NL-15-059, Notification of Full Compliance with Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events and Order EA-12-051 Modifying Licenses with Regard..

Notification of Full Compliance with Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events and Order EA-12-051 Modifying Licenses with Regard..

ML15149A140
Person / Time
Site:	Indian Point
Issue date:	05/20/2015
From:	Coyle L Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, EA-12-051, NL-15-059, TAC MF0738, TAC MF0745
Download: ML15149A140 (47)

Text

Entergy Nuclear Northeast Indian Point Energy Center

%Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-059 May 20, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, OWFN-2 FL Rockville, MD 20852-2738

SUBJECT:

Notification of Full Compliance with Order EA-12-049 "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" and Order EA-12-051 "Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0745 and MF0738)

Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64

REFERENCES:

1. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A736).

2. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A682)

3. Entergy letter to NRC (NL-13-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2013 (ML13079A348)

4. Entergy letter to NRC (NL-13-043), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-043), dated February 27, 2013 (ML13079A348)

5. NRC Letter Regarding Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0744 and MF0745), January 24, 2014 (ML13337A594)

6. NRC Letter Report for the Onsite Audit Regarding Implementation

~N~W5I

NL-15-059 Docket No. 50-286 Page 2 of 3 of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0744, MF0745, MF0737, and MF0738), December 9, 2014 (ML14335A642) 7 NRC Letter Regarding Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051 (Spent Fuel Pool Instrumentation)

(TAC Nos. MF0737 and MF0738), November 8, 2013 (ML13298A805)

Dear Sir or Madam:

The purpose of this letter is to notify the NRC that Indian Pont 3 (IP3) is in compliance with Opders EA-12-049 and EA-12-051. On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Orders EA-12-049 (Reference 1) and Order EA-12-051 (Reference 2) to Entergy Nuclear Operations Inc. (Entergy).

Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Reference 2 was immediately effective and directed Entergy to install reliable spent fuel pool level instrumentation.

Order EA-12-049,Section IV.A.2 and Order EA-12-051,Section IV.A.2 requires completion of full implementation to be no later than two refueling cycles after submittal of the Overall Integrated Plan (OIP), as required by Condition C.1 .a, or December 31, 2016, whichever comes first. In addition,Section IV.C.3 of Orders EA-12-049 and EA-12-051 require that Licensees and CP holders report to the NRC when full compliance is achieved. The OIP for EA-12-049 was submitted (Reference 3) on February 28, 2013 and the OIP for EA-12-051 was submitted (Reference 4) on February 27, 2013. On March 24, 2015, IP3 entered Mode 2 (startup) following the 3RO18 refueling outage.

Full compliance with Orders EA-12-049 and EA-12-051 was achieved at that time as discussed in the Attachments. provides a brief summary of the key elements associated with compliance to Order EA-12-049 for IP3. A listing of each item that has not been docketed as closed by the NRC from the Open and Confirmatory Items identified in the Interim Staff Evaluation (Reference 5), Open items in the OIP (Reference 3), and Audit questions and open items (Reference 6) is provided which references the responses. The responses are based on information and analyses that have been completed as of the date of full compliance. As such, Energy considers these items complete pending NRC closure. provides a brief summary of the key elements associated with compliance to Order EA-12-051 for IP3. A listing of each item that has not been docketed as closed by the NRC from the Open and Confirmatory Items identified in the Interim Staff Evaluation (Reference 7), Open items in the OIP (Reference 4), and Audit questions and open items (Reference 6) is provided which references the responses. The responses are based on information and analyses that have been completed as of the date of full compliance. As such, Energy considers these items complete pending NRC closure.

NL-15-059 Docket No. 50-286 Page 3 of 3 This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct; executed on May

,0, 2015.

Sincerely, Attachments: 1. Indian Point 3 Summary of Compliance Bases for Order EA-12-049

2. Indian Point 3 Summary of Compliance Bases for Order EA-12-051 cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 Mr. John Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspectors Office Mr. John B. Rhodes, President and CEO, NYSERDA

ATTACHMENT 1 TO NL-15-059 INDIAN POINT 3

SUMMARY

OF COMPLIANCE BASES FOR ORDER EA-12-049 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

NL-15-059 Docket No. 50-286 Attachment 1 Page 1 of 39 Indian Point Unit Three's Compliance Letter for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 1) to Entergy. This Order was effective immediately and Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) (Reference 2) for Indian Point Energy Center (IPEC),

documenting the diverse and flexible strategies (FLEX) required. The Order required compliance prior to plant startup from the second refueling outage following submittal of the OIP, or by December 31, 2016, whichever comes first. The compliance date for Indian Point 3 (IP3) was March 24, 2015. The NRC staff requested that the compliance report be submitted within 60 days of the compliance date. The information provided herein documents full compliance for Indian Point 3 in response to the Order.

Milestone Schedule - Items Complete The following milestone(s) have been completed as of March 24, 2015:

Target Milestone Completion Activity Status Date*

Submit Overall Integrated Feb 2013 Completed Implementation Plan Submit Six Month Updates Update 1 Aug 2013 Completed Update 2 Feb 2014 Completed Update 3 Aug 2014 Completed Update 4 Feb 2015 Completed Perform Staffing Analysis Nov 2014 Completed Off-site FLEX Equipment Develop Strategies with NSRC March 2015 Completed Procedures PWROG issues NSSS-specific Jan 2014 Completed guidelines Validation / Demonstration March 2015 Completed Submit Completion Report Unit 3 May 2015 Open

NL-15-059 Docket No. 50-286 Attachment 1 Page 2 of 39 Target Milestone Completion Activity Status Date*

Modifications Engineering and Implementation N-1 Walkdown Spring 2014 Completed Design Engineering Dec 2014 Completed On-site FLEX Equipment Purchase / Procure Jan 2015 Completed Procedures Create Indian Point FSG Oct 2014 Completed Create Maintenance Procedures March 2015 Completed Training:

Develop Training Plan Nov 2014 Completed Implement Training March 2015 Completed

• - Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports STRATEGIES - COMPLETE Indian Point Unit 3 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items. Although there are items not reviewed by the NRC Staff, Entergy considers these items to be closed.

MODIFICATIONS - COMPLETE The modifications required to support the FLEX strategies for Indian Point Unit 3 have been fully implemented in accordance with the station design control process.

EQUIPMENT - PROCURED AND MAINTENANCE & TESTING - COMPLETE The equipment required to implement the FLEX strategies for Indian Point Unit 3 has been procured in accordance with NEI 12-06, Section 11.1 and 11.2, received at IPEC, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Maintenance and testing will be conducted through the use of the Preventative Maintenance program such that equipment reliability is achieved.

NL-15-059 Docket No. 50-286 Attachment 1 Page 3 of 39 PROTECTED STORAGE - COMPLETE The storage facility/facilities required to implement the FLEX strategies for Indian Point Unit 3 has been completed and provides protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Indian Point Unit 3 is stored in its protected configuration.

PROCEDURES - COMPLETE FLEX Support Guidelines (FSGs), for Indian Point Unit 3 have been developed, and integrated with existing procedures. The FSGs and affected existing procedures have been validated per NEI12-06, Section 11.4.3 and are available for use in accordance with the site procedure control program.

TRAINING - COMPLETE Training for Indian Point Unit 3 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

STAFFING - COMPLETE The staffing study for IPEC has been completed in accordance with 10CFR50.54(f),

"Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 1), as documented in letter dated November 3, 2014 which submitted the Phase 2 staffing study (Reference 8).

NATIONAL SAFER RESPONSE CENTERS - COMPLETE Entergy has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support IPEC with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

VALIDATION - COMPLETE Entergy has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) / Final Integrated Plan (FIP) for Order EA-12-049.

NL-15-059 Docket No. 50-286 Attachment 1 Page 4 of 39 FLEX PROGRAM DOCUMENT - ESTABLISHED The Indian Point Unit 3 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.

Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes the FLEX related NRC Audit Visit Open Items, which includes open items on previously issued Audit Questions and new Safety Evaluation (SE) Open Items that were not closed during the October 2014 NRC Audit Visit as documented in the NRCs Report for the Onsite Audit (Reference 12). A fifth table includes a listing of all Audit Questions and the status of each item. Where appropriate the tenses have been changed and items revised to reflect the completion of activities.

NL-15-059 Docket No. 50-286 Attachment 1 Page 5 of 39 Overall Integrated Plan Open Item Status There were no open items documented in N/A the IPEC Overall Integrated Plan Interim Staff Evaluation Open Items Status 3.1.2.A Review of the licensee's This item was closed during the October 2014 new flooding level NRC Audit Visit (associated with AQ IPEC-006).

evaluation results and its potential impact on the flooding hazard analyses previously provided in their Integrated Plan and during the audit process is identified as an Open Item.

Ifthe flooding levels are modified based on the results of this review, it may affect the evaluation of the deployment described in Section 3.1.2.2 of this evaluation.

