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MONTHYEARML13346A0132013-11-26026 November 2013 Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Project stage: Supplement ML14037A2072014-01-31031 January 2014 Update to Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Project stage: Response to RAI ML14171A2002014-06-26026 June 2014 Staff Assessment of the Flooding Walkdown Report Supporting Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident (MF0264) Project stage: Acceptance Review 2014-01-31
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Category:Letter
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En tergyEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360November 26, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852John A. Dent, Jr.Site Vice President
SUBJECT:
Supplemental Response to NRC Request for Information Pursuant to 10CFR 50.54(f)
Regarding the Flooding Aspects of Recommendation 2.3 ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-ichiAccidentPilgrim Nuclear Power StationDocket No. 50-293License No. DPR-35
REFERENCES:
- 1. NRC Letter, "Request for Information Pursuant to Title 10 of the Codeof Federal Regulations 50.54(f)
Regarding Recommendations 2.1, 2.3,and 9.3 of the Near-Term Task Force Review of Insights from theFukushima Dai-ichi Accident",
dated March 12, 2012 (ADAMSAccession No. ML12053A340)
- 2. Entergy Letter to NRC, "Flooding Walkdown Report -Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from Fukushima Dai-ichi
- Accident, dated November 27, 2012 (PNPS Letter 2.12.076)
LETTER NUMBER 2.13.086
Dear Sir or Madam:
On March 12, 2012, the NRC issued Reference 1 to all power reactor licensees and holdersof construction permits in active or deferred status. Enclosure 4 of Reference 1 requested each licensee perform flood protection walkdowns and report the results within 180 days ofNRC endorsement of flooding walkdown guidelines NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features",
Rev. 0-A.Entergy completed the flood protection walkdowns at Pilgrim Nuclear Power Station andsubmitted the results via Reference
- 2. Reference 2 identified where restricted accessprevented walkdown of certain flood protection features.
Walkdowns of the restricted accessitems have been completed and the results are provided in the table attached to this letter.This submittal closes all the open items identified in Reference 2.The attached table provides a list of the restricted access items inspected, their respective disposition, and any action planned or taken. As a result of the inspections:
There were no additional deficiencies found in the supplemental walkdown.
Oneobserved condition did not meet the NEI 12-07 acceptance criteria and was enteredinto the Corrective Action Program but was determined to not be a deficiency asdefined in NEI 12-07. A_')c.p PNPS Letter 2.13.086Page 2 of 3* No temporary measures were required as a result of the completed inspections.
- Available physical margins (APMs) were collected and documented in the walkdownrecord forms for each applicable item inspected.
- All restricted items inspected were within the plant maintenance and monitoring programs unless identified as a deficiency in Table 1 of the attachment.
- Two of the restricted access items (Table #2 of Section 7.4 of the Flooding Report)and one of the inaccessible items (Table #3 of Section 7.4 of the Flooding Report)were reclassified to not be flooding features.
- One of the inaccessible items in Table #3 of Section 7.4 of the Flooding Report wasdetermined to be accessible from a manhole.
Inspection was completed satisfactory.
This letter contains no new regulatory commitments.
Should you have any questions concerning the content of this letter, please contact Mr.Joseph R. Lynch, Manager, Regulatory Assurance at (508) 830-8403.
I declare under penalty of perjury that the foregoing is true and correct; executed onNovember 26, 2013.Sincerely, John A. Dent Jr.Site Vice President JAD/rmb
Attachment:
Pilgrim Nuclear Power Station (PNPS) Resolution of Open Itemscc: Mr. William M. DeanRegional Administrator, Region 1U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100King of Prussia, PA 19406-2713 U. S. Nuclear Regulatory Commission
- Director, Office of Nuclear Reactor Regulation One White Flint North11555 Rockville PikeRockville, MD 20852-2378 Ms. Nadiyah Morgan, Project ManagerOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2AWashington, DC 20555 PNPS Letter 2.13.086Page 3 of 3Mr. John Giarrusso Jr.Planning, Preparedness
& Nuclear Section ChiefMass. Emergency Management Agency400 Worcester RoadFramingham, MA 01702U. S. Nuclear Regulatory Commission ATTN: Robert J. Fretz Jr.Mail Stop OWFN/4A15A 11555 Rockville PikeRockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert L. DennigMail Stop OWFN/1OE1 11555 Rockville PikeRockville, MD 20852-2378 NRC Senior Resident Inspector Pilgrim Nuclear Power Station ATTACHMENT toPNPS Letter 2.13.086PILGRIM NUCLEAR POWER STATION (PNPS)RESOLUTION OF OPEN ITEMS Attachment PNPS Letter 2.13.086Page 1 of 2RESOLUTION OF OPEN ITEMSReport D t en or PlannedFeature Description Ref (yes/no "Deficiency Description ActionsTRef (y....sscrit Observed conditions that Inspection completed and WO written to repairSection did not meet the NEI 12-07 degraded seal conditions.
The path that theDuct bank in the NW corner of the B 7.4 No acceptance criteria were minimal leakage will take due to one degradedRBCCW room, located -18" from entered into the CAP and seal and small head migrates to the torusthe north wall Table #2 were determined to not be compartment that may hold up to 70,000 gal ofdeficiencies as defined in water bounded by internal flooding analysis.
NEI 12-01.SectionConduits in the Condenser Bay, No None Inspection completed satisfactorily.
Turbine Building, Area 8 Table #2The conduits penetrating at J1 22 areSection continuous, do not transit through manholes, Start-up Transformer (SUT E3) 7.4 No and terminate in an elevated, gasketed cabinetJ122 Duct Bank located in the Not applicable, see actions encased in a weather tight concrete building inMonitor Tank Room Table #2 taken. the switchyard.
Therefore, the penetrations conduits to cable seals at J122 are not to becredited as a flood protection feature.Upon detailed review and scrutiny of externalconduit pathway it has been determined thatSection conduits running South from J653 do notShut-down Transformer (SUT E3) 7.4 No Not applicable, see actions transit through manholes.
They are encased inJ653 Duct Bank located in the taken.conduits and gasketed junction boxedMonitor Tank Room Table #2 throughout their run, ending above the floodlevel. Therefore the penetrations conduits tocable seals at J653 are not to be credited as aflood protection feature.
Attachment PNPS Letter 2.13.086Page 2 of 2p rt' D eficie ncy " ---- A .k o Plan nedFeature Description Deficiency Description Actions Taken or Plannedi Rf (yes/ino),
Reclassified Inaccessible FeaturesConduits terminating in A8 were alsoSection scrutinized and identified to terminate in the7.4 No Not applicable, see actions main transformer above flood height with noMonitor Tank Room A-8 duct bank taken. passage through a manhole.
The cables areTable #3 contained within the conduits; the conduit tocable seals are no longer identified as floodfeatures.
In completing detailed reviews and applyingeSection additional scrutiny of external conduitSeals in conduits from Screen Secn pathways and restrictions of features classified house, located in B-RBCCW room No None as restricted, the seals in conduits from the7.4le Ne Screen house were able to be inspected Table #3 externally with additional security precautions from the manhole.
Seals were identified to bein acceptable condition.