JAFP-17-0017, Eighth 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

Eighth 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

ML17059D564
Person / Time
Site:	FitzPatrick
Issue date:	02/28/2017
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF1076, CAC MF1077, EA-12-049, JAFP-17-0017
Download: ML17059D564 (21)

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-17-0017 February 28, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Eighth 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 (ML12056A045)

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 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ML12242A378)

4. ENOI letter, 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 (ML12305A314)

5. ENOI letter, 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 (ML13063A287)

6. ENOI letter, JAFP-16-0045, Certification of Permanent Cessation of Power Operations, dated March 16, 2016 (ML16076A391).

JAFP-17-0017 Page 2 of 3

7. ENOI letter, JAFP-16-0061, Request for Relaxation of March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated April 14, 2016 (ML16105A379)

8. ENOI letter, JAFP-16-0096, Supporting Information for Request for Relaxation of March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated June 16, 2016 (ML16168A452)

9. ENOI letter, JAFP-16-0147, Request for Extension to Comply with March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated September 8, 2016 (ML16252A477)

10. Exelon and ENOI letter, Application for Order Approving Transfer of Renewed Facility Operating License and Proposed Conforming License Amendment, dated August 18, 2016 (ML16235A081)

11. NRC letter, James A. FitzPatrick Nuclear Power Plant - Acceptance of Requested Licensing Action Re: Application for Order Approving Transfer of Renewed Facility Operating License and Proposed Conforming License Amendment (CAC No. MF8293), dated October 3, 2016 (ML16266A483)

12. NRC letter, James A. FitzPatrick Nuclear Power Plant - Relaxation of the Schedule Requirements for Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies For Beyond-Design-Basis External Events" and Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (CAC Nos. MF1077 and MF1076), dated December 2, 2016 (ML16173A342)

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.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance [Reference 2] and an overall integrated plan pursuant to Section IV, Condition C.2. Reference 2 endorses industry guidance document NEI 12-06, Revision 0

[Reference 3] with clarifications and exceptions identified in Reference 2. Reference 4 provided the JAF initial status report regarding mitigation strategies. Reference 5 provided the JAF overall integrated plan.

Reference 6 notified the NRC that Entergy Nuclear Operations Inc. (ENOI) had decided to permanently cease power operations of JAF in January 2017. Due to the possible option to sell JAF in lieu of permanent cessation of power operation, Entergy submitted a request for extension of Order EA 12-049 and Order EA 12-051 full compliance dates to June 30, 2017

JAFP-17-0017 Page 3 of 3

[References 9]. By letter dated August 18, 2016, [Reference 1OJ ENOI and Exelon Generating Company, LLC (Exelon) jointly submitted an application for an order and conforming license amendment transferring the JAF facility from ENOI to Exelon. Reference 11 provides the acceptance by the NRG staff to complete a detailed technical review of the application of the proposed transfer of renewed operating license of the JAF facility. Reference 12 approved a relaxation to the orders to June 30, 2017.

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 eighth 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 William Drews, Regulatory Assurance Manager, at 315-349-6562.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 28th day of February, 2017.

Sincerely, Brian R. ullivan Site Vice President BRS/WCD/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) Eighth 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 NRG Region I Administrator NRG Resident Inspector NRG Project Manager NYSPSC NYSERDA

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 (17 Pages)

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 12), 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 July 31, 2016, and are current as of January 31, 2017.

Seventh Six-Month Status Report - August 2016 (JAFP-16-0139)

Perform Staffing Analysis - December 2016 Draft Implementing Procedures - December 2016 Develop Training Plan - December 2016 Develop Storage Plan - January 2017

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 Plan February 28, 2013 Complete Six-Month Status Report August 2013 Complete Refine Strategies December 2014 Complete Perform Staffing Analysis TBD** Complete December 2016 Develop Strategies / Contract TBD** In progress June 2017 with RRC Six-Month Status Report February 2014 Complete Develop Mods TBD** Complete February 2017 Draft Implementing Procedures TBD** Complete December 2016 Regional Response Center July 2015 Complete Operational Develop Storage Plan TBD** Complete January 2017 Purchase FLEX Equipment TBD** In progress May 2017 Issue Maintenance Procedures TBD** Not Started June 2017 (for FLEX equipment)