3.2.4.7.A It is noted that NEI 12-06 This item was closed during the October 2014 guidance only credits NRC Audit Visit (associated with AQ IPEC-041).

water supplies that are robust with respect to seismic events, floods, and high winds, and the associated missiles. The licensee should determine if a water supply for the SGs and RCS would be available after a tornado event by analyzing the tornado characteristics for the site compared to the separation characteristics of the tanks. This is an alternate approach from the strategies identified in NEI 12-06.

NL-15-059 Docket No. 50-286 Attachment 1 Page 6 of 39 Interim Staff Evaluation Confirmatory Status Items 3.1.1.2.A Confirm that at least one This item was closed during the October 2014 connection point for the NRC Audit Visit (associated with AQ IPEC-036).

FLEX AFW pump is accessible and is located inside a building that is seismically robust as described in Consideration 2 of NEI 12-06, Section 5.3.2.

3.1.1.2.B Confirm that the pickup This item was closed during the October 2014 trucks, forklifts or any other NRC Audit Visit.

equipment that will be used to deploy the portable equipment for implementing FLEX strategies will be reasonably protected from the event as described in Consideration 5 of NEI 12-06, Section 5.3.2.

3.1.1.2.C Confirm provisions will be This item is addressed by updated AQ-IPEC-made to ensure that 023 response.

access to all required areas will be assured in Entergy Response Update to E Portal to the event of a power failure address ISE Confirmatory Item 3.1.1.2.C as described in (02/27/2015)

Consideration 5 of NEI 12-06, Section 5.3.2. 3-FSG-005, Initial Assessment and Flex Equipment, Step 4.2 notifies Security of ELAP and to expedite access per Security procedures listed (i.e., safeguards procedures 0-SE-001, Access Control, 0-SE-021, Integrated Response Plan, and 0-SE-301, Contingency Events). The FLEX Building is accessible by manual action using a come along. Security will be able to open vital areas, initially on uninterruptible power, when notified. Access through the SOCA and PA boundaries can be manually controlled by security. Truck barriers can be operated hydraulically using procedure 0-SE-005. The NRC Report (ML14335A642) for the onsite audit, issued on December 9, 2014, closed this item.

3.1.1.2.D Confirm that the licensee This item was closed during the October 2014

NL-15-059 Docket No. 50-286 Attachment 1 Page 7 of 39 Interim Staff Evaluation Confirmatory Status Items has reviewed the NRC Audit Visit (associated with AQ IPEC-002).

deployment paths from the near site storage areas to the site and from the onsite storage areas to the deployment location to verify that these paths are not subject to soil liquefaction concerns as described in Consideration 1 of NEI 12-06, Section 5.3.2.

3.1.1.3.A Confirm that the licensee's This item was closed during the October 2014 review of the potential NRC Audit Visit (associated with AQ IPEC-004).

impacts of large internal flooding sources that are not seismically robust and do not require ac power has been completed per consideration 2 of NEI 12-06, Section 5.3.3.

3.1.1.4.A Confirm that the This item was closed during the October 2014 intermediate staging area NRC Audit Visit (associated with AQ IPEC-005).

has been selected and implementing procedures have been developed.

3.1.2.2.A Confirm that evaluations This item was closed during the October 2014 address: whether NRC Audit Visit (associated with AQ IPEC-006).

procedures have been established for actions to be taken upon receipt of a hurricane warning; ensuring that fuel in oil storage tanks would not be inundated or damaged by flooding; and, whether the means (e.g., trucks) for moving FLEX equipment is reasonably protected from the event.

3.2.1 .A Confirm which analysis This item was closed following the October performed in WCAP- 2014 NRC Audit Visit as documented in 17601-P is being applied Reference 13 (associated with AQ IPEC-012).

to Indian Point. Also

NL-15-059 Docket No. 50-286 Attachment 1 Page 8 of 39 Interim Staff Evaluation Confirmatory Status Items confirm the licensee has adequately justified the use of that analysis by identifying and evaluating the important parameters and assumptions demonstrating that they are representative of Indian Point and appropriate for simulating the ELAP transient.

3.2.1.1.A Confirm that the licensee is This item was closed following the October using NOTRUMP and has 2014 NRC Audit Visit as documented in taken into account its Reference 13 (associated with AQ IPEC-012).

limitations. Reliance on the NOTRUMP code for the Entergy Response Update to E Portal to address ISE ELAP analysis of Confirmatory Item 3.2.1.1.A (10/27/2014):

Westinghouse plants is limited to the flow The following updated response was conditions prior to reflux superseded by the response to SE#5.

condensation initiation. "The analysis performed in Section 5.2.1 of This includes specifying an WCAP-17601-P used the NOTRUMP computer acceptable definition for code to develop the basis for the time lines in reflux condensation the Overall Integrated Plan for Indian Point cooling. Units 2 and 3.

The PWROG submitted PWROG-14064-P, "Application of NOTRUMP Code Results for the Westinghouse Designed PWRs in Extended Loss of AC Power Circumstances", to the NRC on September 26, 2014. PWROG-14064-P is the position paper on the use of the NOTRUMP thermal hydraulic computer code for analyzing the Westinghouse and CE NSSS designed reactor system response (RCS) to an extended loss of AC power (ELAP) event and addresses the USNRC questions relative to the applicability of the NOTRUMP code to the RCS analysis of an ELAP during various plant audits regarding flexible and diverse coping mitigating strategies (FLEX) implementation."

3.2.1.3.A Confirm that the licensee This item was closed during the October 2014 has satisfactorily NRC Audit Visit (associated with AQ IPEC-01 3).

addressed the applicability of Assumption 4 on page

NL-15-059 Docket No. 50-286 Attachment 1 Page 9 of 39 Interim Staff Evaluation Confirmatory Status Items 4-13 of WCAP-17601 which states that decay heat is per ANS 5.1-1979

+ 2 sigma, or equivalent. If the ANS 5.1-1979 + 2 sigma model is used in the Indian Point ELAP analysis, address the adequacy of the use of the decay heat model in terms of the plant-specific values of the following key parameters: (1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics (addressing whether they are based on the beginning of the cycle, middle of the cycle, or end of the cycle). If a different decay heat model is used, describe the specific model and address the adequacy of the model and the analytical results.

3.2.1.6.A Confirm that the licensee This item was closed during the October 2014 has finalized its strategy NRC Audit Visit (associated with AQ IPEC-035).

for controlling the RCS pressure to prevent nitrogen from escaping from the safety injection accumulators into the RCS until the isolation valves can be closed.

3.2.1.8.A The PWROG submitted to This item is addressed by updated AQ IPEC-NRC a position paper, 050 response.

dated August 15, 2013, which provides test data Entergy Response Update to E Portal for regarding boric acid mixing IPEC -50 (02/27/2015):

NL-15-059 Docket No. 50-286 Attachment 1 Page 10 of 39 Interim Staff Evaluation Confirmatory Status Items under single-phase natural circulation conditions and Indian Point Unit 3 RCS makeup strategy was outlined applicability revised to provide RCS makeup prior to 11.9 conditions intended to hours, to prevent reflux cooling. This strategy is ensure that boric acid supported by PWROG-14027-P, Revision 1, addition and mixing would Table 6-1, Category 1, Time to Enter Reflux occur under conditions Cooling. The RCS makeup strategy revision similar to those for which includes a new time-dependent seal leakage boric acid mixing data is profile based on PWROG-14027-P, Revision 1 available. During the audit results (see SE#13). IPEC will continue to process, the licensee follow PWROG FLEX efforts that may impact informed the NRC staff of this response.

its intent to abide by the generic approach See SE#5 for additional information.

discussed above. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

i i 3.2.1.9.A Confirm that the licensee This item is addressed by updated AQ IPEC-has specified the required 017 response.

time for the operator to realign each of the above Entergy Response Update to E Portal discussed pumps and (02/27/2015):

confirm that the required In regards to the RCS Inventory Response, the times are consistent with Indian Point 3 RCS makeup strategy is revised the results of the ELAP to provide RCS makeup prior to 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to analysis. Confirm that the prevent reflux cooling. This strategy is licensee discussed the supported by the methodology developed on analyses that are used to PWROG-14027-P, Revision 1, Table 6-1, determine the required Category 1, Time to Enter Ref lux Cooling. The flow rate and RCS makeup strategy revision includes a new corresponding total time-dependent seal leakage profile based on developed head for each PWROG-14027-P, Revision 1 results (see also of the portable pumps and updated response SE #13). IPEC will continue also to justify that that the to follow PWROG FLEX efforts that may impact required capacities of each this response.

of the above-discussed portable pumps are adequate to maintain core cooling and sub-criticality during phases 2 and 3 of ELAP. Confirm that the licensee has included a discussion and iustification

NL-15-059 Docket No. 50-286 Attachment 1 Page 11 of 39 Interim Staff Evaluation Confirmatory Status Items of computer codes/methods and assumptions used in the analyses above.

