JAFP-13-0112, First 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)

First 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)

ML13241A204
Person / Time
Site:	FitzPatrick
Issue date:	08/28/2013
From:	Coyle L Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, JAFP-13-0112
Download: ML13241A204 (6)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Lawrence M. Coyle Site Vice President - JAF JAFP-13-0112 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

First 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)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC Order Number, EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

2. NRC Interim Staff Guidance, JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

4. Entergy to NRC, JAFP-12-0124, Initial 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), dated October 29, 2012

5. Entergy to NRC, JAFP-13-0025, 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), dated February 28, 2013

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order [Reference 1] to James A. FitzPatrick Nuclear Power Plant (JAF). Reference 1 was immediately effective and directs JAF to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling

JAFP-13-0112 Page 2 of 2 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 the final interim staff guidance [Reference 2] and an overall integrated plan pursuant to Section IV, Condition C.2. 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 JAF initial status report regarding mitigation strategies. Reference 5 provided the JAF 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 the content 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 report provides 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.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Chris M. Adner, Licensing Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 281h day of August, 2013.

awrence M. Coyle Site Vice President LMC/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Mohan Thadani, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. Francis J. Murray Jr., President NYSERDA

JAFP-13-0112 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (3 Pages)

JAFP-13-0112 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction JAF developed an Overall Integrated Plan (Reference 1 in Section 8), 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 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 the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013.

None (first 6-month status update complete with submission of this document in August 2013).

3. Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Milestone Target Completion Activity Status Revised Target Date Completion Date 60-day Status Update October 29, 2012 Complete Submit Overall February 28, 2013 Complete Integrated Plan 6-month Status Update August 2013 Complete Refine Strategies September 2013 In Progress December 2014 Perform Staffing December 2013 Not Started Analysis Develop Strategies / January 2014 In Progress May 2015 Contract with RRC 6-month Status Update February 2014 Not Started Develop Mods March 2014 Not Started June 2015 Draft Implementing March 2014 Not Started June 2016 Procedures Regional Response TBD In Progress July 2015 Center Operational Develop Storage Plan May 2014 In Progress June 2015 Purchase FLEX June 2014 Not Started Fall 2016 Equipment Page 1 or 3

JAFP-13-0112 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Milestone Target Completion Activity Status Revised Target Date Completion Date Issue Maintenance August 2014 Not Started Fall 2016 Procedures (for FLEX equipment) 6-month Status Update August 2014 Not Started Develop Training Plan October 2014 Not Started Refueling Outage 1 Fall 2014 Not Started 6-month Status Update February 2015 Not Started Implement Training May 2015 Not Started Implement Mods (non- June 2015 Not Started outage) 6-month Status Update August 2015 Not Started 6-month Status Update February 2016 Not Started Issue Implementing May 2016 Not Started Procedures 6-month Status Update August 2016 Not Started Implement Mods Fall 2016 Not Started (outage)

Implement Training Fall 2016 Not Started Updates Refueling Outage 2 (full Fall 2016 Not Started implementation)

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan

[Reference 1].

The JAF integrated plan indicated compliance with the subject order would include implementation of NRC Order EA-12-050, Issuance of Order to Modify License with Regard to Reliable Containment Hardened Vents. Subsequent to the submittal of the integrated plan, the NRC rescinded Order EA-12-050 and issued Order EA-13-109 Issue of Order to Modify Licenses With Regard to Reliable Containment Vents Capable of Operation Under Severe Accident Conditions. JAF will implement requirements of Phase 1 of Order EA-13-109 instead of Order EA-12-050. Phase 1 of Order EA-13-109 currently requires implementation in 2016 at JAF and thus no change in schedule for compliance is currently contemplated.

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JAFP-13-0112 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF expects to comply with the order implementation date and no relief/relaxation is required at this time.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation 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 Status OI-1: Beyond-design-basis external event impact on Not Started requirements in existing licensing documents will be determined based on input from the industry groups and direction from the NRC.

OI-2: The structure, content and details of the Regional In Progress Response Center playbook will be determined.

Draft Safety Evaluation Open Item Status N/A N/A

7. Potential Draft Safety Evaluation Impacts The NRC has not yet issued draft safety evaluations for JAF; therefore, there are no potential impacts to the Draft Safety Evaluation identified at this time.

8. References The following references support the updates to the Overall Integrated Plan described in this attachment.

1. Entergy letter, 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), JAFP-13-0025, dated February 28, 2013.

2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.

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