Six-Month Status Report August 2014 Complete Page 1 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Develop Training Plan TBD** Complete December 2016 Refueling Outage 1 Fall 2014 Complete Six-Month Status Report February 2015 Complete Implement Training TBD** Not Started June 2017 Implement Mods (non-outage) TBD** In progress June 2017 Six-Month Status Report August 2015 Complete Six-Month Status Report February 2016 Complete Issue Implementing Procedures TBD** Not Started June 2017 Six-Month Status Report August 2016 Complete Six-Month Status Report February 2017 Complete Implement Mods (outage) TBD** In progress March 2017 Implement Training Updates TBD** Not Started June 2017 Full Implementation TBD** Not Started June 2017 Validation / Demonstration TBD** Not Started April 2017

• 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 Changes have been identified to the compliance strategy as described in the Overall Integrated Plan (Reference 1) and updates (References 3, 5, 6, 7, 10, 11 and 12). These changes will be incorporated in the Final Integrated Plan (FIP).

Reference 7, Section 4, states that the reactor pressure vessel (RPV) will be depressurized from operating pressure to 200 to 400 psig in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Per the revised Modular Accident Analysis Program (MAAP) analysis, this RPV depressurization will take place in 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Reference 7, Section 4, states that the transition from the reactor core isolation cooling (RCIC) pump to the diesel-driven fire pump takes place at around 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The revised strategy determined that the transition from RCIC to the diesel-driven fire pump takes place at approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.

Reference 7, Section 4, states that the primary strategy to provide power to required DC bus loads will use the temporary station battery charger and that a quick connect type receptacle is provided at the temporary battery charger for connection to the 200KW 600VAC FLEX diesel generator (DG). The revised strategy does not power up the temporary station battery charger but uses a modified motor control center (MCC) bucket capable of being plugged into spare cubicles in the associated Division 1 (primary strategy) or Division 2 (alternate strategy) MCC bus. Each modified MCC Page 2 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 bucket is outfitted with quick connects providing the capability for the 200KW 600VAC FLEX DG to directly feed the required FLEX strategy DC loads that includes the permanent station battery chargers. To satisfy the N+1 requirement, two 200KW 600VAC FLEX DG and two modified MCC buckets are provided.

Reference 1, page 15, identifies that a modification is required to change the power feed for certain critical instruments from the AC instrument bus to a station battery-backed source. All critical instruments required to support the JAF FLEX strategy are provided power from station batteries and no modification is required. Additionally, Reference 7 mistakenly indicated that drywell pressure should not be on the list of instruments on this same page when in fact it should have indicated that torus pressure should not be on the list. Torus pressure is not required for the JAF strategy but, drywell pressure is required.

Reference 1, page 6, states that the station battery chargers will be re-powered at 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The revised strategy re-powers the station battery chargers at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Reference 1, page 18, states that the JAF alternate strategy for powering up station battery chargers is to provide connections and permanent cables to allow the battery chargers to be directly powered up by a 90KW 600VAC DG. The JAF strategy does not require use of any 90KW 600VAC diesel generators nor any capabilities to directly power up the station battery chargers.

Reference 1, page 19, states modifications will be made to (1) add connection points and install cabling to selected busses to facilitate connections of the 200KW 600VAC FLEX DG, (2) install new piping to be used to facilitate replenishing the condensate storage tank (CST) with a portable FLEX pump, (3) add connection points, install cables and transfer switches locally at a battery charger to provide for direct connection of 90KW 600VAC DGs and (4) install a new manually operated jib crane to facilitate the deployment of the portable FLEX pump in the Screenhouse. (1) As mentioned above, the JAF strategy requires two modified MCC buckets to facilitate connection of the 200KW 600VAC FLEX DGs and therefore the modification to install connection points and cabling is not required. (2) As noted in Reference 7, the JAF strategy does not use a portable FLEX pump to refill the CST, therefore, the piping modification is not required.

(3) As noted above, the JAF strategy does not require the use of 90KW 600VAC generators, therefore, the modification to install connection points, cabling and transfer switches is not required. (4) As noted in Reference 7, the JAF strategy does not require a portable FLEX pump to refill the CST, therefore, the modification to install a manually operated jib crane is not required to facilitate deployment of the pump.

