NL-15-112, Fifth 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

Fifth 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

ML15246A119
Person / Time
Site:	Indian Point
Issue date:	08/28/2015
From:	Coyle L Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-112, TAC MF0744, TAC MF0745
Download: ML15246A119 (17)

Text

Entergy Nuclear Northeast

--Entergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-1 12 August 28, 2015 U.S. Nucl ear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

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

Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

REFERENCES:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with .Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

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

Implementation Guide, Revision 0, dated August 2012

4. Entergy letter to NRC (NL-12-144), Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated October 29, 2012

5. Entergy letter to NRC (NL-1 3-042), 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

6. Entergy letter to NRC (NL-13-1 10), 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 A st

NL-15-1 12 Dockets 50-247 Page 2 of 3 (ML13247A032) 7 Entergy letter to NRC (NL-14-031), 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) 8 Entergy letter to NRC (NL-14-1 10), Indian Point Energy Center's Third 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, 2014 (ML14251A227) 9 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 26, 2015 (ML15069A028) 10 Entergy letter to NRC (NL-1 5-059), 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 to Requirements for Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0745 and MF0738) Indian Point Unit Number 3, dated May 20, 2015 (ML15149A140).

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

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

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Entergy initial status report regarding mitigation strategies.

Reference 5 provided the Entergy overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first six-month status report.

Reference 7 provided the second six-month status report. Reference 8 provided the third six-month status report. Reference 9 provided the fourth six-month status report.

The purpose of this letter is to provide the fifth six-month status report pursuant to

NL-15-1 12 Dockets 50-247 Page 3 of 3 Section IV, Condition 0.2, of Reference 1 that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. This update is applicable to IPEC Unit 2 only. IPEC Unit 3 has completed the Order requirements and has reported compliance to the Commission (Reference 10).

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Affairs at (914) 254-6710.

I declare un~der penalty of perjury that the foregoing is true and correct; executed on August ,*_ 2015.

Attachment:

Indian Point Energy Center's Fifth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Mr. Douglas V. Pickett, senior Project Manager, NRC NRR DORL Mr. 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 Ms. Bridget Frym ire, New York State Mr. Robert J. Fretz Jr., NRC NRR OE OB-Mr. Robert L. Dennig, NRC NRR DSS SCVB Ms. Jessica A. Kratchman NRC NSIR DPR DDEP IRIB.

Mr. Eric E. Bowman, NRC NRR DPR PGCB Ms. Eileen M. Mckenna, NRC NRO DSRA BPTS NRC NRR DSS SCVB

ATTACHMENT TO NL-15-1 12 INDIAN POINT ENERGY CENTER'S FIFTH SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-049 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NOS. 50-247

NL-15-1 12 Docket 50-247 Attachment Page 1 of 13 Indian Point Energy Center's Fifth Six Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Indian Point Energy Center (IPEC), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 8), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Entergy submitted a Notification of Full Compliance with Order EA-12-049 for IPEC Unit 3 on May 20, 2015 (Reference 9). The notification stated that:

Attachment 1 [of the Notification of Full Compliance letter] provides a brief summary of the key elements associatedwith 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 3), 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, Entergy considers these items complete pending NRC closure. [Note: the references in the text above refer to references in the notification letter.]

Therefore, this Six Month Status Report addresses only those open items associated with IPEC Unit 2.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31, 2015, and are current as of July 31, 2015:

• Fourth Six-Month Status Report - February 2015

• Notification of Full Compliance for IPEC Unit 3 - May 2015

• Fifth Six Month Status Report - Complete with submission of this document in August 2015 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The milestone listing includes only IPEC Unit 2.

These new milestone target completion dates do not impact the Order implementation date.

NL-15-1 12 Docket 50-247 Attachment Page 2 of 13 Target Revised Target Milestone Completion Activity Status Completion Date* Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Submit Six Month Updates

• Update 1 Aug 2013 Complete Update 2 -Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Perform Staffing Analysis Nov 2014 Complete Off-site FLEX Equipment Develop Strategies with NSRC Oct 2015 Started Procedures PWROG issues NSSS-specific Jan 2014 Complete Issued guidelines May 2013 Modifications Engineering and Implementation N-i Walkdown (Unit 2) Spring 2014 Completed Design Engineering June 2015 Completed Unit 2 Implementation Outage Apr 2016 Not Started Validation I Demonstration Oct 2015 Not Started Yes On-site FLEX Equipment Purchase / Procure Dec 2015 Started Procedures Create Indian Point FSG April 2016 Started Yes Create Maintenance Oct 2015 Started Procedures Training:

Develop Training Plan Aug 2015 Complete Implement Training April 2016 Not Started Submit Completion Report June 2016 Not Started IPEC Unit 2

NL-15-1 12 Docket 50-247 Attachment Page 3 of 13

• - Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at IPEC, changes have been identified to the compliance strategies as described in the original OIP (Reference

1) and in previous correspondence (References 3, 5, 6 and 8).

