JAFP-16-0027, Sixth 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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Sixth 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)
ML16057A603
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 02/26/2016
From: Brian Sullivan
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, JAFP-16-0027
Download: ML16057A603 (14)
v • d • e


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-16-0027 February 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Sixth 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
6. Entergy to NRC, JAFP-15-0133, Notification of Permanent Cessation of Power Operations, dated November 18, 2015

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

JAFP-16-0027 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 endorsed industry guidance document NEI 12-06, Revision O

[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 6 notified the NRC that Entergy had decided to permanently cease power operations of JAF in late 2016 or early 2017. This status report reflects that decision. Entergy is evaluating its responses to Reference 1 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations. The immediate impact to the six-month update report is to suspend all scheduled actions to allow the evaluation of what specific activities related to FLEX will be required. This is reflected in the milestone schedule by revising dates by inserting "to be determined" (TBD).

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 sixth 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.

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 261h day of February, 2016.

Sincerely, Brian R. Sul 1van Site Vice President BRS/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) Sixth 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 Region I Administrator NRC Resident Inspector NRC Senior Project Manager, Mr. Douglas Pickett NYSPSC, Ms. Bridget Frymire NYSERDA President, Mr. John B. Rhodes

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 (11 Pages)

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 James A. FitzPatrick Nuclear Power Plant (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 10), 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 August 1, 2015, and are current as of January 31, 2016.

Fifth Six-Month Status Report - August 2015 (JAFP-15-0104)

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 May 2016 In progress TBD**

Develop Strategies / October 30, 2015 Started TBD**

Contract with RRC Six-Month Status Report February 2014 Complete Develop Mods December 23, 2015 Started TBD**

Draft Implementing June 2016 Not Started TBD**

Procedures Regional Response Center July 2015 Complete Operational Develop Storage Plan December 23, 2015 Started TBD**

Purchase FLEX Equipment Fall 2016 Not Started TBD**

Issue Maintenance Fall 2016 Not Started TBD**

Procedures (for FLEX equipment)

Six-Month Status Report August 2014 Complete Develop Training Plan April 2016 Not Started TBD**

Page 1 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Fall 2016 Not Started TBD**

Implement Mods (non- May 31, 2016 Not Started TBD**

outage)

Six-Month Status Report August 2015 Complete Six-Month Status Report February 2016 In progress Issue Implementing May 2016 Not Started TBD**

Procedures Six-Month Status Report August 2016 Not Started Implement Mods (outage) Fall 2016 Not Started TBD**

Implement Training Fall 2016 Not Started TBD**

Updates Refueling Outage 2 (full Fall 2016 Not Started TBD**

implementation)

Validation / Demonstration Fall 2016 Not Started TBD**

  • Target Completion Date is the last submitted date from either the overall integrated plan or a previous six-month status report.
    • These milestones are being reassessed and revised target completion dates will be determined and included in a future six-month update (see Section 4).
4. Changes to Compliance Method On November 18, 2015, Entergy notified the NRC that it had decided to permanently cease power operations of JAF in late 2016 or early 2017. Entergy is evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations.
5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF will submit a plan that resolves any issues relative to order implementation up to the rescinding of the order by the NRC based on JAF 10 CFR 50.82 defueled certification letter.

This plan may include a relief/relaxation request.

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation Note: The following tables are included for completeness. The 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 (AQ) for the Mitigation Strategies (FLEX) Order.

Page 2 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 1: Overall Integrated Plan Open Items 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.

Table 2: Interim Staff Evaluation Open Items Interim Staff Evaluation Open Items Status 3.1.1.3.A Procedural Interface (Seismic Hazard) - Evaluate the Complete impacts from large internal flooding sources. (Associated with AQ JAF-005 response).

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

Evaluate the separation distance and the axis of (Associated with AQ separation considering the predominant path of tornados JAF-001) in the geographic area to demonstrate that at least N sets of FLEX equipment would remain deployable in the context of a tornado missile hazard.

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.

3.2.3.A Containment- Verify that the implementation of Boiling Open.

Water Reactor Owners Group (BWROG) Emergency (Associated with AQ Procedure Guideline (EPG)/Severe Accident Guideline JAF-017)

(SAG), Revision 3, including any associated plant-specific 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))

Page 3 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Deployment of FLEX Equipment- Confirm that soil Open.

liquefaction will not impede vehicle movement following a (Associated with AQ seismic event. JAF-002) 3.1.1.2.B Deployment of FLEX Equipment- Confirm final design Open.

features of the new storage building including the (Associated with AQ susceptibility to the loss of ac power to deploy JAF-001) equipment.

