JAFP-15-0104, Fifth 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)

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Fifth 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)
ML15240A370
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 08/28/2015
From: Brian Sullivan
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, JAFP-15-0104
Download: ML15240A370 (15)


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-15-0104 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Fifth 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 directed JAF to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

JAFP-15-0104 Page 2 of 2 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 endorsed 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 fifth 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, Regulatory Assurance Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 281h day of August, 2015.

Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) Fifth 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. Douglas Pickett, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. John B. Rhodes, President NYSERDA

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 (12 Pages)

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 last status report (Reference 7), 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 January 31, 2015, and are current as of July 31, 2015.

Fourth Six-Month Status Report - February 2015 (JAFP-15-0026)

3. Milestone Schedule Status Following is 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.

Target Completion Revised Target Milestone Activity Status Date* Completion Date 60-day Status Update October 29, 2012 Complete Submit Overall Integrated February 28, 2013 Complete Plan Six-Month Status Report August 2013 Complete Refine Strategies December 2014 Complete Perform Staffing Analysis June 2015 In progress May 2016 Develop Strategies / May 2015 Started October 30, 2015 Contract with RRC Six-Month Status Report February 2014 Complete Develop Mods June 2015 Started December 23, 2015 Draft Implementing June 2016 Not Started Procedures Regional Response Center July 2015 Complete Operational Develop Storage Plan June 2015 Started December 23, 2015 Purchase FLEX Equipment Fall 2016 Not Started Issue Maintenance Fall 2016 Not Started Procedures (for FLEX equipment)

Six-Month Status Report August 2014 Complete Develop Training Plan November 2015 Not Started April 2016 Page 1 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Target Completion Revised Target Milestone Activity Status Date* Completion Date Refueling Outage 1 Fall 2014 Complete Six-Month Status Report February 2015 Complete Implement Training March 2016 Not Started Fall 2016 Implement Mods (non- June 2015 Not Started May 31, 2016 outage)

Six-Month Status Report August 2015 Complete Six-Month Status Report February 2016 Not Started Issue Implementing May 2016 Not Started Procedures Six-Month Status Report August 2016 Not Started Implement Mods (outage) Fall 2016 Not Started Implement Training Fall 2016 Not Started Updates Refueling Outage 2 (full Fall 2016 Not Started implementation)

Validation / Demonstration Fall 2016 Not Started

  • Target Completion Date is the last submitted date from either the overall integrated plan or a previous six-month status report.
4. Changes to Compliance Method During the design phase of the JAF FLEX project, changes were identified to the compliance strategy as documented in the Overall Integrated Plan (OIP) and updates (References 1, 3, 5, 6, and 7). The changes since the last update are summarized below. These changes will be incorporated in the Final Integrated Plan (FIP).

Page 15 of the OIP identifies containment essential instrumentation. As discussed in the response to AQ 6, torus pressure, drywell pressure, and drywell water level are not required to be on that list.

Page 33 of the OIP states that the FLEX pump will provide 200 gpm makeup water to the SFP via the existing B.5.b spray nozzles. The JAF design minimum pumping capacity is 250 gpm to the SFP, which addresses overspray and guarantees 200 gpm delivered to the SFP.

Page 39 of the OIP states that portable fans will be used to provide ventilation in the Main Control Room (MCR) and the DC Equipment Rooms during Phase 2. Calculations JAF-CALC-MISC-04509 and JAF-CALC-14-00027 determined that ventilation is not required for the MCR, Battery Rooms and DC Equipment Rooms, therefore no portable fans will be provided for Phase 2.

Page 45 of the OIP identifies the BWR Portable Equipment requirements for Phase 2.

The revised JAF strategy no longer requires four portable diesel driven fire pumps Page 2 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 because the existing installed diesel driven fire pumps will be credited for Phase 2. The page also identifies the requirement for three portable ventilation fans for Phase 2. No ventilation fans will be credited in the Phase 2 strategy.

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 Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE) (Reference 4). A fourth table includes the status of each FitzPatrick Audit Question for the Mitigation Strategies (FLEX) Order.