3.2.1.9.B Confirm that the licensee This item was closed during the October 2014 has provided an evaluation NRC Audit Visit (associated with AQ IPEC-036).

that demonstrates flow through a 2-inch connection will be sufficient to provide adequate flow to maintain the SG level using the alternate SG FLEX pump.

3.2.2.A Confirm that the licensee This item was closed during the October 2014 has satisfactorily explained NRC Audit Visit (associated with AQ IPEC-034).

the strategy to provide a secondary connection for SFP makeup if the building is inaccessible, and explain where these valves are and if access to these valves will be available during an ELAP event.

3.2.3.A Confirm that a containment This item is addressed by updated AQ response evaluation has been spreadsheet on the E Portal. (Unit 3 Open Item completed and, based on from the October 2014 NRC Audit Visit.)

the results of this evaluation; required Entergy Response Update to E Portal for actions to ensure Item 3.2.3.A for IPEC Unit 3 (02/27/2015) maintenance of To address the information requested by the containment integrity and NRC Audit Visit Report (ML14335A642) related required instrument to ISE Confirmatory Item 3.2.3.A, the following function will be developed, update to the response is provided for IPEC Unit 3:

The IPEC Unit 3 containment analysis has been revised to incorporate the leakage profile developed by applying PWROG-14015 Category 1 seal leakage rates and PWROG-14027 time period methodology to the IPEC FLEX cooldown timeline.

The results of the revised MAAP analysis for IPEC Unit 3 indicate that the containment

NL-15-059 Docket No. 50-286 Attachment 1 Page 12 of 39 Interim Staff Evaluation Confirmatory Status Items design pressure and design temperature, which values are 47 psig and 271OF respectively, will not be exceeded during Phase 1 or 2 of a FLEX event when the plant was initially in Modes 1-4.

As such, there are no coping strategies required for maintaining containment integrity during Phase 1 or 2. The only action necessary is to monitor containment pressure and temperature.

When the RCS is in Mode 5 or 6, the revised MAAP analysis indicates that a BDBEE event may challenge containment pressure unless a vent path is established. The vent path has been determined to require an equivalent flow to that of a 4" hole in containment and to be opened within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event to guarantee that containment will not pressurize sufficiently to challenge containment pressure or temperature design limits under the assumed worst case boil-off conditions. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is adequate time to ensure that a vent path is established.

Calculation IP-CALC-13-00081, Rev. 1, IP3 MAAP 4.0.5 Containment Analysis for an Extended Loss of all AC Power Event (ELAP),

January 2015, is available on the E Portal.

3.2.4.2.A Confirm that the This item is addressed by updated AQ IPEC-assessment of the 020 response. (Unit 3 Open Item from the predicted maximum October 2014 NRC Audit Visit.)

temperatures in rooms with equipment that is required Entergy Response Update to E Portal for for FLEX strategies during Items 3.2.4.2.A and 3.2.4.6.A (02/27/2015):

the ELAP demonstrates Additionally, to address the information that the equipment will requested by the NRC Audit Visit Report continue to function as (ML14335A642) related to ISE Confirmatory needed.

Item 3.2.4.2.A, the following update to the response is provided for IPEC Unit 3:

Control Room: Section 3.2.1.8 of NEI 12-06 states that the effects of loss of HVAC in an ELAP event can be addressed consistent with NUMARC 87-00 or by plant specific calculation utilizing software such as GOTHIC. Calculation IP-CALC-13-00065 utilized the methodology for temperature limits as defined in NUMARC 87-00 and modeled the control room using

NL-15-059 Docket No. 50-286 Attachment 1 Page 13 of 39 Interim Staff Evaluation Confirmatory Status Items GOTHIC. Section 2.7.1(a) of NUMARC 87-00 indicates the control room is considered a Condition 1 area. Per NUMARC 87-00, a Condition 1 area is considered of low concern with respect to elevated temperature effects as long as a steady state temperature of 1200 F is not exceeded. As documented in calculation IP-CALC-13-00065 the temperature of the control room did not exceed 1200 F for the length of the analysis. Although specific equipment temperature ranges are not referenced in this calculation, the equipment in the control room is considered acceptable via the referenced sections of NUMARC 87-00.

TDAFW Pump Room: Temperature switches are provided in the Auxiliary Feedwater Pump Room to close steam supply isolation valves PCV-1310A and PCV-1310B to prevent adverse environmental conditions resulting from a high energy line break. Switches (TC-1 112A and 1113A) isolate the steam supply to the TDABFP. Calculation IP-CALC-13-00064 justifies that the room heat-up, with the roll-up door opened at 30 minutes, stays below the switch setpoint for up to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> after the BDBEE and therefore adverse environmental conditions do not occur. For that reason the equipment in the Auxiliary Feedwater Pump Room is considered acceptable.

3.2.4.2.B Confirm that hydrogen This item was closed during the October 2014 concentration in the battery NRC Audit Visit (associated with AQ IPEC-047).

rooms during battery recharging would be maintained at an acceptable level.

3.2.4.3.A Confirm that the need for This item is addressed by updated AQ IPEC-heat tracing has been 021 response. (Unit 3 Open Item from the evaluated for the BAST October 2014 NRC Audit Visit.)

and all other equipment Entergy Response Update to E Portal for necessary to ensure that Item 3.2.4.3.A (02/27/2015):

all FLEX strategies can be Additionally, to address the information implemented successfully. requested by the NRC Audit Visit Report (ML14335A642) related to ISE Confirmatory Item 3.2.4.3.A, the following update to the

NL-15-059 Docket No. 50-286 Attachment 1 Page 14 of 39 Interim Staff Evaluation Confirmatory Status Items response is provided for IPEC Unit 3:

During the extreme cold situation in a postulated FLEX event, the FLEX connections at the various tanks proposed as sources for make-up may not be available (i.e., allow flow) due to internal ice formation. The problem is that the FLEX scenario involves an Extended Loss of AC Power (ELAP) which deactivates the heat trace (freeze protection) installed at the applicable tank connections. This heat trace is assumed not to be re-activated until power is restored to it from the FLEX diesel generator a maximum of eight (8) hours into the event. The piping extension from the tank and the first manual (CLOSED) isolation valve in the line will likely be filled with water, which can freeze without adequate insulation and/or heating.

Calculation IP-CALC-13-00058 Rev 1 evaluated the potential for the tank contents themselves to freeze during the BDBEE. The conclusions of these individual tanks calculations were that all sources of water will be available for a significant and sufficient period of time.

Also calculation IP-CALC-15-00007 Rev 0 evaluated the potential for ice formation in the FLEX connection piping from the tank to the isolation valve upon loss of heat tracing. This calculation found that in some cases, some ice would form on the inner wall of the piping during the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period wherein no heat trace was operating. However, in all cases it was concluded that the particular tank connection was available for its intended function.

The isolation valve at the connection will be initially closed. Some minor amount of water could be in the valve body or bonnet in such fashion that with internal icing, opening the said valve could be problematic. For IP3, the heat trace will be active for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (for the RWST and CST respectively) prior to the pumps beings connected for strategy compliance. During this time, it is anticipated that the active heat trace will thaw any ice formed in the valve body or bonnet and allow valve operation with no additional

NL-15-059 Docket No. 50-286 Attachment 1 Page 15 of 39 Interim Staff Evaluation Confirmatory Status Items components required. Use of the PWST and FWST FLEX connections is not credited until later in the event where the heat trace will be on for longer periods of time (at least 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> or later). For that reason these tanks are also acceptable for use. Note later analyses show credited at 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.

3.2.4.6.A Confirm that habitability This item was closed during the October 2014 limits will be maintained NRC Audit Visit (associated with AQ IPEC-020) and/or operator protective and 3.2.4.2A.

measures will be employed in all Phases of an ELAP to ensure operators will be capable of FLEX strategy execution under adverse temperature conditions.

Examples of areas of concern are the control room, TDABFW pump room, SFP area, and charging pump room.

3.2.4.9.A Confirm that method for This item was closed during the October 2014 supplying fuel oil has been NRC Audit Visit (associated with AQ IPEC-025).

finalized. Also confirm that the fuel required for each FLEX piece of equipment has been established and that the total fuel usage has been calculated to demonstrate that sufficient fuel with margin exists on site.

3.2.4.10.A Confirm that analysis of This item was closed during the October 2014 the following aspects of the NRC Audit Visit (associated with AQ IPEC-026).

dc power requirements have been identified and evaluated:

a. The dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool

NL-15-059 Docket No. 50-286 Attachment 1 Page 16 of 39 Interim Staff Evaluation Confirmatory Status Items cooling;

b. The loads that will be shed from the dc bus, the equipment location (or location where the required action needs to be taken), and the required operator actions and the time to complete each action

c. The basis for the minimum dc bus voltage that is required to ensure proper operation of all required electrical equipment.

