NL-13-110, First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML13247A032
Person / Time
Site:	Indian Point
Issue date:	08/27/2013
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-110, TAC MF0744, TAC MF0745, EA-12-049
Download: ML13247A032 (6)

Text

Entergv Nuclear Northeast Indian Point Energy Center OEntergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 John A Veritosa Site Vice President Administration NL-13-110 August 27, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Indian Point Energy Center's First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745)

Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

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 letter to NRC (NL-12-144), 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 049), dated October 29, 2012

5. Entergy letter to NRC (NL-13-042), 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 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 Entergy. Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event

NL-13-110 Dockets 50-247 and 50-286 Page 2 of 2 of a beyond-design-basis external event. Specific requirements are outlined in 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. 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 Entergy initial status report regarding mitigation strategies.

Reference 5 provided the Entergy 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. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 7__, 2013.

Sincerely,

Attachment:

Indian Point Energy Center's First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Mr. Robert J. Fretz Jr., NRC NRR OE OB Mr. Robert L. Dennig, NRC NRR DSS SCVB Ms. Jessica A. Kratchman NRC NSIR DPR DDEP IRIB Mr. Eric E. Bowman, NRC NRR DPR PGCB Ms. Eileen M. Mckenna, NRC NRO DSRA BPTS NRC NRR DSS SCVB

ATTACHMENT TO NL-1 3-110 INDIAN POINT ENERGY CENTER'S FIRST SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-049 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

NL-13-110 Dockets 50-247 and 50-286 Attachment Page 1 of 3 Indian Point Energy Center's 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 Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Indian Point Energy Center (IPEC), 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.

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 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.

• Purchase Equipment This milestone was combined with the Procure Equipment milestone as the two were considered to be the same activity.

• Validation:

Walk-throughs or Demonstration(s): A target completion date has been added to the milestone listing for completion of the walk-throughs. The walk-throughs will be completed during the Indian Point 2 FLEX modification implementation outage. This new milestone target date does not impact the Order implementation date.

The revised milestone target completion dates do not impact the order implementation date.

Milestone Target Activity Revised Completio Status Target n Date Completion Date Submit Overall Integrated Feb 2013 Complete

NL-13-110 Dockets 50-247 and 50-286 Attachment Page 2 of 3 Implementation Plan Submit 6 Month Updates Update 1 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Perform Staffing Analysis Dec 2013 Started Modifications Engineering and Implementation N-1 Walkdown (Unit2) Spring 2014 Not Started Design Engineering Dec 2014 Started Unit 2 Implementation Outage Apr 2016 Not Started Unit 3 Implementation Outage Apr 2015 Not Started On-site FLEX Equipment Purchase / Procure Dec 2014 Started Revised Off-site FLEX Equipment Develop Strategies with RRC Nov 2013 Started Procedures PWROG issues NSSS-specific Jan 2014 Started Revised guidelines Create Indian Point FSG Oct 2014 Started Create Maintenance Procedures Oct 2014 Not Started Training:

Develop Training Plan May 2015 Not Started Implement Training Nov 2015 Not Started Validation / Demonstration May 2016 Not Started Revised Submit Completion Report Jun 2016 Not Started Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

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

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 and the status of each item.

Overall Integrated Plan Open Item Status No open items.

NL-13-110 Dockets 50-247 and 50-286 Attachment Page 3 of 3 Draft Safety Evaluation Open Item Status No open items.

Potential Draft Safety Evaluation Impacts The Draft Safety Evaluation has not been issued at this time.

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

1. Entergy letter to NRC (NL-13-042), 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

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.