Overall Integrated Plan Open Items Status OI-1: Beyond-design-basis external event impact on requirements in Complete/Closed existing licensing documents will be determined based on Entergy has input from the industry groups and direction from the NRC. determined that update to existing licensing basis documents are not required to reflect BDBEEs.

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

Interim Staff Evaluation Open Items Status 3.1.1.3.A Procedural Interface (Seismic Hazard) - Evaluate the This item is addressed impacts from large internal flooding sources. (Audit by updated AQ JAF-Question 5) 005 response.

3.1.3.1.A Protection of FLEX Equipment (High Wind Hazard) - In Progress.

Evaluate the separation distance and the axis of This item will be separation considering the predominant path of tornados addressed by update to in the geographic area to demonstrate that at least N sets AQ JAF-001 response of FLEX equipment would remain deployable in the when information is context of a tornado missile hazard. (Audit Question 1) available.

3.1.4.2.B Deployment of FLEX Equipment (Snow, Ice and Extreme Complete.

Cold) - Evaluate the potential impact on the UHS due to This item is addressed ice blockage or formation of frazil ice as a result of on the updated AQ extreme cold. response spreadsheet on the ePortal.

Page 3 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Interim Staff Evaluation Open Items Status 3.2.3.A Containment- Verify that the implementation of Boiling In Progress.

Water Reactor Owners Group (BWROG) Emergency This item is addressed Procedure Guideline (EPG)/Severe Accident Guideline by updated AQ JAF-(SAG), Revision 3, including any associated plant-specific 017 response.

evaluations, has been completed in accordance with the provisions of NRC letter dated January 9, 2014 (Reference 23 of ISE - Letter from Jack R. Davis (NRC) to Joseph E.

Pollock (NEI) dated January 9, 2014, regarding Boiling Water Reactor Containment Venting (ADAMS Accession No. ML13358A206))

Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Deployment of FLEX Equipment- Confirm that soil In Progress.

liquefaction will not impede vehicle movement following a This item will be seismic event. addressed by update to AQ JAF-002 response when information is available.

3.1.1.2.B Deployment of FLEX Equipment- Confirm final design In Progress.

features of the new storage building including the This item will be susceptibility to the loss of ac power to deploy equipment. addressed by update to AQ JAF-001 response when information is available.

3.1.1.2.C Deployment of FLEX Equipment - Confirm the storage In Progress.

locations and means of protection against the seismic This item will be hazard of the super duty pickup trucks and the two flatbed addressed by update trailers used for deployment of FLEX equipment. to AQ JAF-001 response when information is available.

3.1.1.4.A Offsite Resources- Confirm location of offsite staging In Progress.

area(s), access routes and methods of delivery of This item will be equipment to the site considering the seismic, flood, high addressed by update wind, snow, ice and extreme cold hazards. to AQ JAF-043 response when information is available.

Page 4 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Interim Staff Evaluation Confirmatory Items Status 3.1.3.2.A Deployment of FLEX Equipment (High Wind Hazard) - Complete Confirm availability of debris removal equipment to This item is addressed facilitate deployment of FLEX equipment. on the AQ response spreadsheet on the ePortal.

3.1.3.2.B Deployment of FLEX Equipment (High Wind Hazard) - In Progress.

Confirm protection of the means to move FLEX This item will be equipment. addressed by update to AQ JAF-001 response when information is available.

3.1.4.2.A Deployment of FLEX Equipment (Snow, Ice and Extreme In Progress.

Cold) - Confirm availability of snow removal equipment to This item will be facilitate deployment of FLEX equipment. addressed by update to AQ JAF-001 response when information is available.

3.2.1.1.A Computer Code Used for Extended Loss of AC Power Complete.

(ELAP) Analysis - Benchmarks need to be identified and This item is addressed discussed which demonstrate that Modular Accident by updated AQ JAF-Analysis Program (MAAP) is an appropriate code for the 009 response.

simulation of an ELAP event at JAF.