3.4.A Confirm that the 480V This item was closed during the October 2014 portable/FLEX generators NRC Audit Visit (associated with AQ IPEC-031).

are adequately sized to supply loads assumed for implementing Phase 2 strategies.

October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit AdtLicensee Input Sau Item Item Description Needed Status Reference ISE Cl Containment The calculation This item is addressed on 3.2.3.A Evaluation of the conditions updated AQ response The calculation of the inside the spreadsheet on the E Portal.

conditions inside the containment containment building building was Entergy Response Update on E was done by the done by the Portal (02/27/2015) licensee with an licensee with an To address the information assumption of an assumption of an requested by the NRC Audit Visit initial leak rate of 21 initial leak rate of Report (ML14335A642) related to gallons per minute 21 gallons per ISE Confirmatory Item 3.2.3.A, (gpm) seal leakage minute (gpm) the following update to the per RCP. As the seal leakage per response is provided for IPEC RCP seal leakage RCP. As the Unit 3:

model has not been RCP seal

NL-1 5-059 Docket No. 50-286 Attachment 1 Page 17 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Item Item Description Needed Status Reference accepted yet by the leakage model The IPEC Unit 3 containment NRC staff, it is not has not been analysis has been revised to possible to perform a accepted yet by incorporate the leakage profile final evaluation of the NRC staff, it developed by applying PWROG-this calculation. is not possible to 14015 Category 1 seal leakage perform a final rates and PWROG-14027 time evaluation of this period methodology to the IPEC calculation. FLEX cooldown timeline.

The results of the revised MAAP analysis for IPEC Unit 3 indicate that the containment design pressure and design temperature, which values are 47 psig and 271OF respectively, will not be exceeded during Phase 1 or 2 of a FLEX event when the plant was initially in Modes 1-4. As such, there are no coping strategies required for maintaining containment integrity during Phase 1 or 2. The only action necessary is to monitor containment pressure and temperature to ensure that RCS leakage is minimal.

When the RCS is in Modes 5 or 6, the revised MAAP analysis indicates that a BDBEE event may challenge containment pressure unless a vent path is established. The vent path has been determined to require an equivalent flow to that of a 4" hole in containment and to be opened within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event to guarantee that containment will not pressurize sufficiently to challenge containment pressure or temperature design limits under the assumed worst case boil-off conditions. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is adequate time to ensure that a vent path is established.

NL-15-059 Docket No. 50-286 Attachment 1 Page 18 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Item Item Description Licensee Input Status Reference Calculation IP-CALC-13-00081, Rev. 1, 1P3 MAAP 4.0.5 Containment Analysis for an Extended Loss of all AC Power Event (ELAP), January 2015, is available on the E Portal.

ISE CI Room Temperatures The staff This item is addressed by 3.2.4.2.A The NRC staff needs requested the updated AQ IPEC-020 response additional information licensee to on the E Portal (see 3.2.4.2.A on the maximum provide electrical response above) predicted equipment temperatures in qualification for rooms where FLEX the temperatures equipment is reached in the operating, and the control room and equipment TDAFW pump temperature limits, to room.

confirm that there is no impact on equipment operation.

ISE Cl Heat Tracing The NRC staff This item is addressed by 3.2.4.3.A The NRC staff needs needs additional updated AQ IPEC-021 response additional information information on on the E Portal (see 3.2.4.3.A on the ability to use the ability to use above) outdoor tanks during outdoor tanks extreme cold during extreme conditions with no cold conditions operational heat with no tracing. operational heat tracing, especially when the use of the tank is delayed while FLEX equipment is deployed, and outdoor isolation valves must be opened.

AQ-27 Maintenance and The NRC staff This item is addressed by Testing of FLEX has concerns updated AQ IPEC-027 response Equipment that testing on the E Portal.

The NRC staff has procedures may

NL-15-059 Docket No. 50-286 Attachment 1 Page 19 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Item Item Description Needed Status Reference concerns that testing not have Entergy Response Update to E procedures may not sufficient details, Portal (02/2712015):

have sufficient such as To address the information details, such as acceptance requested by the NRC Audit Visit acceptance criteria criteria and shelf-Report (ML14335A642) related to and shelf-life life maintenance and testing of FLEX considerations for considerations equipment, the following update FLEX equipment, to for FLEX is provided:

identify when FLEX equipment, to equipment needs to identify when Entergy utilizes the EPRI be repaired or FLEX equipment preventive maintenance replaced. Also, the needs to be templates for FLEX as the licensee plans to repaired or foundation and "starting point" for extend certain replaced. Also, the Entergy Fleet PM Basis intervals between the licensee Templates identical to the testing longer than plans to extend process of INPO AP-913 for stated in the EPRI certain intervals critical components. The Entergy templates endorsed between testing Fleet PM Basis Templates for by the NRC. The longer than FLEX provide general guidance licensee will provide stated in the (just as with critical components) a report which EPRI templates that is then converted to model evaluates this endorsed by the Work Order instructions in the extension. NRC. The field. As such, these templates licensee will do not provide all the detail that provide a report would be found in the work which evaluates instructions derived from them.

this extension. The templates provide high order acceptance criteria such as pumps must meet or exceed pump curves, generators must meet or exceed prime ratings, cable insulation should not show any signs of cuts, nicks, tears, etc. This guidance is input to the work order instructions that implement the template requirements. Entergy continues to be an active member of the EPRI FLEX Industry PM working group. Shelf-life preventive maintenance guidance is currently under development with EPRI and has yet to be finalized.

However, Enterav has instituted

NL-15-059 Docket No. 50-286 Attachment 1 Page 20 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Item 1 Item Description Licensee Input Needed Status Reference shelf life preventive maintenance actions within the Entergy Fleet PM Basis Templates as follows pending finalization by EPRI:

• Battery Replacements every 4 years

• Cable exposed surface inspections every 1 year and tan-delta testing every 20 years (this guidance is endorsed by EPRI through the industry PM working group)

• Hose replacements every 10 years Entergy is extending the interval for "Functional Test and Inspection" tasks for engine driven subcomponents from 3 months to 6 months. This task is a fact finding task specific to engine availability to provide assurance that the engine will start and run. An integral component of the EPRI PM database is the capability to run vulnerability studies on stand-alone tasks to determine overall impact to assessing the risk to uncovering failure modes unique to that task. Entergy used the vulnerability tool to determine the increase in risk of detection of the associated failure modes and found the risk to be small (2%)

considering the capability of other tasks with unchanged frequencies to still vet those failure modes. This small increase in risk was determined acceptable and is documented in the associated Entergy PM Basis templates under "Justification for Deviation". It should also be

NL-15-059 Docket No. 50-286 Attachment 1 Page 21 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Item Item Description Needed Status Reference noted that this basis was supported by a document prepared by EPRI (Functional Test- Evaluation of Impact of Interval Extensions, dated 10/7/2014). Also of note, the industry in whole is endorsing this change in frequency from the base template and is doing so in concert with EPRI. It should be noted that this change process is consistent with the living PM process used by Entergy and employed throughout the industry for PM Programs on existing critical components. It is not required that EPRI endorse PM changes in intervals or specific details for subcomponents for any PM on critical components, but any changes made should be substantiated and justified with a technical basis by the licensee.

AQ-28 Offsite Resources The NRC staff This item is addressed by The NRC staff identified that a updated AQ IPEC-028 response identified that a revision is on the E Portal.

revision is needed to needed to procedure FSG-100 procedure FSG- Entergy Response Update on E in order for the 100 in order for Portal (02/27/2015):

licensee staff to the licensee staff To address the information reach the step to to reach the step requested by the NRC Audit Visit activate the offsite to activate the resource delivery. offsite resource therepor proAedure FSG- to revision ofofL procedure The licensee also delivery. The 100 and the SAFER Response needs to finalize the licensee also Plan, the following update to the SAFER Response needs to finalize ponse fovided:

Plan for Indian Point, the SAFER response is provided:

and finalize Response Plan Procedure FSG-100 was revised contractual for Indian Point, to add a step to activate the arrangements for the and finalize offsite resource delivery is in use of the offsite contractual progress.

staging areas. arrangements for Additionally the Indian Point the use of the Energy Center Response Plan is

NL-15-059 Docket No. 50-286 Attachment 1 Page 22 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Status Item Item Description Needed Reference offsite staging available on the E Portal.

areas.

AQ-46 Battery Room The NRC staff This item is addressed by Temperature requested the updated AQ IPEC-046 response Extremes licensee to on the E Portal.

