W3F1-2014-0014, Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML14059A085
Person / Time
Site:	Waterford
Issue date:	02/28/2014
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, W3F1-2014-0014
Download: ML14059A085 (14)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 W3F1-2014-0014 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

References:

1. NRC Order Number EA-12-049, Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No. ML12054A736)

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 (ADAMS Accession No. ML12229A174)

3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12221A205)

4. Entergy letter to NRC, 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 26, 2012 (W3F1-2012-0093) (ADAMS Accession No. ML12300A447)

5. Waterford Steam Electric Station, Unit 3 letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013 (ADAMS Accession No. ML13063A266)

W3F1-2014-0014 Page 2 of 3

6. Waterford Steam Electric Station, Unit 3 letter to NRC, First Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated August 28, 2013 (ADAMS Accession No. ML13241A281)

Dear Sir or Madam:

On March 12, 2012, the NRC issued Order Number EA-12-049 (Reference 1) to Entergy Operations, Inc. (Entergy). The order was immediately effective and required Waterford Steam Electric Station, Unit 3 (Waterford 3) to develop mitigating strategy provisions for beyond-design-basis external events.

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 (OIP). Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3). Reference 4 provided the initial status report regarding mitigating strategies and Reference 5 provided the OIP.

NRC Order EA-12-049 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan with regard to the requirements for mitigation strategies for beyond-design-basis external events for Waterford 3. Reference 6 provided the first six-month status report for Waterford 3. The purpose of this letter is to provide, as an attachment, the second six month status report for the implementation of Order EA-12-049.

There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact John Jarrell, Regulatory Assurance Manager, at (504) 739-6685.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 28, 2014.

Sincerely, MRC/LEM

Attachment:

Waterford Steam Electric Station, Unit 3, Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to the Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

W3F1-2014-0014 Page 3 of 3 cc: Attn: Director, Office of Nuclear Reactor Regulation U. S. NRC RidsNrrMailCenter@nrc.gov Mr. Mark L. Dapas, Regional Administrator U. S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Project Manager for Waterford 3 Alan.Wang@nrc.gov NRC Senior Resident Inspector for Waterford 3 Marlone.Davis@nrc.gov Chris.Speer@nrc.gov

Attachment W3F1-2014-0014 Waterford Steam Electric Station, Unit 3, Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to the Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Attachment to W3F1-2014-0014 Page 1 of 10 Waterford Steam Electric Station, Unit 3, Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to the Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Waterford Steam Electric Station, Unit 3 (Waterford 3), developed an Overall Integrated Plan (Reference 1 in Section 8) documenting the diverse and flexible strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). This attachment provides a planned update of milestone accomplishments since submittal of the last status report (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (OIP), and are current as of January 31, 2014.

• First Six-Month Status Report August 2013

• Second Six-Month Status Report Complete with submission of this document in February 2014 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. This section 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.

Revised Target Target Milestone Completion Activity Status Completion Date **

Date Submit Overall Integrated Plan Feb 2013 Complete Submit Six Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Perform Staffing Analysis Nov 2015 Not Started Modifications:

Engineering and Implementation N-1 Walkdowns May 2014 Not Started

Attachment to W3F1-2014-0014 Page 2 of 10 Revised Target Target Milestone Completion Activity Status Completion Date **

Date Design Engineering Oct 2014 Started Implementation Outage Nov 2015 Not Started On-site FLEX Equipment Purchase Dec 2014 Started Procure Sept 2015 Started Off-site FLEX Equipment Develop Strategies with RRC Dec 2013 Started April 2015 Install Off-Site Delivery Station (if Nov 2015 Not Started Necessary)

Procedures Create Waterford FSGs Nov 2015 Not Started Create Maintenance Procedures Nov 2015 Not Started Training Develop Training Plan May 2015 Not Started Implement Training Nov 2015 Not Started Submit Completion Report Feb 2016* Not Started

• This date corresponds to the last six month status report and provides time to compile the report following the completion of the fall 2015 Implementation Outage.

• • 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 There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Waterford 3 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table 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 a listing of Audit Questions and the status of each item.

Attachment to W3F1-2014-0014 Page 3 of 10 Overall Integrated Plan Open Item Status OI1. The suction path from the TDEFWP to the WCTs would be through In Progress (see a non-running ACCWS pump post-ELAP. It is expected that both related information the TDEFWP and the currently sized EFW FLEX pump (primary in Section 7) strategy) will have sufficient capability and/or NPSH to do so.

However, this will need to be confirmed more fully as the detailed design of the primary strategy for maintaining core cooling and heat removal evolves (with SGs available).

OI2. An analysis will be needed to demonstrate that containment In Progress pressure and temperature will stay at acceptable levels throughout the ELAP event and that no containment spray system will be required as part of FLEX.

OI3. At this stage of the conceptual design, the chemistry effects of In Progress alternate cooling source (ACS) use on secondary wetted components are unknown.

OI4. It is currently unclear how long gravity feed from the SITs can be Closed - The SITs maintained during Modes 5 and 6 in Phase 1. The ability to gravity availability in feed depends upon SIT fluid height/backpressure, line losses Modes 5 and 6 will through the gravity flow path, and developed pressure within the be addressed by RCS. If this time is sufficiently short, Waterford 3 may choose to the outage pre-stage requisite FLEX equipment in Modes 5 and 6. shutdown safety risk planning (EN-OU-108 as revised for FLEX) process.

