Text

Center'S Sixth 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
	ML16067A091
Person / Time
Site:	Indian Point
Issue date:	02/29/2016
From:	Coyle L; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, NL-16-024, TAC MF0744
	Download: ML16067A091 (22)
	v • d • e

Entergy Nuclear Northeast SEntergy 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-1 6-024 February 29, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 Fl Rockville, MD 20852-2738

SUBJECT:

Indian Point Energy Center's Sixth 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)

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-12-049), 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-12-049), dated February 28, 2013.

6. 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), ,**

NL-1 6-024 Dockets 50-247 Page 2 of 3 dated August 27, 2013 (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-14-110), 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).

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 5-1 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 (TAC Nos. MF0744 and MF0745),

dated August 28, 2015 (ML15246A119).

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

12 NRC letter to Entergy Regarding Report for the Onsite Audit for Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA 051 (CAC Nos. MF0744 and MF0737), dated February 26, 2016.

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.

NL-1 6-024 Dockets 50-247 Page 3 of 3 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. References 6 to 10 provided the first through fifth six-month status reports. The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements~of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

The most recent NRC audit report, Reference 12, has been reflected. The update is applicable to IPEC Unit 2 only. IPEC Unit 3 has completed the Order requirements and has reported compliance to the Commission (Reference 11).

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 under penalty of perjury that the foregoing is true and correct; executed on February ~4 06 Atcmn:Indi n Poir~Energy Center's Sixth Six-Month Status Report for the Imp ation of Order EA-12-049 Modifying Licenses with Regard to a~nme 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 Frymire, 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-16-024 INDIAN POINT ENERGY CENTER'S SIXTH 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 NO. 50-247

N L- 16-024 Dockets 50-247 Attachment Page 1 of 18 Indian Point Energy Center's Sixth 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 I 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 10), 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 I [of the Notification of Full Compliance letter] provides a brief summary of the key elements associated with compliance to OrderEA-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, Energy 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 August 1, 2015, and are current as of January 31, 2016:

Fifth Six Month Status Report - August 2015

Sixth Six Month Status Report - Complete with submission of this document in February 2016 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-1 6-024 Dockets 50-247 Attachment Page 2 of 18 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 Complete Perform Staffing Analysis Nov 2014 Complete Off-site FLEX Equipment Develop Strategies with NSRC Oct 2015 Complete 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 / Demonstration Nov 2015"* Completed Yes On-site FLEX Equipment Purchase / Procure Dec 2015 Completed Procedures Create Indian Point FSG April 2016 Started Create Maintenance Oct 2015 Started Procedures Training:

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

- Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports

NL-16-024 Dockets 50-247 Attachment Page 3 of 18

- - Completion was as noted but additional validation was scheduled as rework 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at IPEC Unit 2, changes have been identified to the compliance strategies as described in the original OIP (Reference 1) and in previous correspondence (References 3, 5, 6, 8 and 10).

IPEC Unit 2 FLEX cooldown strategy has been revised. The overall strategy will be a two stage cooldown to reach a final reactor cooling system (RCS) cold leg temperature of less than 350°F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to comply with Westinghouse Technical Bulletin TB-15-1 (Reference 12). The first stage will be a cooldown to an RCS cold leg temperature of approximately 415°F. The second stage cooldown will be commenced within 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months , after the safety injection accumulators are isolated, boration and one hour boron mixing requirements are met, and the FLEX SG Feed Pump is connected and ready for operation.

Phase 1 of IPEC Unit 2 strategy is dependent upon the continued operation of the turbine driven auxiliary boiler feed pump (TDABFP). However, near the end of the second cooldown the anticipated TDABFP steam pressure will potentially be less than the design specified steam pressure for TDABFP operation at design flows. As a result, prior to commencing the second cooldown, the FLEX SG Feed Pump is connected and available to provide makeup to the steam generators, when desired or needed. The TDABFP is the preferred method for steam generator inventory control and may be used if capable to provide required steam generator inventory makeup flow.