3.2.1.1.B Computer Code Used for ELAP Analysis -Confirm that the Complete.

collapsed level remains above Top of Active Fuel (TAF) This item is addressed and the cool down rate is within technical specifications by updated AQ JAF-limits. 012 response.

3.2.1.1.C Computer Code Used for ELAP Analysis - Confirm that Complete.

MAAP was used in accordance with Sections 4.1, 4.2, 4.3, This item is addressed 4.4, and 4.5 of the June 2013 position paper (ADAMS by updated AQ JAF-Accession No. ML13190A201). 010 response.

3.2.1.1.D Computer Code Used for ELAP Analysis - Confirm that Complete.

the licensee, in using MAAP, identified and justified the This item is addressed subset of key modeling parameters cited from Tables 4-1 by updated AQ JAF-through 4-6 of the "MAAP Application Guidance, Desktop 011 response.

Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1 020236).

Page 5 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.1.1.E Computer Code Used for ELAP Analysis - Confirm that Complete.

the specific MAAP analysis case that was used to validate This item is addressed the timing of mitigating strategies in the Integrated Plan by updated AQ JAF-has been identified and is available for NRC staff to 009 response.

review. Alternately, a comparable level of information has been included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within technical specifications limits.

3.2.1.2.A Recirculation Pump Seal Leakage Models - Confirm the Complete.

seal leakage model used in the updated MAAP analysis This item is addressed (which will address the MAAP code limitations when used by updated AQ JAF-for ELAP analysis). Evaluate the seal leakage rate model 014 response.

used, the details of the seal qualification tests and supporting test data, and leakage rate pressure-dependence.

3.2.1.3.A Sequence of Events (SOE) - Confirm the SOE timeline Complete.

after reanalysis using the MAAP code which will address This item is addressed the limitations when used for the ELAP analysis. by updated AQ JAF-012 response.

3.2.1.4.A Systems and Components for Consequence Mitigation - In Progress.

Confirm sizing of the FLEX pumps and 600 Vac FLEX This item will be diesel generator (DG) and the 4160 Vac generator to be addressed by update obtained from the RRC. to AQ JAF-022 response when information is available.

3.2.1.5.A Monitoring Instrumentation and Controls- Confirm ac Complete.

powered torus temperature, pressure and level and This item is addressed drywell temperature and pressure instrumentation is by updated AQ JAF-modified to remain powered during an ELAP. 006 response.

3.2.1.8.A Use of Portable Pumps - Confirm that the use of raw Complete.

water from Lake Ontario for long term core and spent fuel This item is addressed pool cooling strategies is acceptable. by updated AQ JAF-023 response.

3.2.2.A Spent Fuel Pool Cooling - Confirm the method of Complete.

ventilation and power requirements, if any, of the spent This item is addressed fuel pool area. by updated AQ JAF-028 response.

Page 6 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.4.2.A Ventilation (Equipment Cooling) - Confirm that additional Complete.

evaluations of the RCIC room temperature demonstrate This item is addressed that an acceptable environment is maintained during the by updated AQ JAF-transition phase both for equipment in the room and 031 response.

habitability for operators who may need to enter the room.

3.2.4.2.B Ventilation (Equipment Cooling) - Confirm that evaluations Complete.

of the battery room temperature demonstrate that an This item is addressed acceptable environment, during both high ambient by updated AQ JAF-temperature and during extreme cold ambient 069 response.

temperature, is maintained during Phases 2 and 3.

3.2.4.2.C Ventilation (Equipment Cooling) - Confirm the required Complete.

ventilation flow or the size of the portable fans to maintain This item is addressed acceptable environmental conditions in the DC equipment by updated AQ JAF-room. 061 response.

3.2.4.3.A Heat Tracing - Confirm completion of walkdowns and In Progress.

evaluation of where heat tracing may be needed for freeze This item will be protection of equipment or instruments used in the ELAP addressed by update mitigation strategies. to AQ JAF-035 response when information is available.