Reference 1, page 20 Deployment Conceptual Modification states that (1) new FLEX piping will be installed to meet necessary seismic requirements, (2) connection points for the FLEX pump discharge will be outside the Screenhouse and designed to withstand the applicable hazards, and, (3) electrical connection points for the 200KW 600VAC FLEX DGs will be designed to withstand the applicable hazards. The JAF strategy credits the use of permanently installed diesel-driven fire pumps for meeting the needs of reactor core cooling and spent fuel pool makeup. Both diesel-driven fire pumps have been evaluated and determined to be qualified for all applicable external events including their attached piping. FLEX piping adapters and hoses are utilized to complete the flow path connections from the discharge of the diesel-driven fire pumps to the residual heat removal water system. As such no permanent piping or permanent piping Page 3 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 connection point modifications are required for the JAF FLEX strategy. All FLEX piping connections are made within the fully qualified and protected portions of the Screenhouse. FLEX piping adapters and hoses are stored within the Screenhouse which has been determined to be qualified for all applicable external events. As previously discussed above, no new modifications are required to facilitate electrical connection of the 200KW 600VAC FLEX DGs.

Reference 1, page 21 states that the primary Phase 3 strategy to maintain reactor core cooling is to place the installed RHR shutdown cooling (SDC) system in service as powered up by the offsite resource National SAFER Response Center (NSRC) 4160VAC generator. As a means of clarification, the JAF strategy does not require the use of the installed RHR SDC system in Phase 3. While the capability to use RHR SDC in Phase 3 is provided by the FLEX strategy, the primary means of maintaining core cooling for JAF is by continuation of the FLEX Phase 2 strategy (use of diesel-driven fire pumps to maintain core cooling). Based on this, none of the modifications listed in Reference 1, page 23, are required to support the FLEX strategy.

Reference 1, page 24 (and associated follow on discussions on page 25, 26, 27 and 28) states that the reliable hardened vent system (RHVS) as implemented for NRC Order-EA-12-050 is required to support the JAF FLEX strategy. NRC Order EA-12-050 was superseded by NRC Order EA-13-109. In Reference 1919, Entergy Nuclear Operations Inc. (Entergy) requested relief for implementation of Order EA-13-109 to June of 2018. In Reference 20, the NRC granted relief. The JAF FLEX strategy does not rely on the use of the RHVS installed for Order EA-13-109. The JAF strategy credits the use of a qualified vent path of the existing standby gas treatment system to satisfy containment venting. All applicable systems structures and components have been evaluated to be qualified for all applicable external events.

Reference 1, page 30 states no Phase 1 actions are required for more than 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> to maintain spent fuel pool (SFP) cooling. The spent fuel pool time to boil calculation shows that the spent fuel pool does not begin to boil until approximately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> after the inception of the event. Some actions that will be performed before the spent fuel pool floor becomes inaccessible include routing hoses from the floor to an accessible area, positioning a spray monitor for spray capability and establishing a spent fuel pool building vent path.

Reference 1, page 37, states that the main control room (MCR) heatup calculation credits open damper 70FD-8 for heat escaping in the floor of the kitchen and also states that actions are required to check this damper open and to block open the entrance air lock when the MCR reaches 90°F. The MCR heatup calculation does not credit opening the damper nor the air lock for relieving heat. At 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />, during Phase 3, the JAF strategy credits the use of the NSRC 4160VAC generator to power up the electrical buses necessary for use of the MCR ventilation system.

Reference 1, page 40 (and ensuing discussion on page 41), states that the SFP area/building vent path can be enhanced by re-powering a standby gas treatment system (SGTS) fan and that a modification will be performed to provide connection points to facilitate re-powering a SGTS fan directly by a portable FLEX generator. The JAF FLEX strategy does not require the use of a SGTS fan to assist in ventilating the SFP area/building.