Lighting panels are not credited based on not being evaluated robust for a seismic event. Lighting during Phase 1 is limited to the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery backed emergency lights and portable flashlights and lanterns. For Phase 2, lighting can be provided by portable, diesel powered lighting towers. For the Central Control Room (CCR), flashlights stored in the CCR and portable lighting stored in the FLEX Equipment Storage Building are the credited lighting for the CCR.

• For IPEC Unit 2, if the CST and instrument air are unavailable following the BDBEE (missile event), operation of PCV-1 188 (City Water Storage Tank (CWST) to suction of the Turbine Driven Auxiliary Boiler Feedwater Pump (TDABFP)) from the Central Control Room is maintained by installed nitrogen backup and an alternate power supply until a manual blocking device is installed to maintain PCV-1 188 open to align the CWST to the suction of the TDABFP.

Based on nitrogen usage for valve operation, sufficient nitrogen is available to maintain PCV-1 188 open for several hours. Conservatively, the manual blocking device is installed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, eliminating a need for a subsequent nitrogen supply to maintain the CWST available to the suction of the TDABFP.

• On Page 44 of the OIP, it is stated, "Additional equipment may be requi'red to be powered during this event such as portable lighting and ventilation fans. These are not conveniently powered via the FLEX generator." For IPEC Unit 2 the CCR HVAC system is not credited but it is expected to survive the extreme high temperature BDBEE, therefore for this case, ventilation to the CCR can be restore via the Phase 2 FLEX generator.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation IPEC expects to comply with the order implementation date for IPEC Unit 2. IPEC Unit 3 is already in compliance with Order EA-12-049 (Reference 9).

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation For IPEC Unit 3, the following list of 12 open items, included in the NRC Report for the Onsite Visit (Reference 7), were addressed in the Notification of Full Compliance (Reference 9), Attachment 1.

1. ISE CI 3.2.3.A

2. ISE CI 3.2.4.2.A

3. ISE CI 3.2.4.3.A

4. AQ- 27

NL-15-1 12 Docket 50-247 Attachment Page 4 of 13

5. AQ -28

6. AQ -46

7. AQ-51

8. SE#2

9. SE#5

10. SE #7

11. SE #13

12. SE #14 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) for IPEC Unit 2. A fourth table includes a listing of all Audit Questions and the status of each item applicable specifically to IPEC Unit 2 This table also includes a list of the Combined SE Template Technical Review Gaps (Audit Item SE #) and the status of each item applicable to IPEC Unit 2.

Overall Integrated Plan Open Item Status There were no open items documented in the IPEC Overall N/A Integrated Plan Interim Staff Evaluation Open Items IPEC Unit 2 Status 3.1 .2.A Review of the licensee's new flooding level This item is addressed by evaluation results and its potential impact on the AQ IPEC-006 response.

flooding hazard analyses previously provided in their Integrated Plan and during the audit process is identified as an Open Item. If the 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 guidance only credits This item is addressed by water supplies that are robust with respect to AQ IPEC-041 response.

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.

Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status

NL-15-1 12 Docket 50-247 Attachment Page 5 of 13 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status 3.1.1.2.A Confirm that at least one connection point for This item was closed the FLEX AFW pump is accessible and is during the October 2014 located inside a building that is seismically NRC Audit Visit robust as described in Consideration 2 of NEI (associated with AO 12-06, Section 5.3.2. IPEC-002 and IPEC-036).

3.1.1 .2.B Confirm that the pickup trucks, forklifts or any This item was closed other equipment that will be used to deploy the during the October 2014 portable equipment for implementing FLEX NRC Audit Visit.

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 made to ensure that This item is addressed by access to all required areas will be assured in updated AO IPEC-023 the event of a power failure as described in response.

Consideration 5 of NEI 12-06, Section 5.3.2.

3.1.1 .2.D Confirm that the licensee has reviewed the This item was closed deployment paths from the near site storage during the October 2014 areas to the site and from the onsite storage NRC Audit Visit areas to the deployment location to verify that (associated with AO these paths are not subject to soil liquefaction IPEC-002).

concerns as described in Consideration 1 of NEI 12-06, Section 5.3.2.

3.1.1 .3.A Confirm that the licensee's review of the This item is addressed by potential impacts of large internal flooding AQ IPEC-004 response.

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 intermediate staging area has This item was closed been selected and implementing procedures during the October 2014 have been developed. NRC Audit Visit (associated with AQ IPEC-005).

3.1 .2.2.A Confirm that evaluations address: whether This item is addressed by procedures have been established for actions to AQ IPEC-006 response.