3.1.1.2.C Deployment of FLEX Equipment - Confirm the storage Open.

locations and means of protection against the seismic (Associated with AQ hazard of the super duty pickup trucks and the two JAF-001) flatbed trailers used for deployment of FLEX equipment.

3.1.1.4.A Offsite Resources- Confirm location of offsite staging Open.

area(s), access routes and methods of delivery of (Associated with AQ equipment to the site considering the seismic, flood, high JAF-043) wind, snow, ice and extreme cold hazards.

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) - Open.

Confirm protection of the means to move FLEX (Associated with AQ equipment. JAF-001) 3.1.4.2.A Deployment of FLEX Equipment (Snow, Ice and Extreme Open.

Cold) - Confirm availability of snow removal equipment to (Associated with AQ facilitate deployment of FLEX equipment. JAF-001) 3.2.1.1.A Computer Code Used for Extended Loss of AC Power Complete.

(ELAP) Analysis - Benchmarks need to be identified and (Associated with AQ discussed which demonstrate that Modular Accident JAF-009 response)

Analysis Program (MAAP) is an appropriate code for the simulation of an ELAP event at JAF.

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

the collapsed level remains above Top of Active Fuel (Associated with AQ (TAF) and the cool down rate is within technical JAF-012 response) specifications limits.

Page 4 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 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, (Associated with AQ 4.3, 4.4, and 4.5 of the June 2013 position paper JAF-010 response)

(ADAMS Accession No. ML13190A201).

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

the licensee, in using MAAP, identified and justified the (Associated with AQ subset of key modeling parameters cited from Tables 4-1 JAF-011 response) through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1 020236).

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

the specific MAAP analysis case that was used to (Associated with AQ validate the timing of mitigating strategies in the JAF-009 response)

Integrated Plan has been identified and is available for NRC staff to 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 (Associated with AQ (which will address the MAAP code limitations when JAF-014 response) used for ELAP analysis). Evaluate the seal leakage rate model 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 (Associated with AQ the limitations when used for the ELAP analysis. JAF-012 response) 3.2.1.4.A Systems and Components for Consequence Mitigation - Open.

Confirm sizing of the FLEX pumps and 600 Vac FLEX (Associated with AQ diesel generator (DG) and the 4160 Vac generator to be JAF-022) obtained from the RRC.

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

powered torus temperature, pressure and level and (Associated with AQ drywell temperature and pressure instrumentation is JAF-006 response) modified to remain powered during an ELAP.

Page 5 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 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 (Associated with AQ pool cooling strategies is acceptable. 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 (Associated with AQ fuel pool area. JAF-028 response) 3.2.4.2.A Ventilation (Equipment Cooling) - Confirm that additional Complete.

evaluations of the RCIC room temperature demonstrate (Associated with AQ that an acceptable environment is maintained during the JAF-031 response) transition phase both for equipment in the room and habitability for operators who may need to enter the room.

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

evaluations of the battery room temperature demonstrate (Associated with AQ that an acceptable environment, during both high JAF-069 response) ambient temperature and during extreme cold ambient 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 (Associated with AQ maintain acceptable environmental conditions in the DC JAF-061 response) equipment room.

3.2.4.3.A Heat Tracing - Confirm completion of walkdowns and Open.

evaluation of where heat tracing may be needed for (Associated with AQ freeze protection of equipment or instruments used in the JAF-035)

ELAP mitigation strategies.

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

such as dc powered lights. (Associated with AQ JAF-036) 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 Open.

for the selection and size of the FLEX generators to be (Associated with AQ used in support of the coping strategies. JAF-050) 3.2.4.10.A Load Reduction to Conserve DC Power - Confirm final Open.

load shed list and the evaluation of any potential adverse (Associated with AQ effects of shedding those loads. JAF-052)

Page 6 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 3.2.4.10.B Load Reduction to Conserve DC Power - Confirm the Open.

final dc load profile with the required loads and the (Associated with AQ finalized minimum battery voltage. JAF-066) 3.2.4.10.C Load Reduction to Conserve DC Power- Confirm time Open.