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Reference 1, page 43, states that Phase 2 strategy will be continued for Phase 3 (propping open certain fire doors within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />). Phase 3 JAF strategy for the extreme heat condition is to re-power existing exhaust and recirculation ventilation system components using the NSRC 4160VAC generator to address any long term heat up concerns at approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. The JAF strategy at 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> for the extreme cold event is to maximize warm air flow and recirculation by administratively opening and closing off doors to adjacent rooms/buildings along with ambient temperature monitoring.

In addition to the equipment changes provided by Reference 10, Section 4, the following changes are applicable to the Table of BWR Portable Equipment Phase 2 shown in Reference 1, page 45:

a) Only one heavy duty pickup truck is required b) Air compressors are not required c) 90KW 600VAC DGs are not required d) The 200KW 600VAC FLEX DGs employ the use of one single conductor 1/0 cable per phase instead of three 250 MCM cables e) The JAF strategy does not require two 200 gallon fuel tanks mounted on trailers.

Instead, the JAF strategy employs two DC electric-driven fuel pump skids mounted on small hand carts to facilitate transferring fuel from the on-site emergency diesel fuel oil storage tanks directly to diesel engine powered FLEX equipment f) The JAF strategy uses one spray monitor to deliver a minimum of 250 gpm to the spent fuel pool, instead of two 100 gpm spray nozzles.

Reference 1, page 46, provides the list of Phase 3 FLEX equipment. In addition to this equipment, the following equipment from the NSRC is required:

a) One submersible pump b) One medium flow low pressure pump c) One 480VAC generator d) One 480VAC/600VAC step up transformer e) One air compressor In addition to the changes provided in Section 4 of References 7 and 10, the sequence of events time line provided in Reference 1, Attachment 1A, is revised as follows: (1)

Action 2 occurs at 30 minutes, (2) Action 4 is no longer relevant as RCIC only takes suction from the CST, (3) Action 6 is no longer relevant consistent with Action 4 no longer being relevant, (4) Action 7 is completed by 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, (5) Action 8 is completed by 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, (6) Action 9 to vent the containment is completed by 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and the JAF strategy no longer credits the RHVS but uses an installed SGTS vent path, (7) Action 10 is accomplished at 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, (8) Action 11 to makeup to the SFP occurs at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but the action to vent the SFP area/refuel floor occurs at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, (9) Action 12 occurs at greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as the JAF Phase 2 FLEX strategy provides an indefinite coping capability and the decision to place SDC in service is discretionary.

Reference 1, Figures 1, 2 and 3, have been superseded. The correct figures will be provided upon issuance of the FIP.

Finally, the JAF FLEX storage strategy requires the use of two ASCE 7-10 buildings and the use of specific existing plant buildings (Turbine Building, Screenhouse and Reactor Building) to provide adequate protection of all the FLEX equipment, such that no one external event can reasonably fail the JAF FLEX capability (N).

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF submitted a request for relaxation of Order EA-12-049 and Order EA-12-051 full compliance dates to June 30, 2017 (References 13 and 14). This request was based, in part, on Entergy's plan to permanently cease power operations at JAF on January 27, 2017, as certified in its letter to the NRC dated March 16, 2016 (Reference 9). By letter dated August 18, 2016 (Reference 1616), Entergy and Exelon Generation Company, LLC (Exelon) jointly submitted an application for an order and conforming license amendment transferring the JAF facility operating license from Entergy to Exelon, contingent upon certain closing conditions. This letter describes the circumstances leading to the license transfer request. Entergy submitted a second request for relaxation of the Order EA-12-049 and Order EA-12-051 full compliance dates, also to June 30, 2017. This request was based, in part, on a plan to operate JAF after a refueling outage which started in January 2017, contingent upon achieving the closing conditions associated with the license transfer. In light of the facts presented in Entergys letters (References 13, 14 and 15), the NRC staff approved a relaxation of the orders to June 30, 2017 (Reference 18).