The NRC staff needs provide a additional information technical basis to Entergy Response Update on E to evaluate the support the Portal (02/27/2015):

performance of the conclusion that As stated on the response plant batteries the battery provided on 08/28/2014 for IPEC considering the rooms would not Unit 3, the battery rooms are temperature exposed to located inside the control building extremes (hot and extreme high and would not be exposed to cold) that may be and low extreme high and/or low reached in the temperatures temperatures. Therefore, at the battery rooms. during the first onset of the event, the battery phase of the rooms would be at their normal ELAP event.

operating temperature and the temperature of the electrolyte in the cells would build up due to the heat generated by the batteries discharging and during re-charging. The duty cycle calculation IP-CALC-13-00056 assumes a minimum ambient temperature of 600F. This is the temperature of the battery room based on the existing HVAC system design basis. During the worst assumed low temperature environmental conditions, the FLEX strategy starts with a temperature of -15 0 F and equipment de-energized, therefore the heat contribution from the equipment will dwindle over time as the equipment cools down. Based on engineering judgment, considering the thickness of the walls shared with outside environment, the change in temperature inside the battery rooms would be negligible during

NL-15-059 Docket No. 50-286 Attachment 1 Page 23 of 39 October 2014 NRC Audit Visit FLEX Related ODen Items (Reference 13)

Audit Licensee Input Item Item Description Needed Reference Phase 1 (approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).

Therefore, it is reasonable to assume that the battery room will remain near its pre-event temperature during the first phase of the ELAP event until the FLEX generators are deployed and have energized the battery chargers. Once the battery charger is re- energized and is charging the battery, the charger is carrying the DC loads during Phase 2 and 3, which will provide some heating to the battery room.

During the worst assumed high temperature environmental conditions, the battery exhaust fans can be powered from the DC batteries which will maintain ventilation through Phase 1.

Calculation IP-CALC-13-00056, Rev. 0, Battery Sizing and Voltage Drop Calculation for Extended Loss of Power (ELAP),

is available on the E Portal.

i i i AQ-51 Use of Non-Safety- The NRC staff This item is addressed by Related Equipment requested the updated AQ IPEC-051 response The NRC staff needs licensee to on the E Portal.

information on the address non-use of non-safety- safety related Entergy Response Update on E related installed installed Portal (02/27/2015):

electrical equipment electrical Refer to SE#6 submittal of credited during an equipment 10/27/2014 for supplemental ELAP event and its credited for information ability to perform its mitigation safety function strategies and See response to SE #6 below.

considering the whether this To address the information potential external equipment will requested by the NRC Audit Visit hazards. survive the Report (ML14335A642) related to BDBEE. the use of non-safety related installed electrical equipment, the following update to the response is provided for IPEC Unit 3:

NL-15-059 Docket No. 50-286 Attachment 1 Page 24 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Item Item Description Needed Status Reference A review of all installed electrical equipment was performed using the load list shown in Report IP-RPT-13-00059. Based on this review, the only non-safety related components credited in the strategy are the heat trace systems associated with the RWST, CST, PWST and FWSTs, Battery Room Ventilation and the auxiliary HVAC system for the Control Room. The equipment associated with the heat trace is designed for cold temperatures and has operating temperature ranges that are below the -150 F extreme cold BDBEE. For that reason it is acceptable to credit the heat trace in the extreme cold BDBEE coping strategy. In addition, for the extreme high temperature BDBEE, the non-safety related auxiliary HVAC system is activated for long term Control Room habitability once the Phase 2 generator is connected. The Auxiliary HVAC units are Liebert Model DME037E which have a vendor rated outdoor temperature limit of 1150 F which matches the extreme high temperature beyond design basis external event.

SE#2 RCP Seal Leakage Provide final This item is addressed on and NSAL 14-1 resolution for this updated AQ response Westinghouse issue. spreadsheet on the E Portal.

nuclear safety advisory letter NSAL Entergy Response Update on E 1 indicates there Portal (02/27/2015):

may be higher Revise the 10/27/2014 response leakage from the for Items a, b and g as follows:

reactor coolant pump a. Revise "Indian Point Energy (RCP) seals during Center (IPEC) contracted with

NL-15-059 Docket No. 50-286 Attachment 1 Page 25 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input S Item Item Description Needed Status Reference an extended loss of Westinghouse to perform a ac power (ELAP) plant specific evaluation of the than was previously RCP seal leak-off using a analyzed. The methodology similar to that licensee proposed to used in the generic analysis limit leakage by performed for NSAL 14-1.

throttling existing The overall result is that the valves in the #1 seal FLEX strategy assumption of leakoff line. The NRC 21 gpm seal leakage is staff expressed expected to remain valid for concerns regarding Indian Point Units 2 and 3."

the licensee's The assumption of 21 gpm of proposal. The seal leakage per RCP is no licensee is working to longer the leakage rate resolve this issue, assumed in the strategy.

and is considering Indian Point Energy Center modifications to the (IPEC) contracted with plant. The NRC will Westinghouse to perform review the final plant specific evaluations to resolution. justify Indian Point Unit 3 as a Category 1 plant as reported in PWROG-14015-P, Rev. 1.

By making this category change, Indian Point is able to use the Category 1 plant results in subsequent analysis for cooldown and depressurization documented in PWROG-14027-P.

An analysis was done to justify Indian Point Unit 3 as a Category 1 plant via the installation of orifices.

Therefore, by applying such methods as installation of orifices, seal leakage rates for Indian Point Unit 3 will be in agreement with the seal leakage rates for Category 1 plants as presented on Table 4 of PWROG-14015-P, Rev.

1. The RCS makeup strategy revision includes a new time-dependent seal leakacie

NL-15-059 Docket No. 50-286 Attachment 1 Page 26 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Status Item Item Description Needed Reference profile based on PWROG-14027-P, Revision 1 results.

IPEC will continue to follow PWROG FLEX efforts that may impact this response.

b. Revise "As indicated above, Westinghouse is performing a plant specific seal leak-off evaluation for IPEC. The results include throttling of the

1. 1 Seal Leak-off Line rotameter isolation valves such that IPEC Units 2 and 3 can be classified as a Category 1 plant as indicated in PWROG-14015-P and subsequent phases of the PWROG Seal Leakage Program." to As indicated above, Indian Point Energy Center (IPEC) contracted with Westinghouse to perform plant specific evaluations which will justify Indian Point Units 2 and 3 as Category 1 plants as reported in PWROG-14015-P. By applying such methods as installation of orifices, seal leakage rates for Indian Point Units 2 and 3 will be in agreement with the seal leakage rates for Category 1 plants as presented on Table 4 of PWROG-14015-P, Rev. 1 and the methodology identified in PWROG-14027, Rev. 1. As a result the IP3 seal leakage rates are as follows:

1) Pre-cooldown period (0-30 minutes): 16.75 gpm/seal

2) Cooldown period (30

NL-15-059 Docket No. 50-286 Attachment 1 Page 27 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input S Item Item Description Needed Status Reference minutes- 180 minutes):

11.6 gpm/seal

3) Post-cooldown period (180 minutes - 6900 minutes): 5.7 gpm/seal

g. Revise "The plant modifications for reclassifying IPEC Unit 2 and 3 from Category 4 to Category 1 Plant are to throttle the rotameter isolation globe valves to increase the overall equivalent length of 3/4" schedule 160 piping of the #1 Seal Leak-off Line to 120.3 ft.

The time frame for completing the valve throttling will be no later than the FLEX outage schedule for each unit, per Order EA-12-049." to The plant modification for reclassifying IPEC Unit 3 from Category 4 to Category 1 Plant was the installation of orifices in the RCP seal leak off lines. Entergy installed an orifice on the seal leak off line during refueling outage 3R18 (spring 2015) that would align the leakage rates with the leakage rates from Category 1 plants as provided on Table 6 of PWROG-14015, Rev. 1.

Subsequent discussion is in the Margin Analysis SE #5 Accuracy of the Provide PWROG This item is addressed on NOTRUMP resolution on updated AQ response Computer Code accuracy of the spreadsheet on the E Portal.

