* Third Six-Month Status Report -Complete with submission of this document inAugust 2014.3 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 CompleteModifications Approved for February 2014 CompleteImplementation Page 1 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Target RevisedMilestone Completion Activity Status TargetDate* Completion DateDevelop Training Plan March 2014 CompleteSubmit Six-Month Status Report August 2014 CompleteProcedure Changes Training Material October 2014 In ProgressCompleteSubmit Six-Month Status Report February 2015 Not StartedImplement Training (Schedule LORT March 2015 Not StartedPlan to Support Implementation)

Modification Implementation Complete May 2015 In ProgressDemonstration

/ Functional Test June 2015 Not StartedSubmit Six-Month Status Report August 2015 Not StartedSubmit Completion Report December 2015 Not Started*Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month statusreport.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 and any open items or confirmatory items documented in the InterimStaff Evaluation (ISE). A fourth table includes a listing of Audit Questions and their status.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.Page 2 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Overall Integrated Plan Open Item Status2. Structure, content and details of the Regional Response Not StartedCenter playbook will be determined.

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.considering the pressure within the RPV and the loss ofpressure along with details regarding the FLEX pump supplyline routes, length of hoses runs, connecting

fittings, andelevation changes to show that the pump is capable ofinjecting water into the RPV with a sufficient rate to maintainand 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 3.3.1.1.2.A

-The licensee identified that access to at least The PNPS ISE Open andone connection point for the equipment will requires access Confirmatory Items arethrough routes that are not FSAR Seismic Class I, however addressed in a single documentthey have been evaluated and the potential for large scale that has been uploaded to thedebris 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 andadditional information concerning coping strategies for the Confirmatory Items arefailure of seismically qualified electrical equipment that can addressed in a single documentbe affected by beyond-design-basis seismic events as that has been uploaded to thediscussed 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 andvans. The licensee is in the process of performing a Confirmatory Items arecalculation to demonstrate conformance with NEI 12-06, addressed in a single documentSection 7.3.1.b, bullet 4 related to adequate tie down of the that has been uploaded to thePage 3 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Interim Staff Evaluation Confirmatory Items Statussea vans. Evaluation of the completed calculation must be ePortal.completed 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 The PNPS ISE Open andthat there are existing plant procedures that address Confirmatory Items arehurricanes.

The procedures need to be evaluated for addressed in a single documentconformance to NEI 12-06, considerations 1, 2, and 5. that has been uploaded to theePortal.3.2.1.1.A-From the June 2013 position paper, The PNPS ISE Open andbenchmarks must be identified and discussed which Confirmatory Items aredemonstrate 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 theExtended 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 andActive Fuel (TAF) and the cool down rate must be within Confirmatory Items aretechnical specification limits. addressed in a single documentthat has been uploaded to theePortal.3.2.1.1 .C -MAAP4 must be used in accordance with The PNPS ISE Open andSections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position Confirmatory Items arepaper. addressed in a single documentthat has been uploaded to theePortal.3.2.1.1.D

-In using MAAP4, the licensee must identify and The PNPS ISE Open andjustify the subset of key modeling parameters cited from Confirmatory Items areTables 4-1 through 4-6 of the "MAAP4 Application addressed in a single documentGuidance, Desktop Reference for Using MAAP4 Software, that has been uploaded to theRevision 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 tosubstantially affect the ELAP analysis performed for thatlicensee's plant.3.2.1.1 .E -The specific MAAP4 analysis case that was The PNPS ISE Open andused to validate the timing of mitigating strategies in the Confirmatory Items areintegrated plan must be identified and should be available on addressed in a single documentthe ePortal for NRC staff to view. Alternately, a comparable that has been uploaded to thelevel of information may be included in the supplemental ePortal.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.Page 4 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Interim Staff Evaluation Confirmatory ItemsStatus3.2.1.2.A

-The following is requested:

The PNPS ISE Open and1. Justification for the assumptions made regarding Confirmatory Items areprimary system leakage from the recirculation pump addressed in a single documentseals and other sources.

that has been uploaded to the2. 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 howmixing of the leakage flow with the drywellatmosphere is modeled.3.2.1.5.A

-The integrated plan does not identify non- The PNPS ISE Open andpowered local instrumentation other than Containment Confirmatory Items arepressure and RPV level and pressure.

The integrated plan addressed in a single documentidentifies that phase 2 equipment will have installed local that has been uploaded to theinstrumentation needed to operate the equipment.