after the ELAP for connecting the FLEX DG to the battery (Associated with AQ chargers. JAF-052) 3.4.A Off-site Resources- Confirm that NEI 12-06, Section 12.2 Open.

guidelines 2 through 10 are addressed, or that an (Associated with AQ appropriate alternative is justified. JAF-043)

Page 7 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date Open - This AQ response will be updated when information is JAF-001 available (associated with ISE Open Item 3.1.3.1.A and ISE TBD**

Confirmatory Items 3.1.1.2.B, 3.1.1.2.C, 3.1.3.2.B, 3.1.4.2.A)

Open - This AQ response will be updated when information is TBD**

JAF-002 available (associated with ISE Confirmatory Item 3.1.1.2.A)

JAF-003 Open TBD**

JAF-004 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-005 Open Item 3.1.1.3.A)

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

JAF-008 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-009 Confirmatory Items 3.2.1.1.A, 3.2.1.1.E)

Closed* Response available on the ePortal (associated with ISE Closed JAF-010 Confirmatory Item 3.2.1.1.C)

Closed* Response available on the ePortal (associated with ISE Closed JAF-011 Confirmatory Item 3.2.1.1.D)

Closed* Response available on the ePortal (associated with ISE Closed JAF-012 Confirmatory Items 3.2.1.1.B, 3.2.1.3.A)

JAF-013 Closed* Response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-014 Confirmatory Item 3.2.1.2.A)

JAF-015 Closed* Response available on the ePortal Closed JAF-016 Closed* Response available on the ePortal Closed JAF-017 Open (associated with ISE Open Item 3.2.3.A) TBD**

JAF-018 Closed* Response available on the ePortal Closed JAF-019 Closed* Response available on the ePortal Closed JAF-021 Closed* response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-022 Confirmatory Item 3.2.1.4.A)

Closed* Response available on the ePortal (associated with ISE Closed JAF-023 Confirmatory Item 3.2.1.8.A)

Page 8 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date JAF-026 Closed* Response available on the ePortal Closed JAF-027 Closed* Response available on the ePortal Closed 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 Closed* Response available on the ePortal (associated with ISE Closed JAF-031 Confirmatory Item 3.2.4.2.A)

JAF-032 Closed* Response available on the ePortal Closed JAF-033 Closed* Response available on the ePortal Closed JAF-034 Closed* Response available on the ePortal Closed JAF-035 Open (associated with ISE Confirmatory Item 3.2.4.3.A) TBD**

JAF-036 Open (associated with ISE Confirmatory Item 3.2.4.4.A) TBD**

JAF-037 Closed* Response available on the ePortal Closed JAF-038 Closed* Response available on the ePortal Closed JAF-040 Closed* Response available on the ePortal Closed JAF-043 Open (associated with ISE Confirmatory Items 3.1.1.4.A, 3.4.A) TBD**

JAF-046 Closed* Response available on the ePortal Closed JAF-049 Closed* Response available on the ePortal Closed JAF-050 Open (associated with ISE Confirmatory Item 3.2.4.8.A) TBD**

Open (associated with ISE Confirmatory Items 3.2.4.10.A, JAF-052 TBD**

3.2.4.10.C)

JAF-053 Closed* Response available on the ePortal Closed JAF-055 Closed* Response available on the ePortal Closed JAF-056 Open TBD**

JAF-057 Closed* Response available on the ePortal Closed JAF-058 Open TBD**

JAF-059 Closed* Response available on the ePortal Closed JAF-060 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-061 Confirmatory Item 3.2.4.2.C)

Page 9 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date JAF-062 Open TBD**

JAF-063 Closed* Response available on the ePortal Closed JAF-064 Open TBD**

JAF-065 Open TBD**

JAF-066 Open (associated with ISE Confirmatory Item 3.2.4.10.B) TBD**

JAF-068 Closed* Response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-069 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.
    • These AQ are being reassessed and revised target completion dates will be determined and included in a future six-month update (see section 4).
7. Potential Interim Staff Evaluation Impacts Entergy is currently evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations (Reference 9). Therefore, Entergy has not yet identified any additional potential impacts to the Interim Staff Evaluation since the previous six month status report (Reference 10).