3.2.4.4.A Lighting - Confirm need for additional portable lighting, In Progress.

such as dc powered lights. This item will be addressed by update to AQ JAF-036 response when information is available.

3.2.4.4.B Communications - Confirm that upgrades to the site's NRC Confirmatory communication system have been completed. Action 3.2.4.8.A Electrical Power Sources - Confirm the technical basis for In Progress.

the selection and size of the FLEX generators to be used This item will be in support of the coping strategies. addressed by update to AQ JAF-050 response when information is available.

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JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.4.10.A Load Reduction to Conserve DC Power - Confirm final In Progress.

load shed list and the evaluation of any potential adverse This item will be effects of shedding those loads. addressed by update to AQ JAF-052 response when information is available.

3.2.4.10.B Load Reduction to Conserve DC Power - Confirm the final In Progress.

dc load profile with the required loads and the finalized This item will be minimum battery voltage. addressed by update to AQ JAF-066 response when information is available.

3.2.4.10.C Load Reduction to Conserve DC Power- Confirm time In Progress.

after the ELAP for connecting the FLEX DG to the battery This item will be chargers. addressed by update to AQ JAF-052 response when information is available.

3.4.A Off-site Resources- Confirm that NEI 12-06, Section 12.2 In Progress.

guidelines 2 through 10 are addressed, or that an This item will be appropriate alternative is justified. addressed by update to AQ JAF-043 response when information is available.

Page 8 of 12

JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Audit Completion or Status Questions Target Date In progress - This AQ response will be updated when information JAF-001 is available (associated with ISE Open Item 3.1.3.1.A and ISE February 2016 Confirmatory Items 3.1.1.2.B, 3.1.1.2.C, 3.1.3.2.B, 3.1.4.2.A)

In progress - This AQ response will be updated when information February 2016 JAF-002 is available (associated with ISE Confirmatory Item 3.1.1.2.A)

In progress - This AQ response will be updated when information February 2016 JAF-003 is available In progress - This AQ response will be updated when information February 2016 JAF-004 is available Updated response available on the ePortal (associated with ISE Complete JAF-005 Open Item 3.1.1.3.A) (with update)

Closed* Response available on the ePortal (associated with ISE Closed JAF-006 Confirmatory Item 3.2.1.5.A)

In progress - This AQ response will be updated when information February 2016 JAF-008 is available Updated response available on the ePortal (associated with ISE Complete JAF-009 Confirmatory Items 3.2.1.1.A, 3.2.1.1.E) (with update)

Updated response available on the ePortal (associated with ISE Complete JAF-010 Confirmatory Item 3.2.1.1.C) (with update)

Updated response available on the ePortal (associated with ISE Complete JAF-011 Confirmatory Item 3.2.1.1.D) (with update)

Updated response available on the ePortal (associated with ISE Complete JAF-012 Confirmatory Items 3.2.1.1.B, 3.2.1.3.A) (with update)

Updated response available on the ePortal Complete JAF-013 (with update)

Updated response available on the ePortal (associated with ISE Complete JAF-014 Confirmatory Item 3.2.1.2.A) (with update)

Updated response available on the ePortal Complete JAF-015 (with update)

JAF-016 Closed* Response available on the ePortal Closed In progress. Updated response available on the ePortal JAF-017 February 2016 (associated with ISE Open Item 3.2.3.A)

Updated response available on the ePortal Complete JAF-018 (with update)

Updated response available on the ePortal Complete JAF-019 (with update)

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JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Audit Completion or Status Questions Target Date JAF-021 Closed* response available on the ePortal Closed Updated response available on the ePortal (associated with ISE Complete JAF-022 Confirmatory Item 3.2.1.4.A) (with update)

Updated response available on the ePortal (associated with ISE Complete JAF-023 Confirmatory Item 3.2.1.8.A) (with update)

JAF-026 Closed* Response available on the ePortal Closed Updated response available on the ePortal Complete JAF-027 (with update)

Closed* Response available on the ePortal (associated with ISE Closed JAF-028 Confirmatory Item 3.2.2.A)