Westinghouse used NOTRUMP the NOTRUMP code. Provide a Entergy Response Update on E computer code to comparison chart Portal (02/27/2015):

develop certain to compare how The PWROG resolution of timelines for operator the plant

NL-15-059 Docket No. 50-286 Attachment 1 Page 28 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Status Item Item Description Needed Reference actions in an ELAP parameters accuracy of the NOTRUMP code event (see WCAP- assumed in the is provided in PWROG-14064-P 17601-P for Westinghouse Revision 0 (Application of example). NRC analyses NOTRUMP Code Results for simulations using the compare to Westinghouse Designed PWRs in TRACE code Indian Point Extended Loss of AC Power indicate some parameters. Circumstances) and validates the differences, which use of NOTRUMP for ELAP may be significant events with restrictions identified enough to affect the regarding boron mixing, RCP seal timeline for operator leakage and reflux cooling. IPEC actions. The meets the identified restrictions Pressurized Water by unit-specific application of the Reactor Owners boron mixing NRC endorsement Group (PWROG) is letter dated January 8, 2014 working with the (ML13276A183, Boron Mixing NRC on a resolution, Endorsement Letter in regards to which may be Mitigation Strategies Order EA-applicable to all 12-049), PWROG-14015 PWRs. The NRC Revision 0 (No. 1 Seal Flow Rate staff also needs a for Westinghouse Reactor comparison chart Coolant Pumps Following Loss of from the licensee to All AC Power, Task 2: Determine compare how the Seal Flow Rates) and PWROG-plant parameters 14027 Revision 1 (No. 1 Seal assumed in the Flow Rate for Westinghouse Westinghouse Reactor Coolant Pumps analyses compare to Following Loss of All AC Power, Indian Point Task 3: Evaluation of Revised parameters. Seal Flow Rate on Time to Enter Reflux Cooling and Time at which the Core Uncovers).

A comparison chart to compare how the plant parameters assumed in the Westinghouse analyses compare to IPEC parameters for seal leakage and reflux cooling is provided in file "SE 5 Analysis Data Summary.docx" located on the E Portal.

SE #7 Operation of the SG The NRC staff This item is addressed on I ADVs has concerns updated AQ response

NL-15-059 Docket No. 50-286 Attachment 1 Page 29 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit Licensee Input Item Item Description Needed Status Reference The NRC staff has with the nitrogen spreadsheet on the E Portal.

concerns with the bottles used to nitrogen bottles used provide the Entergy Response Update on E to provide the motive motive force to Portal (02/27/2015):

force to operate the operate the SG Revise the 10/27/2014 response SG ADVs, needed ADVs, needed for Item 3 above as follows:

for plant cooldown. for plant The staff needs cooldown. Additionally, to address the additional information Provide information requested by the NRC on the capacity of the additional Audit Visit Report nitrogen bottles, and information on (ML14335A642) related to the what other the capacity of operation of the SG ADVs, the equipment uses the nitrogen following update to the response those bottles. bottles, and what is provided:

other equipment ADV and associated PRV uses those operation have adequate installed bottles. standby nitrogen bottles that are placed in service. IP-CALC 00059 (Nitrogen Backup to AFW Valves and Atmospheric Dump Valves for FLEX Event -IPEC 3) determined that the installed nitrogen bottles will provide the needed compressed air to maintain ADV operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for IP3. Additional bottles are stored in the FLEX Equipment Storage Building to provide an adequate nitrogen bottle supply for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, which allows adequate time to obtain additional nitrogen bottles (or portable air compressor) as needed.

Calculation IP-CALC-13-00059 is available on the E Portal.

SE #13 RCP Seal Leakage The NRC staff This item is addressed on Rates needs updated AQ response The NRC staff needs information to spreadsheet on the E Portal.

information to demonstrate that Entergy Response (10/27/2014):

demonstrate that the the current RCP IPEC is participating in the current RCP seal seal leakage rate PWROG RCP Working Group leakage rate calculation is under PA-SEE-i 196 and the calculation is accurate or accurate or conservative, response to this question will be

NL-15-059 Docket No. 50-286 Attachment 1 Page 30 of 39 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 13)

Audit it Licensee Input Item Item Description Needed Status Reference conservative, coordinated within this effort.

Subsequent discussion is in the Margin Analysis SE #14 Pressurization of the The NRC staff This item is addressed on RCP #1 Seal Leakoff has asked the updated AQ response Line licensee to spreadsheet on the E Portal.

The NRC staff has determine the Entergy Response Update asked the licensee to expected (02/27/2015):

determine the maximum To address the information expected maximum pressure in the requested by the NRC Audit Visit pressure in the #1 #1 seal leakoff Report (ML14335A642) related seal leakoff line line during this to the pressurization of the RCP during this event and event and to

1. 1 seal leakoff lines, the to demonstrate that demonstrate that following update is provided the components of the components this line will not fail in of this line will a. Figure 3 of PWROG-14015-P such a manner that not fail in such a Rev 1 shows the expected will increase the seal manner that will pressure response in the No.

leakage. increase the seal 1 Seal and Leak-off Line for leakage. a Category 1 plant. The expected maximum steady state pressure in the leak-off line up stream of the flow elements (e.g., restriction orifice) is less than 1000 psia. The pressure downstream of the flow element is on the order of 150 psig, which corresponds to the relief valve setting.

These values are less than the design values, so the leak-off line is expected to remain intact. The analysis for the leak-off rate assumes that the pressure downstream of the flow element (e.g., restriction orifice) goes to atmosphere, so even if the low pressure piping was to fail, the seal leakage rate will remain within analyzed values.

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Audit Licensee Input Status Item Item Description Needed Reference To address the potential pulse situation concern wherein the peak pressure /

temperature in the line may be high for a brief period of time before steady-state conditions assert themselves and pressures and temperatures stabilize at the more reasonable expected values described above, the 2045 psia peak pressure which was measured in the Montereau hot shock test (Appendix B to WCAP-10541) remains applicable to IPEC design. Therefore, because the seal leak off lines up to and including the location of the flow restricting orifice are designed for 2580 psig at 650 F and 2510 psig at 680 F, the potential pulse concern will not result in the seal leak off line failing and producing an increase in seal leakage.

IPEC continues to participate in industry initiatives for analyzing the expected maximum pressure (currently 2045 psia) in the seal leak off line during a loss of seal cooling event. It is expected that if the WCAP-10541 peak pressure is revised, IPEC will remain bounding based on the current margin to exceeding the design criteria discussed above.

Audit Completion Questions Status or Target Date IPEC-002 This item was closed during the October 2014 NRC Audit Closed

NL-15-059 Docket No. 50-286 Attachment 1 Page 32 of 39 Completion Audit Status or Target Questions Date Visit (associated with ISE Confirmatory Item 3.1.1.2.D).

This item was closed during the October 2014 NRC Audit IPEC-003 Visit. Closed This item was closed during the October 2014 NRC Audit Closed IPEC-004 Visit (associated with ISE Confirmatory Item 3.1.1.3.A).

This item was closed during the October 2014 NRC Audit Closed IPEC-005 Visit (associated with ISE Confirmatory Item 3.1.1.4.A).

This item was closed during the October 2014 NRC Audit Closed IPEC-006 Visit (associated with ISE Open Item 3.1.2.A and ISE Confirmatory Item 3.1.2.2.A).

IPEC-008 This item was closed during the October 2014 NRC Audit Closed Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-009 Visit.

Updated response available on the E Portal Entergy Response Update (02/27/2015):

The debris assessment has been finalized. The conclusions stated on the response update dated 08/28/2014 remain valid. Therefore, the removal of snow, ice, and debris can be cleared using heavy-duty debris IPEC-010 removal equipment (e.g., 4 Wheel Loader with fork blade Review ready and bucket attachment stored in the FLEX equipment storage building). Since the debris removal vehicles will be kept inside the FLEX equipment building, no procedures are required for the protection of the vehicles.

Furthermore, the NRC report for the onsite audit (ML14335A642), issued on December 9, 2014, closed this item.

Updated response available on the E Portal.

Entergy Response Update (02/27/2015):

FLEX equipment will be stored inside the FLEX Equipment Storage Building. Calculation IP-CALC-14-00033, IPEC-01 1 evaluated the FESB for the impacts of extreme heat Review ready conditions and determined that the peak indoor temperature within the first eight hours following the event is less than 106 0 F with no compensatory actions taken.

FLEX equipment is specified to tolerate storage under the high temperature conditions identified above.

Portable/FLEX equipment will be deployed and operated to

NL-15-059 Docket No. 50-286 Attachment 1 Page 33 of 39 Audit Completion Questions Status or Target Date locations outside of plant structures and buildings.

Therefore, the effects of high temperatures on the FLEX equipment have been addressed through the design requirement process, and development of specific procedures is not applicable. Furthermore, the NRC report for the onsite audit (ML14335A642), issued on December 9, 2014, closed this item.

This item was closed during the October 2014 NRC Audit Closed IPEC-012 Visit (associated with ISE Confirmatory Item 3.2.1 .A and ISE Confirmatory Item 3.2.1.1 .A).

This item was closed during the October 2014 NRC Audit Closed IPEC-013 Visit (associated with ISE Confirmatory Item 3.2.1.3.A).

This item was closed during the October 2014 NRC Audit Closed IPEC-014 Vst Visit.

IPEC-017 Updated response available on the E Portal (associated Review ready with ISE Confirmatory Item 3.2.1.9.A).

Updated response available on the E Portal (associated Review ready with ISE Confirmatory Item 3.2.4.2.A) (Unit 3 Open Item IPEC-020 from the October 2014 NRC Audit Visit.). Coe This item was closed during the October 2014 NRC Audit Visit (associated with ISE Confirmatory Item 3.2.4.6.A)

Updated response available on the E Portal (associated Review ready IPEC-021 with ISE Confirmatory Item 3.2.4.3.A) (Unit 3 Open Item from the October 2014 NRC Audit Visit.).