Page 10 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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

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
9. Entergy to NRC, JAFP-15-0133, Notification of Permanent Cessation of Power Operations, dated November 18, 2015
10. Entergy to NRC, 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 049), dated August 28, 2015 Page 11 of 11

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-16-0027 February 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Sixth 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
6. Entergy to NRC, JAFP-15-0133, Notification of Permanent Cessation of Power Operations, dated November 18, 2015

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

JAFP-16-0027 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 endorsed industry guidance document NEI 12-06, Revision O

[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 6 notified the NRC that Entergy had decided to permanently cease power operations of JAF in late 2016 or early 2017. This status report reflects that decision. Entergy is evaluating its responses to Reference 1 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations. The immediate impact to the six-month update report is to suspend all scheduled actions to allow the evaluation of what specific activities related to FLEX will be required. This is reflected in the milestone schedule by revising dates by inserting "to be determined" (TBD).

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 sixth 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.

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 261h day of February, 2016.

Sincerely, Brian R. Sul 1van Site Vice President BRS/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) Sixth 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 Region I Administrator NRC Resident Inspector NRC Senior Project Manager, Mr. Douglas Pickett NYSPSC, Ms. Bridget Frymire NYSERDA President, Mr. John B. Rhodes

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 (11 Pages)

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 James A. FitzPatrick Nuclear Power Plant (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 10), 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 August 1, 2015, and are current as of January 31, 2016.

Fifth Six-Month Status Report - August 2015 (JAFP-15-0104)

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 May 2016 In progress TBD**

Develop Strategies / October 30, 2015 Started TBD**

Contract with RRC Six-Month Status Report February 2014 Complete Develop Mods December 23, 2015 Started TBD**

Draft Implementing June 2016 Not Started TBD**

Procedures Regional Response Center July 2015 Complete Operational Develop Storage Plan December 23, 2015 Started TBD**

Purchase FLEX Equipment Fall 2016 Not Started TBD**

Issue Maintenance Fall 2016 Not Started TBD**

Procedures (for FLEX equipment)

Six-Month Status Report August 2014 Complete Develop Training Plan April 2016 Not Started TBD**

Page 1 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Fall 2016 Not Started TBD**

Implement Mods (non- May 31, 2016 Not Started TBD**

outage)

Six-Month Status Report August 2015 Complete Six-Month Status Report February 2016 In progress Issue Implementing May 2016 Not Started TBD**

Procedures Six-Month Status Report August 2016 Not Started Implement Mods (outage) Fall 2016 Not Started TBD**

Implement Training Fall 2016 Not Started TBD**

Updates Refueling Outage 2 (full Fall 2016 Not Started TBD**

implementation)

Validation / Demonstration Fall 2016 Not Started TBD**

  • Target Completion Date is the last submitted date from either the overall integrated plan or a previous six-month status report.
    • These milestones are being reassessed and revised target completion dates will be determined and included in a future six-month update (see Section 4).
4. Changes to Compliance Method On November 18, 2015, Entergy notified the NRC that it had decided to permanently cease power operations of JAF in late 2016 or early 2017. Entergy is evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations.
5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF will submit a plan that resolves any issues relative to order implementation up to the rescinding of the order by the NRC based on JAF 10 CFR 50.82 defueled certification letter.

This plan may include a relief/relaxation request.

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation Note: The following tables are included for completeness. The 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 (AQ) for the Mitigation Strategies (FLEX) Order.

Page 2 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 1: Overall Integrated Plan Open Items 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.

Table 2: Interim Staff Evaluation Open Items Interim Staff Evaluation Open Items Status 3.1.1.3.A Procedural Interface (Seismic Hazard) - Evaluate the Complete impacts from large internal flooding sources. (Associated with AQ JAF-005 response).

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

Evaluate the separation distance and the axis of (Associated with AQ separation considering the predominant path of tornados JAF-001) in the geographic area to demonstrate that at least N sets of FLEX equipment would remain deployable in the context of a tornado missile hazard.

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.

3.2.3.A Containment- Verify that the implementation of Boiling Open.

Water Reactor Owners Group (BWROG) Emergency (Associated with AQ Procedure Guideline (EPG)/Severe Accident Guideline JAF-017)

(SAG), Revision 3, including any associated plant-specific 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))

Page 3 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Deployment of FLEX Equipment- Confirm that soil Open.

liquefaction will not impede vehicle movement following a (Associated with AQ seismic event. JAF-002) 3.1.1.2.B Deployment of FLEX Equipment- Confirm final design Open.

features of the new storage building including the (Associated with AQ susceptibility to the loss of ac power to deploy JAF-001) equipment.