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 performed in WCAP- This item was closed

_______17601-P is being applied to Indian Point. Also following the October

NL-15-1 12 Docket 50-247 Attachment Page 6 of 13 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status confirm the licensee has adequately justified the 2014 NRC Audit Visit as use of that analysis by identifying and documented in evaluating the important parameters and Reference 7 (associated assumptions demonstrating that they are with AQ IPEC-012).

representative of Indian Point and appropriate for simulating the ELAP transient.

3.2.1.1 .A Confirm that the licensee is using NOTRUMP This item was closed and has taken into account its limitations, following the October Reliance on the NOTRUMP code for the ELAP 2014 NRC Audit Visit as analysis of Westinghouse plants is limited to the documented in flow conditions prior to ref lux condensation Reference 7 (associated initiation. This includes specifying an acceptable with AQ IPEC-012).

definition for reflux condensation cooling.

3.2.1 .3.A Confirm that the licensee has satisfactorily This item is addressed by addressed the applicability of Assumption 4 on AQ IPEC-013 response.

page 4-13 of WCAP-17601 which states that decay heat is per ANS 5.1-1 979 + 2 sigma, or equivalent. Ifthe ANS 5.1-1 979 + 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 has finalized its This item is addressed by strategy for controlling the RCS pressure to AQ IPEC-035 response.

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 NRC a position This item is addressed by paper, dated August 15, 2013, which provides updated AQ IPEC-050 test data regarding boric acid mixing under response.

single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. During the

NL-15-1 12 Docket 50-247 Attachment Page 7 of 13 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

3.2.1 .9.A Confirm that the licensee has specified the This item- is addressed by required time for the operator to realign each of updated AQ IPEC-017 the above discussed pumps and confirm that response.

the required times are consistent with the results of the ELAP analysis. Confirm that the licensee discussed the analyses that are used to determine the required flow rate and corresponding total developed head for each of the portable pumps and also to justify that that the required capacities of each 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 justification of computer codes/methods and assumptions used in the analyses above.

3.2.1 .9.B Confirm that the licensee has provided an This item is addressed by evaluation that demonstrates flow through a 2- AQ IPEC-036 response.

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 has satisfactorily This item is addressed by explained the strategy to provide a secondary AQ IPEC-034 response.

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 evaluation has been This item is addressed by completed and, based on the results of this updated AQ response evaluation; required actions to ensure spreadsheet on the maintenance of containment integrity and ePortal.

required instrument function will be developed.

3.2.4.2.A Confirm that the assessment of the predicted This item is addressed by maximum temPeratures in rooms with updated AQ IPEC-020 equipment that is required for FLEX strategies response.

during the ELAP demonstrates that the equipment will continue to function as needed.

3.2.4.2.B Confirm that hydrogen concentration in the This item is addressed by

NL-15-1 12 Docket 50-247 Attachment Page 8 of 13 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status battery rooms during battery recharging would updated AQ IPEC-047 be maintained .at an acceptable level, response.

3.2.4.3.A Confirm that the need for heat tracing has been This item is addressed by evaluated for the BAST and all other equipment updated AQ IPEC-021 necessary to ensure that all FLEX strategies response.

can be implemented successfully.

3.2.4.6.A Confirm that habitability limits will be maintained This item is addressed by and/or operator protective measures will be updated AQ I PEC-020 employed in all Phases of an ELAP to ensure response.

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.

3.2.4.7.B Confirm that the licensee has evaluated the This item was closed acceptability of the missile protection for the during the October 2014 Unit 2 BAST. NRC Audit Visit (associated with AQ IPEC-041).

3.2.4.9.A Confirm that method for supplying fuel oil has This item is addressed by been finalized. Also confirm that the fuel updated AQ IPEC-025 required for each FLEX piece of equipment has response.

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 the following aspects of This item is addressed by the dc power requirements have been identified updated AQ IPEC-026 and evaluated. response.

a. The dc load profile with the required loads for the mitigating st~rategies to maintain core cooling, containment, and spent fuel pool 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 portable/FLEX This item is addressed by generators are adequately sized to supply loads AQ IPEC-031 response.

assumed for implementing Phase 2 strategies.

NL-15-1 12 Docket 50-247 Attachment Page 9 of 13 Audit IPCUi ttsCompletion or Questions IPCUi ttsTarget Date This item was closed during the October 2014 NRC IPEC-002 Audit Visit (associated with ISE Confirmatory Item Closed 3.1.1.2.D)

IPEC-003 Response available on the ePortal. Review ready This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-004 3.1.1 .3.A. The preceding table provides the status to this ISE Confirmatory Item.

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

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Open Item 3.1.2.A..

IPEC006 The preceding table provides the status to this ISE Open Item.

IPEC-008 Response available on the ePortal. Review ready IPC-09 This item was closed during the October 2014 NRC Closed Audit Visit.

