ML13247A411

Pilgrim Nuclear Power Station'S First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Stratgies for Beyond-Design-Basis External Events

ML13247A411
Person / Time
Site:	Pilgrim
Issue date:	08/28/2013
From:	Dent J A Entergy Nuclear Operations
To:	Document Control Desk
References
EA-12-049
Download: ML13247A411 (8)

Text

uF EntergyEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360John A. Dent, Jr.Site Vice President August 28, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station's First Six-Month Status Report inResponse to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

REFERENCE:

1. NRC Order Number EA-12-049, "Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events",

dated March 12, 2012 (PNPS Letter 1.12.013)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance withOrder EA-12-049, Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML 12229A1 74)3. Nuclear Energy Institute (NEI) 12-06, Revision 0, "Diverse andFlexible Coping Strategies (FLEX) Implementation Guide", datedAugust 20124. Pilgrim Nuclear Power Station Letter to NRC, "Initial Status Reportin Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-1 2-049)",dated October 29, 2012 (PNPS Letter 2.12.072)

5. Pilgrim Nuclear Power Station Letter to NRC, "Overall Integrated Plan Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049)",

dated February 28, 2013 (PNPS Letter 2.13.012)

6. NRC Order Number EA-12-050, "Order to Modify Licenses WithRegard To Reliable Hardened Containment Vents", dated March 12,2012 (PNPS Letter 1.12.014) 14(6(~

PNPS Letter 2.13.069Page 2 of 47. NRC Order Number EA-13-109, "Order to Modify Licenses WithRegard To Reliable Hardened Containment Vents Capable ofOperation Under Severe Accident Conditions",

dated June 6, 2013(PNPS Letter 1.13.028)

LETTER NUMBER 2.13.069

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to Entergy.

Reference 1 was immediately effective anddirects Entergy to develop, implement, and maintain guidance and strategies to maintainor restore core cooling, containment, and spent fuel pool cooling capabilities in the eventof a beyond-design-basis external event. Specific requirements are outlined inAttachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance ofthe final interim staff guidance (Reference

2) and an overall integrated plan pursuant toSection 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 provided the Pilgrim Station initial status report regarding mitigation strategies.

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

The purpose of this letter is to provide the first 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 reportprovides 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.The FLEX strategies in the Overall Implementation Plan currently rely on the currentconceptual design of the reliable hardened vent (RHV) system that was developed inresponse to Reference 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 NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required.

The industry, through NEI andthe owners' group, is addressing the new requirements provided in NRC Order EA-13-109 on the schedule outlined in NRC Order EA-1 3-109. Because of the new order (NRCOrder EA-1 3-109), the design of the hardened containment vent is being reevaluated.

Any design changes resulting from the revised hardened vent order will be reflected in afuture six month update.Should you have any questions concerning the content of this letter, please contact Mr.Joseph R. Lynch at (508) 830-8403.

PNPS Letter 2.13.069Page 3 of 4This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed onAugust 28, 2013.Sincerely, ohnA.Dent Jr.JAD/rmb

Attachment:

Pilgrim Nuclear Power Station's First Six-Month 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) 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 Mr. Richard V. Guzman, Project ManagerOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2AWashington, DC 20555Mr. 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. 4A1 5A11555 Rockville PikeRockville, MD 20852-2378 PNPS Letter 2.13.069Page 4 of 4U. S. Nuclear Regulatory Commission Attn: Robert L. DennigOWFN, Mailstop

1. 1OE111555 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 2.13.069PILGRIM NUCLEAR POWER STATION'S FIRST 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 Pilgrim Nuclear Power Station's First 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 the development of the OverallIntegrated Plan (Reference 1), and are current as of July 31, 2013.None.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.

• Validation Demonstration/Functional Test: The demonstrations/functional tests will be completed duringand following the FLEX modification implementation outage.The revised milestone target completion dates do not impact the order implementation date.Target RevisedMilestone Completion Activity TargetDate Status Completion DateSubmit 60 Day Status Report October 2012 CompleteSubmit Overall Integrated February 2013 CompleteImplementation PlanSubmit 6 Month Status Report August 2013 CompleteSubmit 6 Month Status Report February 2014 Not StartedModifications Approved for February 2014 Not StartedImplementation Develop Training Plan March 2014 Not StartedSubmit 6 Month Status Report August 2014 Not StartedPage 2 of 4 PNPS's First Six Month Status Report for theAugust 28, 2013Implementation of FLEXTarget RevisedMilestone Completion Activity TargetDate Status Completion Date_ _DateProcedure Changes Training Material October 2014 Not StartedCompleteSubmit 6 Month Status Report February 2015 Not StartedImplement Training (Schedule LORT March 2015 Not StartedPlan to Support Implementation)

Modification Implementation Complete May 2015 Not StartedDemonstration

/ Functional Test June 2015 Not StartedSubmit 6 Month Status Report August 2015 Not StartedSubmit Completion Report December 2015 Not Started4 Changes to Compliance MethodThe 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 3, NRC Order EA-12-050.

Reference 4, 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-13-109 on the schedule outlined in NRC OrderEA-13-109.

Because of the new order (NRC Order EA-1 3-109), the design of the hardenedcontainment vent is being reevaluated.

Any design changes resulting from the revised hardenedvent order will be reflected in a future six month update.There 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 Draft SafetyEvaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.Overall Integrated Plan Open Item StatusNone.Draft Safety Evaluation Open Item StatusNone.7 Potential Draft Safety Evaluation ImpactsThere are no potential impacts to the Draft Safety Evaluation identified at this time.Page 3 of 4 PNPS's First Six Month Status Report for the Implementation of FLEXAugust 28, 20138 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-13-109, Order to Modify Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.Page 4 of 4