3.1.1.2.C Deployment of FLEX Equipment - Confirm the storage Open.

locations and means of protection against the seismic (Associated with AQ hazard of the super duty pickup trucks and the two JAF-001) flatbed trailers used for deployment of FLEX equipment.

3.1.1.4.A Offsite Resources- Confirm location of offsite staging Open.

area(s), access routes and methods of delivery of (Associated with AQ equipment to the site considering the seismic, flood, high JAF-043) wind, snow, ice and extreme cold hazards.

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) - Open.

Confirm protection of the means to move FLEX (Associated with AQ equipment. JAF-001) 3.1.4.2.A Deployment of FLEX Equipment (Snow, Ice and Extreme Open.

Cold) - Confirm availability of snow removal equipment to (Associated with AQ facilitate deployment of FLEX equipment. JAF-001) 3.2.1.1.A Computer Code Used for Extended Loss of AC Power Complete.

(ELAP) Analysis - Benchmarks need to be identified and (Associated with AQ discussed which demonstrate that Modular Accident JAF-009 response)

Analysis Program (MAAP) is an appropriate code for the simulation of an ELAP event at JAF.

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

the collapsed level remains above Top of Active Fuel (Associated with AQ (TAF) and the cool down rate is within technical JAF-012 response) specifications limits.

Page 4 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 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, (Associated with AQ 4.3, 4.4, and 4.5 of the June 2013 position paper JAF-010 response)

(ADAMS Accession No. ML13190A201).

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

the licensee, in using MAAP, identified and justified the (Associated with AQ subset of key modeling parameters cited from Tables 4-1 JAF-011 response) through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1 020236).

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

the specific MAAP analysis case that was used to (Associated with AQ validate the timing of mitigating strategies in the JAF-009 response)

Integrated Plan has been identified and is available for NRC staff to 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 (Associated with AQ (which will address the MAAP code limitations when JAF-014 response) used for ELAP analysis). Evaluate the seal leakage rate model 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 (Associated with AQ the limitations when used for the ELAP analysis. JAF-012 response) 3.2.1.4.A Systems and Components for Consequence Mitigation - Open.

Confirm sizing of the FLEX pumps and 600 Vac FLEX (Associated with AQ diesel generator (DG) and the 4160 Vac generator to be JAF-022) obtained from the RRC.

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

powered torus temperature, pressure and level and (Associated with AQ drywell temperature and pressure instrumentation is JAF-006 response) modified to remain powered during an ELAP.

Page 5 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 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 (Associated with AQ pool cooling strategies is acceptable. 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 (Associated with AQ fuel pool area. JAF-028 response) 3.2.4.2.A Ventilation (Equipment Cooling) - Confirm that additional Complete.

evaluations of the RCIC room temperature demonstrate (Associated with AQ that an acceptable environment is maintained during the JAF-031 response) transition phase both for equipment in the room and habitability for operators who may need to enter the room.

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

evaluations of the battery room temperature demonstrate (Associated with AQ that an acceptable environment, during both high JAF-069 response) ambient temperature and during extreme cold ambient 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 (Associated with AQ maintain acceptable environmental conditions in the DC JAF-061 response) equipment room.

3.2.4.3.A Heat Tracing - Confirm completion of walkdowns and Open.

evaluation of where heat tracing may be needed for (Associated with AQ freeze protection of equipment or instruments used in the JAF-035)

ELAP mitigation strategies.

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

such as dc powered lights. (Associated with AQ JAF-036) 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 Open.

for the selection and size of the FLEX generators to be (Associated with AQ used in support of the coping strategies. JAF-050) 3.2.4.10.A Load Reduction to Conserve DC Power - Confirm final Open.

load shed list and the evaluation of any potential adverse (Associated with AQ effects of shedding those loads. JAF-052)

Page 6 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status 3.2.4.10.B Load Reduction to Conserve DC Power - Confirm the Open.

final dc load profile with the required loads and the (Associated with AQ finalized minimum battery voltage. JAF-066) 3.2.4.10.C Load Reduction to Conserve DC Power- Confirm time Open.

after the ELAP for connecting the FLEX DG to the battery (Associated with AQ chargers. JAF-052) 3.4.A Off-site Resources- Confirm that NEI 12-06, Section 12.2 Open.

guidelines 2 through 10 are addressed, or that an (Associated with AQ appropriate alternative is justified. JAF-043)