JAF-029 Closed* Response available on the ePortal Closed Updated response available on the ePortal (associated with ISE Complete JAF-031 Confirmatory Item 3.2.4.2.A) (with update)

JAF-032 Closed* Response available on the ePortal Closed Updated response available on the ePortal Complete JAF-033 (with update)

JAF-034 Closed* Response available on the ePortal Closed In progress - This AQ response will be updated when information February 2016 JAF-035 is available (associated with ISE Confirmatory Item 3.2.4.3.A)

In progress - This AQ response will be updated when information February 2016 JAF-036 is available (associated with ISE Confirmatory Item 3.2.4.4.A)

JAF-037 Closed* Response available on the ePortal Closed JAF-038 Closed* Response available on the ePortal Closed Updated response available on the ePortal Complete JAF-040 (with update)

In progress - This AQ response will be updated when information February 2016 JAF-043 is available (associated with ISE Confirmatory Items 3.1.1.4.A, 3.4.A)

JAF-046 Closed* Response available on the ePortal Closed JAF-049 Closed* Response available on the ePortal Closed In progress - This AQ response will be updated when information JAF-050 February 2016 is available (associated with ISE Confirmatory Item 3.2.4.8.A)

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JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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 Audit Completion or Status Questions Target Date In progress - This AQ response will be updated when information JAF-052 is available (associated with ISE Confirmatory Items 3.2.4.10.A, February 2016 3.2.4.10.C)

JAF-053 Closed* Response available on the ePortal Closed Updated response available on the ePortal Complete JAF-055 (with update)

In progress - This AQ response will be updated when information February 2016 JAF-056 is available Updated response available on the ePortal Complete JAF-057 (with update)

In progress - This AQ response will be updated when information Complete JAF-058 is available (with update)

Updated response available on the ePortal Complete JAF-059 (with update)

In progress - This AQ response will be updated when information February 2016 JAF-060 is available Updated response available on the ePortal (associated with ISE Complete JAF-061 Confirmatory Item 3.2.4.2.C) (with update)

In progress - This AQ response will be updated when information February 2016 JAF-062 is available JAF-063 Closed* Response available on the ePortal Closed In progress - This AQ response will be updated when information February 2016 JAF-064 is available In progress - This AQ response will be updated when information February 2016 JAF-065 is available In progress - This AQ response will be updated when information February 2016 JAF-066 is available (associated with ISE Confirmatory Item 3.2.4.10.B)

JAF-068 Closed* Response available on the ePortal Closed Updated response available on the ePortal (associated with ISE Complete JAF-069 (with update)

Confirmatory Item 3.2.4.2.B)

JAF-071 Closed* Response available on the ePortal Closed JAF-072 Closed* Response available on the ePortal Closed JAF-073 Closed* Response available on the ePortal Closed

  • Closed indicates that Entergys response is complete.

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JAFP-15-0104 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fifth 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

7. Potential Interim Staff Evaluation Impacts In addition to the changes to compliance methods identified in Section 4 the items discussed below have potential impact on the Interim Staff Evaluation since the last 6-month update.

ISE/TER Section 3.2.4.2, Pages 41 and 42, the Technical Evaluation Report (TER) states that portable fans will be used to provide ventilation in the MCR and the DC equipment rooms during Phase 2. Calculations JAF-CALC-MISC-04509 and JAF-CALC-14-00027 determined that ventilation is not required, therefore no portable fans will be provided for Phase 2.

8. References The following references support the updates to the Overall Integrated Plan described in this attachment.
1. 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.
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.
3. Entergy to NRC, 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), dated August 28, 2013.
4. NRC letter, James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF1077), dated February 21, 2014
5. Entergy to NRC, JAFP-14-0023, Second 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 049), dated February 28, 2014
6. Entergy to NRC, JAFP-14-0105, Third 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 049), dated August 28, 2014
7. Entergy to NRC, JAFP-15-0026, Fourth 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 049), dated February 27, 2015
8. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 Page 12 of 12