5 Need for RelieflRelaxation and Basis for the RelieflRelaxation 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 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. A fifth table includes the FLEX related NRC Audit Visit (Reference 11) open items, which includes open items on previously issued ISE Open and Confirmatory Items and new Safety Evaluation (SE) Open Items that were not closed during the December 2015 NRC Audit Visit, and their status.

Note that during the December 2015 NRC Audit Visit the NRC utilized a spreadsheet entitled Indian Point Nuclear Generating Units SE Item Tracker to maintain a status of Open Items associated with development of the NRC's Safety Evaluation. The SE

NL-1 6-024 Dockets 50-247 Attachment Page 4 of 18 Tracker numbered each item with an Audit Item No. based on the category of the Open Item. The categories were:

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

B. Audit Questions (Audit Item x-B)

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

D. SEP Instrumentation RAIs (Audit Item SRAI-x-D)

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

In the Status columns of the following tables, closed items are identified by the phrase "This item was closed during the December 2015 NRC Audit Visit." Open/Closed status pending confirmation from the audit report.

Overall Integrated Plan Open Item Status There were no open items documented in the IPEC Overall N/A Integrated Plan ISE Open and Confirmatory Items IPEC Unit 2 Status 3.1 .2.A Review of the licensee's new flooding level This item was closed evaluation results and its potential impact on the during the December flooding hazard analyses previously provided in 2015 NRC Audit Visit their Integrated Plan and during the audit (associated with AQ process is iden~tified as an Open Item. If the IPEC-006).

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 was closed water supplies that are robust with respect to during the December seismic events, floods, and high winds, and the 2015 NRC Audit Visit associated missiles. The licensee should (associated with AQ determine if a water supply for the SGs and IPEC-041).

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-1 6-024 Dockets 50-247 Attachment Page 5 of 18 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 AQ 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 was closed access to all required areas will be assured in during the December the event of a power failure as described in 2015 NRC Audit Visit Consideration 5 of NEI 12-06, Section 5.3.2. (associated with AQ IPEC-023).

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 AQ 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 was closed potential impacts of large internal flooding during the December sources that are not seismically robust and do 2015 NRC Audit Visit not require ac power has been completed per (associated with AQ consideration 2 of NEI 12-06, Section 5.3.3. IPEC-004).

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 I PEC-005).

3.1 .2.2.A Confirm that evaluations address: whether This item was closed procedures have been established for actions to during the December be taken upon receipt of a hurricane warning; 2015 NRC Audit Visit ensuring that fuel in oil storage tanks would not (associated with AQ be inundated or damaged by flooding; and, IPEC-006).

whether the means (e.g., trucks) for moving FLEX equipment is reasonably protected from the event.

NL-1 6-024 Dockets 50-247 Attachment Page 6 of 18 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status 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 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 I PEC-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 reflux 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 was closed addressed the applicability of Assumption 4 on during the December page 4-13 of WCAP-17601 which states that 2015 NRC Audit Visit decay heat is per ANS 5.1-1979 + 2 sigma, or (associated with AQ equivalent. Ifthe ANS 5.1-1 979 + 2 sigma IPEC-013).

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 was statused strategy for controlling the RCS pressure to as open during the prevent nitrogen from escaping from the safety December 2015 NRC injection accumulators into the RCS until the Audit Visit (associated isolation valves can be closed, with AQ IPEC 035). See the December 2015 NRC Audit Visit FLEX Related Open Items table (below)

Audit Item Cl 3.2.1.6.A for status.

NL-1 6-024 Dockets 50-247 Attachment Page 7 of 18 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status 3.2.1 .8.A The PWROG submitted to NRC a position This item was statused paper, dated August 15, 2013, which provides as open during the test data regarding boric acid mixing under December 2015 NRC single-phase natural circulation conditions and Audit Visit (associated outlined applicability conditions intended to with AQ IPEC 050). See ensure that boric acid addition and mixing would the December 2015 NRC occur under conditions similar to those for which Audit Visit FLEX Related boric acid mixing data is available. During the Open Items table (below) audit process, the licensee informed the NRC Audit Item CI 3.2.1.8.A staff of its intent to abide by the generic for status.