Page 7 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date Open - This AQ response will be updated when information is JAF-001 available (associated with ISE Open Item 3.1.3.1.A and ISE TBD**

Confirmatory Items 3.1.1.2.B, 3.1.1.2.C, 3.1.3.2.B, 3.1.4.2.A)

Open - This AQ response will be updated when information is TBD**

JAF-002 available (associated with ISE Confirmatory Item 3.1.1.2.A)

JAF-003 Open TBD**

JAF-004 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-005 Open Item 3.1.1.3.A)

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

JAF-008 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-009 Confirmatory Items 3.2.1.1.A, 3.2.1.1.E)

Closed* Response available on the ePortal (associated with ISE Closed JAF-010 Confirmatory Item 3.2.1.1.C)

Closed* Response available on the ePortal (associated with ISE Closed JAF-011 Confirmatory Item 3.2.1.1.D)

Closed* Response available on the ePortal (associated with ISE Closed JAF-012 Confirmatory Items 3.2.1.1.B, 3.2.1.3.A)

JAF-013 Closed* Response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-014 Confirmatory Item 3.2.1.2.A)

JAF-015 Closed* Response available on the ePortal Closed JAF-016 Closed* Response available on the ePortal Closed JAF-017 Open (associated with ISE Open Item 3.2.3.A) TBD**

JAF-018 Closed* Response available on the ePortal Closed JAF-019 Closed* Response available on the ePortal Closed JAF-021 Closed* response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-022 Confirmatory Item 3.2.1.4.A)

Closed* Response available on the ePortal (associated with ISE Closed JAF-023 Confirmatory Item 3.2.1.8.A)

Page 8 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date JAF-026 Closed* Response available on the ePortal Closed JAF-027 Closed* Response available on the ePortal Closed 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 Closed* Response available on the ePortal (associated with ISE Closed JAF-031 Confirmatory Item 3.2.4.2.A)

JAF-032 Closed* Response available on the ePortal Closed JAF-033 Closed* Response available on the ePortal Closed JAF-034 Closed* Response available on the ePortal Closed JAF-035 Open (associated with ISE Confirmatory Item 3.2.4.3.A) TBD**

JAF-036 Open (associated with ISE Confirmatory Item 3.2.4.4.A) TBD**

JAF-037 Closed* Response available on the ePortal Closed JAF-038 Closed* Response available on the ePortal Closed JAF-040 Closed* Response available on the ePortal Closed JAF-043 Open (associated with ISE Confirmatory Items 3.1.1.4.A, 3.4.A) TBD**

JAF-046 Closed* Response available on the ePortal Closed JAF-049 Closed* Response available on the ePortal Closed JAF-050 Open (associated with ISE Confirmatory Item 3.2.4.8.A) TBD**

Open (associated with ISE Confirmatory Items 3.2.4.10.A, JAF-052 TBD**

3.2.4.10.C)

JAF-053 Closed* Response available on the ePortal Closed JAF-055 Closed* Response available on the ePortal Closed JAF-056 Open TBD**

JAF-057 Closed* Response available on the ePortal Closed JAF-058 Open TBD**

JAF-059 Closed* Response available on the ePortal Closed JAF-060 Open TBD**

Closed* Response available on the ePortal (associated with ISE Closed JAF-061 Confirmatory Item 3.2.4.2.C)

Page 9 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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 Table 4: Audit Question Status Audit Completion or Status Questions Target Date JAF-062 Open TBD**

JAF-063 Closed* Response available on the ePortal Closed JAF-064 Open TBD**

JAF-065 Open TBD**

JAF-066 Open (associated with ISE Confirmatory Item 3.2.4.10.B) TBD**

JAF-068 Closed* Response available on the ePortal Closed Closed* Response available on the ePortal (associated with ISE Closed JAF-069 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.
    • These AQ are being reassessed and revised target completion dates will be determined and included in a future six-month update (see section 4).
7. Potential Interim Staff Evaluation Impacts Entergy is currently evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations (Reference 9). Therefore, Entergy has not yet identified any additional potential impacts to the Interim Staff Evaluation since the previous six month status report (Reference 10).

Page 10 of 11

JAFP-16-0027 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Sixth 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

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
9. Entergy to NRC, JAFP-15-0133, Notification of Permanent Cessation of Power Operations, dated November 18, 2015
10. Entergy to NRC, 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 049), dated August 28, 2015 Page 11 of 11
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