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide:

Table 1: summary and status of any open items in the Overall Integrated Plan (Reference 1),

Table 2: open items and Table 3: confirmatory items in the Interim Staff Evaluation (ISE) (Reference 4),

Table 4: the status of Audit Question and Table 5: open Audit Questions for the Mitigation Strategies (FLEX) Order NRC Audit (Reference 17);

Note: Table 5 includes open items on previously issued ISE Open and Confirmatory Items and new Safety Evaluation (SE) Open Items that were not closed during the October 2016 NRC Audit Visit, and their status. During the October 2016 NRC Audit Visit, the NRC utilized a spreadsheet entitled FitzPatrick Nuclear Plant, SE Item Tracker to maintain a status of Open Items associated with development of the NRCs Safety Evaluation. The SE Tracker numbered each item with an Audit Item No. based on the category of the Open Item. The categories were:

A. ISE Open and Confirmatory Items (Audit Item OI-xxxxx or CI-xxxxx)

B. Audit Questions (Audit Item AQ. x)

C. Licensee OIP Open Items (Audit Item OIP.x)

D. SFP Instrumentation RAIs (Audit Item SFPI. x)

E. Combined SE Template Technical Review Gaps (Audit Item SE.x)

In the Status columns of the following tables, closed items are identified by the phrase This item was closed during the October 2016 NRC Audit Visit.

Table 1: Overall Integrated Plan Open Items Overall Integrated Plan Open Items Status OI-1: Beyond-design-basis external event impact on This item was closed during requirements in existing licensing documents will be the October 2016 NRC determined based on input from the industry groups and Audit Visit (Reference 17) direction from the NRC.

OI-2: The structure, content and details of the Regional This item was closed during Page 6 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Response Center playbook will be determined. the October 2016 NRC Audit Visit (Reference 17)

Table 2: Interim Staff Evaluation Open Items Interim Staff Evaluation Open Items Status OI 3.1.1.3.A Procedural Interface (Seismic Hazard) - Evaluate the This item was closed impacts from large internal flooding sources. during the October 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.5 response).

OI 3.1.3.1.A Protection of FLEX Equipment (High Wind Hazard) - This item was closed Evaluate the separation distance and the axis of during the October separation considering the predominant path of 2016 NRC Audit Visit tornados in the geographic area to demonstrate that at (Reference 17) least N sets of FLEX equipment would remain (Associated with AQ.1) deployable in the context of a tornado missile hazard.

OI 3.1.4.2.B Deployment of FLEX Equipment (Snow, Ice and This item was closed Extreme Cold) - Evaluate the potential impact on the during the October UHS due to ice blockage or formation of frazil ice as a 2016 NRC Audit Visit result of extreme cold. (Reference 17)

OI 3.2.3.A Containment- Verify that the implementation of Boiling This item was closed Water Reactor Owners Group (BWROG) Emergency during the October Procedure Guideline (EPG)/Severe Accident Guideline 2016 NRC Audit Visit (SAG), Revision 3, including any associated plant- (Reference 17) 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 (ML13358A206))

Table 3: Interim Staff Evaluation Confirmatory Items Interim Staff Evaluation Confirmatory Items Status CI 3.1.1.2.A Deployment of FLEX Equipment- Confirm that soil This item was closed liquefaction will not impede vehicle movement during the October following a seismic event. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.2)

CI 3.1.1.2.B Deployment of FLEX Equipment- Confirm final design This item was closed features of the new storage building including the during the October susceptibility to the loss of ac power to deploy 2016 NRC Audit Visit equipment. (Reference 17)

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 (Associated with AQ.1)

CI 3.1.1.2.C Deployment of FLEX Equipment - Confirm the storage This item was closed locations and means of protection against the seismic during the October hazard of the super duty pickup trucks and the two 2016 NRC Audit Visit flatbed trailers used for deployment of FLEX (Reference 17) equipment. (Associated with AQ.1)

CI 3.1.1.4.A Offsite Resources- Confirm location of offsite staging This item was closed area(s), access routes and methods of delivery of during the October equipment to the site considering the seismic, flood, 2016 NRC Audit Visit high wind, snow, ice and extreme cold hazards. (Reference 17)

CI 3.1.3.2.A Deployment of FLEX Equipment (High Wind Hazard) - This item was closed Confirm availability of debris removal equipment to during the October facilitate deployment of FLEX equipment. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.1)

CI 3.1.3.2.B Deployment of FLEX Equipment (High Wind Hazard) - This item was closed Confirm protection of the means to move FLEX during the October equipment. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.1)

CI 3.1.4.2.A Deployment of FLEX Equipment (Snow, Ice and This item was closed Extreme Cold) - Confirm availability of snow removal during the October equipment to facilitate deployment of FLEX 2016 NRC Audit Visit equipment. (Reference 17)

(Associated with AQ.1)

CI 3.2.1.1.A Computer Code Used for ELAP Analysis - This item was closed Benchmarks need to be identified and discussed during the October which demonstrate that Modular Accident Analysis 2016 NRC Audit Visit Program (MAAP) is an appropriate code for the (Reference 17) simulation of an ELAP event at JAF. (Associated with AQ.9).