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 was closed required time for the operator to realign each of during the December the above discussed pumps and confirm that 2015 NRC Audit Visit the required times are consistent with the (associated with AQ results of the ELAP analysis. Confirm that the IPEC 017).

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 was closed evaluation that demonstrates flow through a 2- during the December inch connection will be sufficient to provide 2015 NRC Audit Visit adequate flow to maintain the SG level using (associated with AQ the alternate SG FLEX pump. IPEC-036).

3.2.2.A Confirm that the licensee has satisfactorily This item was closed explained the strategy to provide a secondary during the December connection for SEP makeup if the building is 2015 NRC Audit Visit inaccessible, and explain where these valves (associated with AQ are and if access to these valves will be IPEC-034).

available during an ELAP event.

3.2.3.A Confirm that a containment evaluation has been This item was statused completed and, based on the results of this as open during the evaluation; required actions to ensure December 2015 NRC maintenance of containment integrity and Audit Visit. See the

NL-1 6-024 Dockets 50-247 Attachment Page 8 of 18 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status required instrument function will be developed. December 2015 NRC Audit Visit FLEX Related Open Items table (below)

Audit Item CI 3.2.3.A for status.

3.2.4.2.A Confirm that the assessment of the predicted This item was closed maximum temperatures in rooms with during the December equipment that is required for FLEX strategies 2015 NRC Audit Visit during the ELAP demonstrates that the (associated with AQ equipment will continue to function as needed. IPEC-020).

3.2.4.2.B Confirm that hydrogen concentration in the This item was closed battery rooms during battery recharging would during the December be maintained at an acceptable level. 2015 NRC Audit Visit (associated with AQ IPEC-047).

3.2.4.3.A Confirm that the need for heat tracing has been This item was closed evaluated for the BAST and all other equipment during the December necessary to ensure that all FLEX strategies 2015 NRC Audit Visit can be implemented successfully. (associated with AQ IPEC-02 1).

3.2.4.6.A Confirm that habitability limits will be maintained This item was closed and/or operator protective measures will be during the December employed in all Phases of an ELAP to ensure 2015 NRC Audit Visit operators will be capable of FLEX strategy (associated with AQ execution under adverse temperature IPEC-020).

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 was closed been finalized. Also confirm that the fuel during the December required for each FLEX piece of equipment has 2015 NRC Audit Visit been established and that the total fuel usage (associated with AQ has been calculated to demonstrate that IPEC-025).

sufficient fuel with margin exists on site.

N L- 16-024 Dockets 50-247 Attachment Page 9 of 18 Interim Staff Evaluation Confirmatory Items IPEC Unit 2 Status 3.2.4.1 0.A Confirm that analysis of the following aspects of This item was closed the dc power requirements have been identified during the December and evaluated: 2015 NRC Audit Visit

a. The dc load profile with the required loads (associated with AQ for the mitigating strategies to maintain IPEC-026).

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 was closed generators are adequately sized to supply loads during the December assumed for implementing Phase 2 strategies. 2015 NRC Audit Visit (associated with AQ IPEC-03 1).

B. Audit IPCUi ttsCompletion or Target Questions IPCUi ttsDate This item was closed during the October IPEC-002 2014 NRC Audit Visit (associated with ISE Closed Confirmatory Item 3.1.1.2.D).

IPEC-003 This item was closed during the December Closed 2015 NRC Audit Visit.

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-004 Confirmatory Item 3.1.1.3.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October Closed IPEC-005 2014 NRC Audit Visit (associated with ISE Confirmatory Item 3.1 .1.4.A)

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-006 Open Item 3.1 .2.A.. The preceding table provides the status to this ISE Open Item.

NL-1 6-024 Dockets 50-247 Attachment Page 10 of 18 B. Audit IPCUi ttsCompletion or Target Questions IPCUi ttsDate This item was closed during the December Closed IPEC-008 2015 NRC Audit Visit.

This item was closed during the October Closed IPEC-009 204NCAdtVs.

2015 NRC Audit Visit.

This item was closed during the December Closed IPEC-Oll 2015 NRC Audit Visit.

