Vermont Yankee Presentation to VSNAP 7/9/12

VY/Entergy Fukushima ResponseBernard Buteau

Tonight’s Presentation

• Industry Actions Immediately Following the accident at Fukushima

• Key Priorities for longer term responses• Industry response to INPO Event Report and NRC Orders• Industry FLEX approach• VY Specific Response to INPO Event Report• VY Schedule to respond to NRC Orders• Entergy Organizational Structure addressing NRC Orders

Industry Starting Points• NRC Near Term Task Force (NTTF) established to identify Fukushima

Lessons Learned• NRC Management established priorities to address Task Force

Recommendations • 3 Priorities established: Tiers 1, 2, and 3

– Tier 1 Issues being addressed now– NRC Orders and 50.54(f) address Tier 1 Recommendations– Tier 1 issue on Station Blackout (SBO) Rulemaking intended to address

gaps between current SBO regulations and loss of power due to Beyond Design Basis Events

• Joint industry/Nuclear Energy Institute (NEI) Task Forces working with NRC for all issues; Entergy represented on all Task Forces

• Standardization – industry/fleet working through NEI to establish common guidance, methods, and submittals; Entergy developing fleet solutions

Design Basis and Beyond Design Basis

• Design Basis information identifies specific functions performed by a system, structure or component as defined in the Vermont Yankee Updated Final Safety Analysis Report (UFSAR)

• Design Basis Events incorporate realistic worst case scenarios (e.g. Maximum Expected Flood conditions, Seismic Events, etc…)

• Beyond Design Basis Events postulate events that are more severe than those considered as Design Basis Events

Key Priorities• Maintain Operational Safety Focus• Create an Entergy Fukushima response Organization

– Establish Points of Contact – Corporate Governance and Site Execution

– Brief Site Points of Contact– Select Vendors

• Develop work breakdown structure/project scoping• Establish plans, resource needs, and budgets• Enhance integration with and communications to sites

Tier 1 Recommendations• Seismic/Flooding Reevaluation [Analyses]• Seismic/Flooding Inspections• SBO/Extended Loss of AC Power Rulemaking• Mitigation of Beyond Design Basis Events

– Loss Of Ultimate Heat Sink [LUHS] and – Extended Loss of AC Power [ELAP]

• Reassess Mark I Hardened Containment Vent • Install new Spent Fuel Pool Instrumentation • Enhance Emergency Operating Procedures (EOPs)

Severe Accident Management Guidelines (SAMGs) and Extensive Damage Management Guidelines (EDMGs)

• Reassess Emergency Plan (EP) Staffing and Communications

NRC Orders and 50.54(f) LetterMarch 12, 2012

Three Orders– Hardened Containment Vents– Spent Fuel Pool Instrumentation– Mitigation Strategies for Beyond Design Basis External Events

(Note: For VY the design basis river level is 252 feet – normal river level is around 219 feet. River level rose to a max of 223 feet after Hurricane Irene)

50.54(f) Letter - (NRC Requests for Information)– Perform Seismic Reevaluation and Inspections to new criteria– Perform Flooding Reevaluation and Inspections to new criteria– Assess Emergency Plan Staffing and Communications to new

criteria

Order 1 - Mitigation Strategies for Beyond Design Basis (BDB) External Events

• Strategies must maintain/restore core cooling, containment, and Spent Fuel Pool cooling

• Response equipment must be reasonably protected from external events

• Three phased approach to severe events, including Extended Loss of all AC Power (ELAP) and Loss of Ultimate Heat Sink (LUHS)– Phase 1 relies on installed equipment and resources to respond to

severe event– Phase 2 relies on portable, onsite equipment to extend response

capability– Phase 3 relies on offsite resources for long term response

• Industry has proposed FLEX system• Interim Staff Guidance to be issued by NRC in August 2012

Order 2 - Hardened Containment Vent

• Design Features:– Requires remote operation AND monitoring capability– Sized to prevent containment overpressure– No spurious actuation– Upgrades containment vent in place since early 1990s

• Interim Staff Guidance scheduled to be issued by NRC in August 2012

Order 3 - SFP Instrumentation• Design Features:

– Independent primary backup instruments to measure pool level

– Protected from hazards– Mounted to ensure functionality post-seismic

event– Can withstand expected environment

• Interim Staff Guidance scheduled to be issued by NRC in August 2012

The Industry FLEX Approach• Industry response to Order on Beyond Design

Basis (BDB) Events• Key Goals:

– Prevent fuel damage (Core and Spent Fuel Pool)– Provide diverse, redundant, “flexible” means to restore and

maintain core and fuel pool cooling and containment• Assumes Extended Loss of AC Power and Loss of

Ultimate Heat Sink• N+1 Sets of Portable equipment for mitigation• Interim Staff Guidance scheduled to be issued by NRC

in August 2012• First round of equipment ordered for each site

NEI 12-06 Diverse and Flexible coping Strategies (FLEX)