CI 3.2.1.1.B Computer Code Used for ELAP Analysis -Confirm This item was closed that the collapsed level remains above Top of Active during the October Fuel (TAF) and the cool down rate is within technical 2016 NRC Audit Visit specifications limits. (Reference 17)

(Associated with AQ.12)

CI 3.2.1.1.C Computer Code Used for ELAP Analysis - Confirm This item was closed that MAAP was used in accordance with Sections 4.1, during the October 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper 2016 NRC Audit Visit Page 8 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 (ML13190A201). (Reference 17)

(Associated with AQ.10).

CI 3.2.1.1.D Computer Code Used for ELAP Analysis - Confirm This item was closed that the licensee, in using MAAP, identified and during the October justified the subset of key modeling parameters cited 2016 NRC Audit Visit from Tables 4-1 through 4-6 of the "MAAP Application (Reference 17)

Guidance, Desktop Reference for Using MAAP (Associated with Software, Revision 2" (Electric Power Research AQ.11).

Institute Report 1 020236).

CI 3.2.1.1.E Computer Code Used for ELAP Analysis - Confirm This item was closed that the specific MAAP analysis case that was used to during the October validate the timing of mitigating strategies in the 2016 NRC Audit Visit Integrated Plan has been identified and is available (Reference 17) 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.

CI 3.2.1.2.A Recirculation Pump Seal Leakage Models - Confirm This item was closed the seal leakage model used in the updated MAAP during the October analysis (which will address the MAAP code 2016 NRC Audit Visit limitations when used for ELAP analysis). Evaluate (Reference 17) the seal leakage rate model used, the details of the (Associated with seal qualification tests and supporting test data, and AQ.14).

leakage rate pressure-dependence.

CI 3.2.1.3.A Sequence of Events (SOE) - Confirm the SOE This item was closed timeline after reanalysis using the MAAP code which during the October will address the limitations when used for the ELAP 2016 NRC Audit Visit analysis. (Reference 17)

CI 3.2.1.4.A Systems and Components for Consequence This item was closed Mitigation - Confirm sizing of the FLEX pumps and during the October 600 Vac FLEX diesel generator (DG) and the 4160 2016 NRC Audit Visit Vac generator to be obtained from the RRC. (Reference 17)

(Associated with AQ.22).

CI 3.2.1.5.A Monitoring Instrumentation and Controls- Confirm ac This item was closed powered torus temperature, pressure and level and during the October Page 9 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 drywell temperature and pressure instrumentation is 2016 NRC Audit Visit modified to remain powered during an ELAP. (Reference 17)

(Associated with AQ.6).

CI 3.2.1.8.A Use of Portable Pumps - Confirm that the use of raw This item was closed water from Lake Ontario for long term core and spent during the October fuel pool cooling strategies is acceptable. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.23).

CI 3.2.2.A Spent Fuel Pool Cooling - Confirm the method of This item was closed ventilation and power requirements, if any, of the during the October spent fuel pool area. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.28).

CI 3.2.4.2.A Ventilation (Equipment Cooling) - Confirm that This item was closed additional evaluations of the RCIC room temperature during the October demonstrate that an acceptable environment is 2016 NRC Audit Visit maintained during the transition phase both for (Reference 17) equipment in the room and habitability for operators (Associated with who may need to enter the room. AQ.31).