IPECOlO Resonseavalabe onthee~otal.Revew ead IPEC-0l10 Response available on the ePortal. Review ready This item was closed during the October 2014 NRC Closed IPEC012 Audit Visit to its associated ISE Confirmatory Item 3.2.1 .A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPECOl ~3.2.1 .3.A. The preceding table provides the status to this ISE Confirmatory Item.

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

This item was closed during the October 2014 NRC Review ready Audit Visit to its associated ISE Confirmatory Item IPEC-017 3.2.1.9.A. The preceding table provides the status of these ISE Confirmatory Item.

NL-15-1 12 Docket 50-247 Attachment Page 10 of 13 Audit IPCUi ttsCompletion or Questions IPCUi ttsTarget Date This item was closed during the October 2014 NRC Closed IPEC-020 Audit Visit to its associated ISE Confirmatory Item 3.2.4.6.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-021 3.2.4.3.A. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-022 Response available on the ePortal. Review ready IPEC-023 Updated Response available on the ePortal. Review ready This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-0253.2.4.9.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-026 3.2.4.10.A. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-027 Response available on the ePortal. Review ready IPEC-028 Updated response available on the ePortal. Review ready IPEC-029 Updated response available on the ePortal Review ready This item was closed during the October 2014 NRC Closed IPEC031 Audit Visit to its associated ISE Confirmatory Item 3.4.

- The preceding table provides the status to this ISE Confirmatory Item.

IPEC-032 Response available on the ePortal Review ready IPEC-033 Updated response available on the ePortal Review ready This item was closed during the October 2014 NRC Closed IPEC034 Audit Visit to its associated ISE Confirmatory Item 3.2.2.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed IPEC035Audit Visit to its associated ISE Confirmatory Item 3.2.1.6.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed IPEC-036 Audit Visit to its associated ISE Confirmatory Item 3.2.1.9.B. The preceding table provides the status to

NL-15-1 12 Docket 50-247 Attachment Page 11 of 13 Audit IPCUi ttsCompletion or Questions IPCUi ttsTarget Date this ISE Confirmatory Item.

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

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Open Item 3.2.4.7.A.

IPEC-041 The preceding table provides the status to this ISE Open Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-042 3.2.4.3.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-043 3.2.4.3.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-045 3.2.4.2.A. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-046 Response available on the ePortal Review ready This item was closed during the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item IPEC-047 3.2.4.2.B. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-048 Response available on the ePortal Review ready IPEC-049a Response available on the ePortal. Review ready IPEC-049b Response available on the ePortal. Review ready IPEC-049c Response available on the ePortal. Review ready IPEC-049d Response available on the ePortal. Review ready IPEC-049e Response available on the ePortal. Review ready IPEC-049f Response available on the ePortal. Review ready IPEC-049g Response available on the ePortal. Review ready IPEC-049h Response available on the ePortal. Review ready IPEC-049i Response available on the ePortal. Review ready IPEC-050 This item was closed following the October 2014 NRC Closed Audit Visit to its associated ISE Confirmatory Item

NL-15-1 12 Docket 50-247 Attachment Page 12 of 13 Audit IPCUi ttsCompletion or Questions IPCUi ttsTarget Date 3.2.1.8.A. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-051 Updated response available on the ePortal Review ready SE #1 Updated response available on the ePortal. Review ready SE #2 Response available on the ePortal. Review ready SE #4 Response available on the ePortal. Review ready SE #5 Response available on the ePortal. Review ready SE #6 Response available on the ePortal. Review ready SE #7 Updated response available on the ePortal. Review ready SE #8 Response available on the ePortal. Review ready SE #9 Response available on the ePortal. Review ready SE #10 Response available on the ePortal. Review ready SE #11 Response available on the ePortal. Review ready SE #12 Response available on the ePortal. Review ready SE #13 Response available on the ePortal. Review ready SE #14 Response available on the ePortal. Review ready SE #15 Response available on the ePortal. Review ready SE #16 Response available on the ePortal. Review ready SE #17 Response available on the ePortal. Review ready 7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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

1. Entergy letter to NRC (NL-1 3-042), 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

NL-15-1 12 Docket 50-247 Attachment Page 13 of 13

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

3. Entergy letter to NRC (NL-13-1 10), 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

4. 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-12-049 (Mitigation Strategies) (TAC Nos. MF0744 and MF0745), dated January 24, 2014

5. Entergy letter to NRC (NL-14-031), 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)

6. Entergy letter to NRC (NL-1 4-1 10), Indian Point Energy Center's Third 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, 2014 (ML14251A227).

7. Indian Point Nuclear Generating Unit Nos. 2 and 3 - 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)

8. Entergy letter to NRC (NL-15-025), 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 26, 2015 (ML15069A028).

9. Entergy letter to NRC (NL-1 5-059), 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 to Requirements for Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0745 and MF0738) Indian Point Unit Number 3, dated May 20, 2015 (ML15149A140).