NRC Orders – Key DatesMar 2012 NRC Orders issued

Apr 2012 Sites acknowledge “no hardship” with the Orders; COMPLETE

Aug 2012 NRC to issue Interim Staff Guidance

Oct 2012 Initial Status Reports due from industry

Feb 2013 Overall Integrated Plans due (update every 6 months thereafter)

Full Compliance to all Orders must be achieved by the sooner of December 31, 2016 or the 2nd RFO from submittal of the integrated plan

INPO and NRC Fukushima OrdersINPO Requirements

• 3/15/11 INPO Event Report (IER) 11-1* [All actions required complete by 4/16/11]

NRC Requirements

• 4/18/11 NRC issued Inspection Manual / Temp Instructions

• 4/22/11 NRC Inspection of VY per Temp Instructions {NRC Inspection / no findings}

• 5/11/11 NRC Bulletin 2011-11 “Mitigating Strategies” issued to obtain a comprehensive verification that licensees' mitigating strategies maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire

• 3/12/12 – NRC issued Orders to modify licenses

* Tsunami occurred on 3/11/11

VY Immediate Response to INPO Event Report 11-1

• Addressed recommendations made in INPO Level 1 Event Report 11-1 by doing the following:

• Verified plant staff’s ability to mitigate conditions that result from beyond design basis events (Security, Severe Accident Management)

• Verified that emergency equipment is available and functional• Tested active equipment and walked down and inspected passive equipment• Verified that procedures to implement needed strategies are in place and

executable• Verified qualifications of operators and support staff who operate the

emergency equipment• Verified that needed agreements and contracts are in place to help mitigate

consequences

Above actions were performed by March 23rd , 2011

VY Immediate Response toINPO Event Report 11-1

• Verified the capability to mitigate Station Blackout (SBO) required by station design is functional and valid

• Performed walk downs and inspections to verify all required materials properly staged

• Demonstrated through walk downs that procedures for response to SBO are executable

• Completed walk downs and inspections by March 30th, 2011

VY Immediate Response toINPO Event Report 11-1

• Verified the capability to mitigate internal and external flooding events meets station design:• Verified through walk downs and inspections that

required materials and equipment are adequate and properly staged

• Verified that accessible doors and barriers are functional

• Completed verification actions by April 6th, 2011

VY Immediate response toINPO Event Report 11-1

• Performed walk downs and inspections of equipment needed to mitigate fire and flood events to identify the potential that the equipment’s function could be lost during a seismic event Identified mitigating strategies for identified vulnerabilities

• Performed walk downs and inspections of important equipment such as:– Storage tanks– Plant water intake structure and – Fire and flood response equipment

to develop mitigating strategies to cope with loss of important functions• These walk downs and inspections were completed by

April 13th, 2011

VY Immediate response to INPO Level 1 Event Report

Results

• Enhancement/Improvement recommendations included items such as:– Creation of new Preventive Maintenance activities to check air

pressure in vehicle tires, modify cooling tower panels to allow faster access to deep basin, create test to check pump flow, etc

– Replacement of small portable generator– Enhancing procedures to add or improve content– Creating new or improved training modules

Any issues identified during the INPO walk downs were entered into the VY Corrective Action Tracking system

VY Fukushima Projected Response Dates to NRC Orders

SR Vice President

Fukushima Project – Management Organization – Over 100 staff & Contract Personnel

VP Engineering VP Project Management

VP Project Licensing VP Fukushima Project

Sr. Licensing Manager Executive Assistant General Manager

Project Director

Engineering Lead

Fleet Project Manager

Licensing Lead

Director Project Mgt

Fleet DE Leads

Fleet Licensing Leads

Fukushima Project – Design Engineering Organization

Contractor Lead Eng

VP Engineering

Lead Engineer

SBO/FLEX Lead

Seismic Lead

Flooding Lead

Cont. Vent Lead

SFP Instr. Lead

EP Lead

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-

W3 -

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Entergy Site LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

VP Fukushima Project

GM Engineering

Seismic Lead

Executive Sponsor

Asst. Executive Sponsor

PM Director

Fleet PM

Assistant PM

Manager of Projects(9 sites)

Entergy Site PMsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Site Project TeamsEstimator Scheduler Cost Eng.

Engineering Field Eng. Licensing

EP Support Operations Maintenance

(Others as needed)

Sr. Licensing Mgr

Licensing Engineer

Site Licensing Mgrs(9 sites)

EP Director

Site Licensing Leads ANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

EP Managers(9 sites)

Site EP Staff LeadsANO -

GGNS - IPEC -JAF - PLP -

PNPS -RBS -VY-W3 -

Fukushima Project – Project Team Organization

Corp. Project Team Scheduler Estimator

Cost Eng. - Communications -

Corporate Positions

DE Director

Questions?