This item was closed during the October 2014 NRC Audit Closed IPEC-022 Visit.

Updated response available on the E Portal (associated Review ready IPEC-023 with ISE confirmatory Item 3.1.1.2.C).

This item was closed during the October 2014 NRC Audit Closed IPEC-025 Visit (associated with ISE Confirmatory Item 3.2.4.9.A)

This item was closed during the October 2014 NRC Audit Closed IPEC-026 Visit (associated with ISE Confirmatory Item 3.2.4.10.A)

Updated response available on the E Portal (Unit 3 Open Review ready IPEC-027 Item from the October 2014 NRC Audit Visit.).

Response available on the E Portal (Unit 3 Open Item from Review ready IPEC-028 the October 2014 NRC Audit Visit.).

This item was closed during the October 2014 NRC Audit Closed IPEC-029Visit.

NL-15-059 Docket No. 50-286 Attachment 1 Page 34 of 39 Audit Completion Questions Status or Target Date This item was closed during the October 2014 NRC Audit Closed Visit (associated with ISE Confirmatory Item 3.4.A)

This item was closed during the October 2014 NRC Audit IPEC-032 Visit. Closed This item was closed during the October 2014 NRC Audit Closed IPEC-033 Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-034 Visit (associated with ISE Confirmatory Item 3.2.2.A).

This item was closed during the October 2014 NRC Audit Closed Visit (associated with ISE Confirmatory Item 3.2.1.6.A).

This item was closed during the October 2014 NRC Audit Closed IPEC-036 Visit (associated with ISE Confirmatory Item 3.1.1.2.A).

This item was closed during the October 2014 NRC Audit Closed Visit (associated with ISE Confirmatory Item 3.2.1.9.B).

This item was closed during the October 2014 NRC Audit Closed IPEC-037 Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-041 Visit (associated with ISE Open Item 3.2.4.7.A and ISE Confirmatory Item 3.2.4.7.B).

IPEC-042 This item was closed during the October 2014 NRC Audit Closed Visit.

IPEC-043 This Vst item was closed during the October 2014 NRC Audit Closed Visit.

IPEC-045 This item was closed during the October 2014 NRC Audit Closed Visit.

IPEC Unit 3 - Updated response available on the E Portal Review ready IPEC-046 (Unit 3 Open Item from the October 2014 NRC Audit Visit.) - see above IPEC Unit 3 - This item was closed during the October Closed IPEC-047 2014 NRC Audit Visit (associated with ISE Confirmatory Item 3.2.4.2.B)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

This item was closed following the October 2014 NRC Closed IPEC-049a Audit Visit.

This item was closed following the October 2014 NRC Closed IPEC-049b Audit Visit.

IPEC-049c This item was closed during the October 2014 NRC Audit Closed

NL-15-059 Docket No. 50-286 Attachment 1 Page 35 of 39 Audit Completion Questions Status or Target Date Visit.

This item was closed following the October 2014 NRC Closed IPEC-049d Au'dit Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-049e Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-049f Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-049g Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-049h Visit.

This item was closed during the October 2014 NRC Audit Closed IPEC-049i Visit.

IPEC-050 Updated response available on the E Portal (associated Review ready with ISE Confirmatory Item 3.2.1.8.A).

Updated response available on the E Portal (Unit 3 Open Review ready IPEC-051 Item from the October 2014 NRC Audit Visit.).

• Closed indicates that Entergy's response is complete.

Margin Analysis At this time the PWROG continues to resolve issues over the amount of RCP seal leakage that would be expected during an extended loss of ac power (ELAP) for reactors with the standard Westinghouse seals. The IP3 OIP RCP seal leak rate profile and the analysis to validate the capability to maintain natural circulation core cooling used Westinghouse WCAP-1 7601. The PWROG generic analysis methodology and results included use of the 4-Loop Westinghouse reference plant identified in WCAP-17601. Subsequent to the OIP, the IP3 analyses have used the Category 1 plant (based on the installation of RCP seal line orifice) analysis results and mass balance methodology of PWROG-14015 and PWROG-14027 with plant specific parameters. Margins were achieved regarding resolution of leak rate by the use of generic parameters and results as follows:

To utilize the PWROG RCP seal leak rates for a Category 1 plant and apply the reflux cooling analysis methodology, the following actions were taken to support the IP3 FLEX strategy timeline:

1. IP3 analysis using plant-specific parameters determined accumulator mass injection and initial RCS mass were less than the PWROG generic analysis input parameters. As a result, an IP3 parameter specific calculation (Reference 17) determined the time to onset of reflux cooling using the mass balance methodology

NL-15-059 Docket No. 50-286 Attachment 1 Page 36 of 39 was 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> in place of the generic analysis result of 15.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Reference 15).

2. IP3 calculations using IP3 parameters and Category 1 RCP seal leak rates (References 14 and 15) plus 1 gpm unidentified RCS leakage were performed to determine the impact on RCS makeup inventory capability for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> (Referencel 8) and that containment pressure / temperature responses (Referencel 9) remain less than design parameters. Results were incorporated into the FLEX strategy (Reference 23).

3. Installation of a flow orifice in each RCP seal leak-off line during the 3R18 Refueling Outage under EC 54478 (Reference 20) was performed to characterize IP3 as a Category 1 plant with respect to RCP No. 1 seal leakage.

4. To confirm that the installation of orifices in the RCP leak-off lines ensure Category 1 performance, the IP3 specific seal leak-off piping configurations were analyzed in calculation IP-CALC-15-00017 (Reference 21). The leak rates determined in this calculation were lower than References 14 and 15, except at the lowest cited temperature and pressure conditions. At 375 0 F and 200 psia, the calculation found that flow choking occurs at the installed orifice at a flow rate of 3.5 gpm when conservatively not crediting relief valve backpressure of 150 psig. References 14 and 15 credited the relief valve backpressure and thus flow choking actually occurred at a flow rate of 0.7 gpm (Reference 22).

The time to the onset of Reflux Cooling Margin represents another area of margin. The Phase 2 Staffing Assessment contained in NL-2014-132 (Reference 8) identifies that RCS makeup will be started between 10 to 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. This is prior to the onset of reflux cooling at 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> as determined in Reference 17. This calculation and the IP3 FLEX strategy (Reference 23) contain the following conservative approaches different than the PWROG generic analysis that reported a time to onset of reflux cooling of 15.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Reference 15):

1. The IP3 analysis (Reference 17) uses IP3 parameters and therefore eliminates the concern of using non-conservative available RCS mass values.

2. The IP3 calculation (Reference 17) includes the loss of 1 gpm unidentified RCS leakage in addition to the Category 1 leak rate profile.

3. The IP3 FLEX strategy initiates plant cooldown 90 minutes earlier than the PWROG analysis.

4. The IP3 FLEX strategy cooldown is completed 60 minutes earlier than assumed in the PWROG analysis.

Subsequent to Reference 17, calculation IP-CALC-15-00035 (Reference 22) quantifies additional margin gained as a result of using the IP3 specific RCP seal leak-off values (Reference 21) applied to Reference 17 results instead of the PWROG generic seal leak rates. Calculation IP-CALC-15-00035 determined the time to onset of reflux cooling was

NL-15-059 Docket No. 50-286 Attachment 1 Page 37 of 39 14.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, using IP3 specific leak rates provide an additional 2.34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> to the Reference 17 result (11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />) for the onset of reflux cooling.

In summary, the FLEX strategy identifies that RCS makeup will be started between 10 to 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> (References 8 and 22) with the onset of reflux cooling occurring at 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.

Analyses and modifications ensure RCS makeup can be initiated prior to the onset of reflux cooling. Subsequently, using IP3 specific leak rates resulting from the orifice modification (Reference 20) provides an additional 2.34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> of margin added to the original 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of margin assuming RCS makeup is initiated at 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. Therefore, there exists 3.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of margin from the conservative latest initiation of RCS makeup at 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> until the onset of reflux cooling at 14.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, calculation IP-CALC-15-00035 (Reference 22) also identifies an increase in RCS makeup inventory availability (additional 18,519 gallons remaining after 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />), reduction in containment temperature (reduction of 17.2 0 F) and pressure (reduction of 1.3 psi) based on using the site-specific leak rates in place of the generic PWROG leak rates.