This item was closed during the Oectber Closed 2014 NRC Audit Visit to its associated ISE IPEC-012 Confirmatory Item 3.2.1.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-013 Confirmatory Item 3.2.1.3.A. The preceding table provides the status to this ISE Confirmatory Item.

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

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

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-020 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 Closed 2014 NRC Audit Visit to its associated ISE IPEC-021 Confirmatory Item 3.2.4.3.A. The preceding table provides the status to this ISE Confirmatory Item.

This item was closed during the December Closed IPEC-022 2015 NRC Audit Visit.

IPC-23 This item was closed during the December Closed 2015 NRC Audit Visit.

NL-1 6-024 Dockets 50-247 Attachment Page 11 of 18 B. Audit IPCUi ttsCompletion or Target Questions IPCUi ttsDate This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-025 Confirmatory Item 3.2.4.9.A. The preceding table provides the status to this ISE Confirmatory Item.

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

__________Confirmatory Item.

This item was closed during the December Closed IPEC-027 205NCAdtVs.

IPEC-028 2015 NRC Audit Visit.

This item was closed during the December Closed IPEC-029 2015 NRC Audit Visit.

This item was closed during the Oectber Closed 2014 NRC Audit Visit to its associated ISE IPEC-031 Confirmatory Item 3.4. The preceding table provides the status to this ISE Confirmatory Item.

IPEC-032 This item was closed during the December Closed 2015 NRC Audit Visit.

This item was closed during the December Closed IPEC-033 2015 NRC Audit Visit.

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-034 Confirmatory Item 3.2.2.A. The preceding table provides the status to this ISE

__________Confirmatory Item.

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-035 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 Closed 2014 NRC Audit Visit to its associated ISE IPEC-036 Confirmatory Item 3.2.1.9.B. The preceding table provides the status to this ISE Confirmatory Item.

NL-1 6-024 Dockets 50-247 Attachment Page 12 of 18 B. Audit IPCUi ttsCompletion or Target Questions IPCUi ttsDate This item was closed during the October Closed IPEC-037 2014 NRC Audit Visit.

This item was closed during the October Closed 2014 NRC Audit Visit to its associated ISE IPEC-041 Open Item 3.2.4.7.A. The preceding table provides the status to this ISE Open Item.

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

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

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

This item was statused as open during the See the December 2015 December 2015 NRC Audit Visit. See the NRC Audit Visit FLEX IPEC-046 December 2015 NRC Audit Visit FLEX Related Open Items Related Open Items table (below) Audit Item table (below) 46-B for status.

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

This item was closed during the December Closed IPEC-048 2015 NRC Audit Visit.

This item was statused as open during the NRC Audit Report (2 IPEC-049a December 2015 NRC Audit Visit pending 2016) shows as closed.

NRC review of information provided.

This item was closed during the December Closed IPEC049b 2015 NRC Audit Visit.

This item was closed during the December Closed IPEC049c 2015 NRC Audit Visit.

NL-1 6-024 Dockets 50-247 Attachment Page 13 of 18 B. Audit IPCUi ttsCompletion or Target Questions IPCUi ttsDate IPE-09d This item was closed during the December Closed IPEC-049ed hsie a lsddrn h eebr Coe 2015 NRC Audit Visit.

IPE-09f This item was closed during the December Closed 2015 NRC Audit Visit.

This item was closed during the December Closed IPEC-049gf 05NCAdtVst IPEC049h 2015 NRC Audit Visit.

IPE-09i This item was closed during the December Closed IPEC049g 2015 NRC Audit Visit.

This item was closed folloing the Oectober Closed 2014 NRC Audit Visit.t t socae S This item was closed during the December Closed IPEC-049i 205NCAdtVs.

1NR1Adi Visit.tViit SE duringotenDecemer21 This item was closed Otbr Closed

2NR Visit.Vii 1Adi t tsasoite S SE This item was closed during the December 21 Closed

4NR1Adi Visit.tViit SE This item was statsedasoe during thSe the December Coe2015 SE Dcmbr21 NRC Audit Visit. SeteNCAdtVstFE SE This item was closed during the December 2015 Closed

6 NRC Audit Visit.