The ePortal.licensee 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 The PNPS ISE Open andmaximum calculated MCR temperature and a detailed Confirmatory Items aresummary of the analysis used to determine the temperature addressed in a single documentand the procedure for control of MCR temperature.

The that has been uploaded to thelicensee response was that existing procedure 2.4.149 ePortal.addresses "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 The PNPS ISE Open andof portable lighting.

Confirmatory Items areaddressed in a single documentthat has been uploaded to theePortal.3.2.4.4.B

-The licensee provided its communications The PNPS ISE Open andassessment in letters dated October 31, 2012 and February Confirmatory Items are21, 2013 (Agencywide Documents Access and Management addressed in a single documentSystem (ADAMS) Accession Nos. ML12321A051 and that has been uploaded to theML1 3058A032) in response to the NRC letter dated March ePortal.12, 2012, 50.54(f) request for information letter. The NRCstaff provided its evaluation on May 21, 2013 (ADAMSAccession No. ML13127A179).

The NRC staff hasdetermined that the assessment for communications isreasonable, and the analyzed existing

systems, proposedenhancements, and interim measures will help to ensurePage 5 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Interim Staff Evaluation Confirmatory Items Statusthat 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 The PNPS ISE Open andprocedures/guidance with regard to the access to the Confirmatory Items areProtected Area and internal locked areas. During the audit addressed in a single documentprocess, the licensee identified existing security doors that that has been uploaded to theprovide 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 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

&EC45556),

will be posted to the ePortal.

The NRC staff willcomplete the review after they are posted.3.2.4.8.B

-During the audit process, the licensee identified The PNPS ISE Open andEngineering Changes are being developed to support the Confirmatory Items areFLEX project which requires electrical studies to be addressed in a single documentperformed.

This includes the electrical diesel loading and that has been uploaded to theload flow studies.

The addition of the transfer switches and ePortal.additional 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 The PNPS ISE Open andthat at one hour, the ELAP decision is made and deep dc Confirmatory Items areload 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 documentthe dc load shed is complete (item 4). The licensee was that has been uploaded to therequested 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 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 The PNPS ISE Open anddetailed discussion on the loads that will be shed from the dc Confirmatory Items arePage 6 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Interim Staff Evaluation Confirmatory Items Statusbus, the equipment location (or location where the required addressed in a single documentaction needs to be taken). During the audit process, the that has been uploaded to thelicensee responded by identifying that a tentative list of loads ePortal.proposed 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.

3.4.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.Audit Questions Status Completion or TargetDatePNPS-002 Closed*PNPS-003 Closed* (See ISE Confirmatory Item3.1.1.2.A response)

PNPS-004 Closed*PNPS-006 Closed*PNPS-007 Closed*PNPS-008 Closed* (See ISE Confirmatory Item3.1.3.2.A response)

PNPS-009 Closed* (See ISE Confirmatory Item3.1.3.1.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 Item3.2.1.1.C response)

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

Page 7 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Audit Questions Status Completion or TargetDatePNPS-018 Closed*PNPS-019 Closed* (See ISE Confirmatory Item3.2.1.1.A)

PNPS-020 Closed*PNPS-021 Closed*PNPS-022 Closed*PNPS-024 Closed*PNPS-025 Closed*PNPS-026 Updated response available on theePortalPNPS-027 Closed*PNPS-030 Closed*PNPS-032 Closed*Closed* (See ISE Confirmatory Item3.2.4.2.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 Item3.2.4.5.A response)

PNPS-042 Closed*PNPS-043 Closed*PNPS-044 Closed*PNPS-046 Closed*Closed* (See ISE Confirmatory ItemPNPS-047 34A3.4.A)PNPS-049 Closed*Page 8 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 2014Audit Questions Status Completion or TargetDatePNPS-053 Closed*PNPS-054 Closed* (See ISE Confirmatory Item3.2.4.10.A response)

PNPS-055 Closed* (See ISE Confirmatory Item3.2.4.10.B)

PNPS-056 Closed*Closed* (See ISE Confirmatory Item3.2.4.8.B)

PNPS-058 Closed*PNPS-059 Closed*PNPS-060 Closed*PNPS-065 Updated response available onePortalPNPS-066 Closed* (See ISE Confirmatory Item3.2.4.8.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 ImpactsEntergy has not identified any additional potential impacts to the Interim Staff Evaluation sincethe previous six month status report (Reference 9).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.Page 9 of 10 Attachment toPNPS Letter 2.14.061PNPS's Third Six Month Status Report for the Implementation of FLEXAugust 28, 20143. 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 6,2013.5. 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 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)

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