The design of the RCP#1 seal leakoff line versus the expected pressure profile provides margin. The RCP #1 seal leakoff line pressurization spike creates a potential for a ruptured line and increased RCS leak rate. As noted in response to SE#14, the potential pulse situation is a concern wherein the peak pressure / temperature in the line may be high for a brief period of time before steady-state conditions assert themselves and pressures and temperatures stabilize. The peak pressure of 2045 psia (measured in the Montereau hot shock test, Appendix B to WCAP-10541) remains applicable to IPEC. Because the #1 seal leak off lines up to and including the location of the flow restricting orifice are designed for 2580 psig at 650 OF and 2510 psig at 680 OF, there is margin to assure that the potential pulse concern will not result in the seal leak off line failing and producing an increase in seal leakage.

This issue is considered closed based on this information.

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

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 (ML12054A736).

2. Entergy Letter to NRC (NL-13-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (ML13079A348).

3. Entergy Letter to NRC (NL-13-110), Indian Point Energy Center's First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2013 (ML13247A032).

NL-15-059 Docket No. 50-286 Attachment 1 Page 38 of 39

4. Entergy Letter to NRC (NL-1 3-031), Indian Point Energy Center's Second Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated February 27, 2014 (ML14070A365).

5. Entergy Letter to NRC (NL-1 4-110), Indian Point Energy Center's Third Six-Month Status Report for the Implementation of Order EA-1 2-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2014 (ML14251A227).

6. Entergy Letter to NRC (NL-1 5-025), Indian Point Energy Center's Fourth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated February 27. 2015.

7. NRC Letter to Entergy, Indian Point Nuclear Generating Unit Nos. 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049 (Mitigation Strategies) (TAC Nos. MF0744 and MF0745), dated January 24, 2014 (ML13337A594).

8. Entergy Letter to NRC (NL-14-132) Regarding Response to March 12, 2012, Request for Information (RFI) Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dia-ichi Accident, Enclosure 5 Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated November 3, 2014 (ML14328A631).

9. Entergy Letter to NRC (NL-13-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (ML13079A348).

10. NRC Letter to Entergy Regarding Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies AND Reliable Spent Fuel Instrumentation Related To Orders EA-12-049 and EA-12-051 (TAC NOS. MF0744, MF0745, MF07371 AND MF0738), dated September 30, 2014 (ML14269A384).

11. 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).

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

13. NRC Letter to Entergy Regarding Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation

NL-15-059 Docket No. 50-286 Attachment 1 Page 39 of 39 Related to Orders EA 12-049 and EA 12-051 (TAC Nos. MF0744, MF0745, MF0737 and MF0738), dated December 9, 2014 (ML14335A642).

14. Westinghouse Report PWROG-14015-P, Rev. 1, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power, September 19, 2014.

15. Westinghouse Report PWROG-142027-P, Rev 2, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power Task 3, October, 2014.

16. WCAP-17601 -P, Rev. 1, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock and Wilcox NSSS Designs

17. IP-CALC-15-00003, Rev. 0, IP3 Time to Reflux Cooling Calculation

18. IP-CALC-14-00012, Rev. 0, 1P3 RCS Inventory Evaluation for FLEX

19. IP-CALC-13-00081, Rev. 1, IP3 MAAP 4.0.5 Containment Analysis for an Extended Loss of all AC Power Event (ELAP)

20. EC 54478, Rev. 1, Installation of an Orifice Plate on the Outlet Flange of Flow Meters FIT-156B, -157B, -158B, -159B

21. IP-CALC-15-00017, Rev. 0, (Westinghouse Number CN-SEE-1-15-2 Rev 0): Indian Point Reactor Coolant Pump Seal Leakoff Analysis with Flow Restricting Orifice

22. IP-CALC-15-00035, Rev.0, Margin Gained in the Results of Applicable FLEX Calculations Using Input from IP-CALC-15-00017

23. EC 45874, Rev. 1, IP3 FLEX Strategy Development

ATTACHMENT 2 TO NL-15-059 INDIAN POINT 3

SUMMARY

OF COMPLIANCE BASES FOR ORDER EA-12-051 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

NL-15-059 Dockets 50-247 and 50-286 Attachment 2 Page 1 of 3 Indian Point Unit Three's Compliance Letter for the Implementation of Order EA-12-051 Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Reference 1) to Entergy. This Order was effective immediately and Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (OIP) (Reference 2) for Indian Point Energy Center (IPEC), documenting the Reliable Spent Fuel Pool Instrumentation requirements. The Order required compliance prior to plant startup from the second refueling outage following submittal of the OIP, or by December 31, 2016, whichever comes first. The compliance date for Indian Point 3 (IP3) was March 24, 2015. The NRC staff requested that the compliance report be submitted within 60 days of the compliance date. The information provided herein documents full compliance for Indian Point 3 in response to the Order.

COMPLIANCE IP3 has installed two independent full scale level monitors on the Unit 3 Spent Fuel Pool (SFP) in response to Reference 1. Indian Point Energy Center (IPEC) is a three unit site with Unit 1 decommissioned with an empty spent fuel pool and Units 2 and 3 each have a separate and associated spent fuel pool.

Entergy submitted the IP3 OIP by letter dated February 27, 2013 (Reference 2). Entergy responded to an NRC request for additional information (Reference 4) by letter dated August 20 2013 (Reference 5). The NRC letter of November 8, 2013 (Reference 6), the NRC provided its interim staff evaluations and requested additional information necessary for completion of the review. This information was provided in the Entergy Status reports (References 7, 8, 9, and 10). The NRC conducted an Audit of the Entergy responses to Orders EA-12-049 and EA 051 and documented the results in Reference 11. Reference 10 contained a summary of the responses provided:

RAI # IP3 Response Status IP3 Review Status 1 Submitted in Reference 7 Closed During NRC Audit (Reference 11) 2 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 3 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 4 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 5 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 6a Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 6b Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 6c Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 7 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11)

NL-15-059 Dockets 50-247 and 50-286 Attachment 2 Page 2 of 3 8 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 9 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 10 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 11 Submitted in Reference 9 Closed During NRC Audit (Reference 11) 12 Submitted in Reference 9 Closed During NRC Audit (Reference 11) 13 Uploaded to e-portal September 30, 2014 Closed During NRC Audit (Reference 11) 14 Submitted in Reference 10 (See Note) Reference 10 Section 9 (See Note) 15a Submitted in Reference 9 Closed During NRC Audit (Reference 11) 15b Submitted in Reference 9 Closed During NRC Audit (Reference 11) 16 Submitted in Reference 10 Closed During NRC Audit (Reference 11) 17 Submitted in Reference 10 Closed During NRC Audit (Reference 11) 18a Submitted in Reference 10 (See Note) Reference 10 Section 9 (See Note) 18b Submitted in Reference 10 (See Note) Reference 10 Section 9 (See Note) 18c Submitted in Reference 10 (See Note) Reference 10 Section 9 (See Note)

Note: These RAIs were listed as Open Items in the NRC Audit Visit Report (Reference 11).

Compliance with Order EA-12-051 was achieved using the guidance in Nuclear Energy Institute (NEI) document NEI 12-02 (Reference 3) which has been endorsed by the NRC (Reference 12).

REFERENCES

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A682).

2. Entergy Letter to NRC (NL-13-043), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 27, 2013 (ML13072A082).

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation",

Revision 1, dated August 2012.

4. NRC Letter Requesting Additional Information Regarding Reliable Spent Fuel Pool Instrumentation, Order no. EA-12-051 (TAC Nos. MF0737 and MF0738), dated June 25, 2013 (ML13169A127).

5. Entergy Letter to NRC (NL-13-103) Response to Request for Additional Information (RAI) Regarding Reliable Spent Fuel Pool (SFP) Instrumentation (Order No, EA-12-051) (TAC NOS. MF0737 and MF0738) dated August 20, 2013 (ML13239A238).

6. NRC Letter to Entergy Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0737 and MF0738), Dated November 8, 2013. (ML13298A805).

7. Entergy Letter to NRC (NL-1 3-109), Indian Point Energy Center's First Six-Month

NL-15-059 Dockets 50-247 and 50-286 Attachment 2 Page 3 of 3 Status Report for the Implementation of Order EA-12-051 Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0737 and MF0738), dated August 27, 2013 (ML13247A031).

8. Entergy Letter to NRC (NL-14-029), Indian Point Energy Center's Second Six-Month Status Report for the Implementation of Order EA-12-051 Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0737 and MF0738), dated February 27, 2014 (ML14070A447).

9. Entergy Letter to NRC (NL-14-109), Indian Point Energy Center's Third Six-Month Status Report for the Implementation of Order EA-12-051 Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0737 and MF0738), dated August 27, 2014 (ML14251A226).

10 Entergy Letter to NRC (NL-1 5-026), Indian Point Energy Center's Fourth Six-Month Status Report for the Implementation of Order EA-1 2-051 Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0737 and MF0738), dated February 26, 2015. (ML15069A028).

11. NRC Letter to Entergy Regarding Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA 12-049 and EA 12-051 (TAC Nos. MF0744, MF0745, MF0737 and MF0738), dated December 9, 2014 (ML14335A642).

12. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 (ML12221A339).