CI 3.2.4.2.B Ventilation (Equipment Cooling) - Confirm that This item was closed evaluations of the battery room temperature during the October demonstrate that an acceptable environment, during 2016 NRC Audit Visit both high ambient temperature and during extreme (Reference 17) cold ambient temperature, is maintained during (Associated with Phases 2 and 3. AQ.46)

CI 3.2.4.2.C Ventilation (Equipment Cooling) - Confirm the This item was closed required ventilation flow or the size of the portable during the October fans to maintain acceptable environmental conditions 2016 NRC Audit Visit in the DC equipment room. (Reference 17)

(Associated with AQ.61)

CI 3.2.4.3.A Heat Tracing - Confirm completion of walkdowns and This item was closed evaluation of where heat tracing may be needed for during the October freeze protection of equipment or instruments used in 2016 NRC Audit Visit the ELAP mitigation strategies. (Reference 17)

(Associated with AQ.35)

Page 10 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 CI 3.2.4.4.A Lighting - Confirm need for additional portable This item was closed lighting, such as dc powered lights. during the October 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.36)

CI 3.2.4.4.B Communications - Confirm that upgrades to the site's This item was closed communication system have been completed. during the October 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.37)

CI 3.2.4.8.A Electrical Power Sources - Confirm the technical This item was closed basis for the selection and size of the FLEX during the October generators to be used in support of the coping 2016 NRC Audit Visit strategies. (Reference 17)

(Associated with AQ.22 and AQ.50)

CI 3.2.4.10.A Load Reduction to Conserve DC Power - Confirm This item was closed final load shed list and the evaluation of any potential during the October adverse effects of shedding those loads. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.65)

CI 3.2.4.10.B Load Reduction to Conserve DC Power - Confirm the This item was closed final dc load profile with the required loads and the during the October finalized minimum battery voltage. 2016 NRC Audit Visit (Reference 17)

(Associated with AQ.64 and AQ.66)

CI 3.2.4.10.C Load Reduction to Conserve DC Power- Confirm time This item was closed after the ELAP for connecting the FLEX DG to the during the October battery chargers. 2016 NRC Audit Visit (Reference 17)

CI 3.4.A Off-site Resources- Confirm that NEI 12-06, Section This item was closed 12.2 guidelines 2 through 10 are addressed, or that during the October an appropriate alternative is justified. 2016 NRC Audit Visit (Reference 17)

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Questions Audit Completion or Status Questions Target Date This item was closed during the October 2016 NRC Audit Visit AQ.1 (Reference 17) (associated with ISE OI 3.1.3.1.A and ISE CI N/A 3.1.1.2.B, CI 3.1.1.2.C, CI 3.1.3.2.A, CI 3.1.3.2.B, CI 3.1.4.2.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.2 (Reference 17) (associated with ISE CI 3.1.1.2.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.3 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.4 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.5 (Reference 17) (associated with ISE OI 3.1.1.3.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.6 (Reference 17) (associated with ISE CI 3.2.1.5.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.8 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.9 (Reference 17) (associated with ISE CI 3.2.1.1.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.10 (Reference 17) (associated with ISE CI 3.2.1.1.C)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.11 (Reference 17) (associated with ISE CI 3.2.1.1.D)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.12 (Reference 17) (associated with ISE CI 3.2.1.1.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.13 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.14 (Reference 17) (associated with ISE CI 3.2.1.2.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.15 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.16 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.17 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.18 (Reference 17)

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Questions Audit Completion or Status Questions Target Date This item was statused as open during the October 2016 NRC N/A AQ.19 Audit Visit (Reference 17). See Table 5 (below) for status of this item.

This item was closed during the October 2016 NRC Audit Visit N/A AQ.21 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.22 (Reference 17) (associated with ISE CI 3.2.1.4.A and CI 3.2.4.8.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.23 (Reference 17) (associated with ISE CI 3.2.1.8.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.26 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.27 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.28 (Reference 17) (associated with ISE CI 3.2.2.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.29 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.31 (Reference 17) (associated with ISE CI 3.2.4.2.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.32 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.33 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.34 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.35 (Reference 17) (associated with ISE CI 3.2.4.3.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.36 (Reference 17) (associated with ISE CI 3.2.4.4.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.37 (Reference 17) (associated with ISE CI 3.2.4.4.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.38 (Reference 17)

AQ.40 This item was closed during the October 2016 NRC Audit Visit N/A Page 13 of 17

JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Questions Audit Completion or Status Questions Target Date (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.46 (Reference 17) (associated with ISE CI 3.2.4.2.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.50 (Reference 17) (associated with ISE CI 3.2.4.8.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.52 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.53 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.55 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.56 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.57 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.58 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.59 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.60 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.61 (Reference 17) (associated with ISE CI 3.2.4.2.C)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.62 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.63 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.64 (Reference 17) (associated with ISE CI 3.2.4.10.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.65 (Reference 17) (associated with ISE CI 3.2.4.10.A)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.66 (Reference 17) (associated with ISE CI 3.2.4.10.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.68 (Reference 17)

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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 Questions Audit Completion or Status Questions Target Date This item was closed during the October 2016 NRC Audit Visit N/A AQ.69 (Reference 17) (associated with ISE CI 3.2.4.2.B)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.70 (Reference 17)

This item was closed during the October 2016 NRC Audit Visit N/A AQ.71 (Reference 17)

NOTE During the October 2016 Audit Visit, additional information related to each Open Item was provided to the NRC for review. By the end of the NRC Audit Visit, the NRC verbally had statused each open item and indicated what the staff needed to close the Open Items. The Status column in the table below reflects the current activity in progress to close the Open Items.

Table 5: October 2016 - NRC Audit Visit FLEX Related Open Items Audit Item Status Item Description Reference (Post Audit)

AQ.19 Provide additional information Open regarding the installed diesel-driven Pending NRC review, no further Entergy fire pump and the associated piping, action required.

fuel supply and support equipment to demonstrate that it is protected against all postulated BDBEEs.

SE.8 Provide a discussion/analysis on the Open ability of electrical and mechanical Pending NRC review, no further Entergy equipment (i.e., valve solenoids, action required.

instruments, relays, etc.) located within containment and other areas of the plant (i.e., Main Control Room, RCIC [reactor core isolation cooling]

Pump Room, SRV areas, Switchgear Rooms, Battery Rooms, etc.) that is relied upon during an ELAP to function in the expected environmental conditions (for both extreme high and low temperatures) for the duration of the ELAP event (i.e., indefinitely).

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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, Entergy has not identified any additional potential impacts to the Interim Staff Evaluation since the previous six month status report (Reference 12).

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 (ML13063A287).

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 (ML12054A736).

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 (ML13241A204).

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 (ML14007A681)

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 (ML14059A359)

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 (ML14241A261)

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 (ML15058A587)

8. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12242A378)

9. Entergy to NRC, JAFP-16-0045, Certification of Permanent Cessation of Power Operations, dated March 16, 2016 (ML16076A391)

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 (ML15240A370)

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JAFP-17-0017 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Eighth 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. Entergy to NRC, 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 049), dated February 26, 2016 (ML16057A603)

12. Entergy to NRC, JAFP-16-0139, Seventh 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 25, 2016 (ML14007A681)

13. Entergy to NRC, JAFP-16-0061, Request for Relaxation of March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated April 14, 2016 (ML16105A379)

14. Entergy to NRC, JAFP-16-0096, Supporting Information for Request for Relaxation of March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated June 16, 2016 (ML16168A452)

15. Entergy to NRC, JAFP-16-0147, Request for Extension to Comply with March 12, 2012 Commission Orders Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051), dated September 8, 2016 (ML16252A477)

16. Entergy and Exelon Generation to NRC, Application for Order Approving Transfer of Renewed Facility Operating License and Proposed Conforming License Amendment, dated August 18, 2016 (ML16235A081)

17. NRC to Entergy, James A. FitzPatrick Nuclear Power Plant - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (CAC Nos. MF1077 AND MF1076), dated December 14, 2016 (ML16343A011)

18. NRC to Entergy, James A. FitzPatrick Nuclear Power Plant - Relaxation of the Schedule Requirements for Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" and Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation (CAC Nos. MF1077 and MF1076), dated December 2, 2016 (ML16173A342)

19. Entergy to NRC, JAFP-16-0148, Request for Extension to Comply with NRC Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated September 8, 2016 (ML16252A482)

20. NRC to Entergy, James A. FitzPatrick Nuclear Power Plant - Relaxation of the Schedule Requirements for Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, 21.

dated January 9, 2017 (ML16336A754)

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