OI5. It is expected that only the component cooling water system and In Progress (see dry cooling towers will need to be made operational to reject the related information heat load generated post-ELAP in Phase 3. However, this must in Section 7) be investigated more fully to confirm such. Notably, only 60% of the dry cooling tower fan motors are currently missile protected and none of the wet cooling tower (WCT) fan motors are missile protected. If more than 60% of dry cooling tower (DCT) capacity is needed to support Phase 3, DCT and/or WCT fan motors may need to be missile protected. Currently available information follows:

The DCT one train heat removal in an accident would be 113.38 Mbtu/hr. Given that 60% of the DCT is missile protected, its assumed that that 40% of the heat removal capability is lost. 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> after shutdown, decay heat is less than 68 Mbtu/hr (ANS 79 decay heat curve) and less than the heat removal capacity of the DCTs. As the event proceeds, the required heat removal will decrease. Until this point in the event, Phase 1 and 2 FLEX strategies will be capable of removing decay heat. Final system operating details for the CCW and DCT (i.e., number of pumps and fans to operate) still need to be determined.

Attachment to W3F1-2014-0014 Page 4 of 10 Interim Staff Evaluation Open Items Status 3.1.3.A Wind Hazard Screening - The licensee's response fails to In Progress consider the warning time offered by a hurricane storm for pre-staging FLEX equipment. In addition, as described in NEI 12-06, Section 7.2.2, hurricanes can have a significant impact on local infrastructure, e.g., downed trees and flooding that should be considered in the interface with off-site resources.

3.2.1.1.B CENTS - Justify conformance with the limitations of the use In Progress of CENTS by providing the CENTS-calculated value of the centered one-hour moving average of the flow quality at the top of the SG tubes, which corresponds to the maximum void fraction of 0.2 in SG tubes as conditions used to define termination of single phase natural circulation, and confirming that the value is less than the limit specified in the white paper dated September 24, 2013 for use in defining the onset of reflux being.

3.2.1.2.A RCP Seal Leakage - Justification of less than 15 gpm per On page 28 of the RCP seal leakage in analysis. OIP, it is stated:

Consistent with Reference 8 methodology, the total leakage from the Waterford RCP seals is assumed to be no greater than approximately 58 gpm during Phase

1. The total seal leakage assumed in the current analysis is no greater than 60 gpm. This will be reflected in a future update to the OIP.

(See related information in Section 7) 3.2.1.2.B RCP generic seal question regarding: (1) the analysis used In Progress to determine the leakage rate, (2) cold leg subcooling, (3) leakage flow path characteristics after seal failure, (4) seal performance at high temperatures, (5) isolation of controlled bleed off lines, and (6) pressure dependent seal leakage rates.

3.2.1.3.A Decay Heat -Assumption 4 on page 4-13 of WCAP-17601 In Progress states that decay heat is per ANS [American Nuclear Society] 5.1-1979 + 2 sigma, or equivalent. Address the

Attachment to W3F1-2014-0014 Page 5 of 10 Interim Staff Evaluation Open Items Status applicability of assumption 4 to Waterford. If the ANS 5.1-1979 + 2 sigma model is used in the Waterford 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.

3.2.1.8.A Core Sub-Criticality- Regarding boron mixing, the NRC staff In Progress (see has not yet accepted the PWROG [Pressurized Water related information Reactor Owners Group] position paper on boron mixing. in Section 7)

Therefore, additional technical justification will be needed to resolve this issue, both generically and on a plant-specific basis.

3.2.4.2.A Ventilation - Adequacy of ventilation in the control room to In Progress protect energized equipment throughout the entire ELAP event, especially if the ELAP is due to high temperature hazard.

3.2.4.2.B Ventilation- Effects of elevated temperatures in the battery In Progress room, especially if the ELAP is due to a high temperature hazard.

3.2.4.2.C Ventilation - Hydrogen concentration in the battery rooms In Progress during recharging 3.2.4.2.D Ventilation - Loss of ventilation and any potential impacts on In Progress the necessary equipment in the TDEFW pump room.

3.2.4.4.A Lighting - Review the licensee's assessment of the In Progress habitability/accessibility requirements to ensure lighting is appropriately addressed.

3.2.4.8.A Electrical Power Sources/Isolation and Interactions- Provide Revised response a summary of the sizing calculations used to determine the to associated Audit adequacy of the FLEX generators used to power plant Question 41 electrical equipment. provided on the Entergy ePortal on 10/30/13.

3.2.4.10.A Load Reduction to Conserve DC Power - The licensee's In Progress Integrated Plan on Page 7 identifies dc load shed at hour 1 and 4. With regard to the load shedding of the dc bus in order to conserve battery capacity:

a. Provide the dc load profile for the mitigation strategies to maintain core cooling, containment, and SFP cooling during

Attachment to W3F1-2014-0014 Page 6 of 10 Interim Staff Evaluation Open Items Status all modes of operation. In your response, describe any load shedding that is assumed to occur and the actions necessary to complete each load shed. Also provide a detailed discussion on 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 necessary and the time to complete each action. In your response, explain which functions are lost as a result of shedding each load and discuss any impact on defense-in-depth strategies and redundancy.

b. Identify any plant components that will change state if vital ac or dc power is lost or de-energized during the load shed.

c. Provide the minimum voltage that must be maintained and the basis for the minimum voltage on each battery/dc bus during each Phase under all MODES of operation (consider the impact of reduced loading as a result of load shedding).

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Seismic Protection - Licensee to ensure that: 1) seismic In Progress interactions to ensure equipment is not damaged by non-seismically robust equipment or structures for portable equipment that will be stored outside; 2) how large FLEX equipment such as pumps and power supplies stored inside seismic structures is appropriately secured to protect them during a seismic event; and, 3) where other portable equipment such as hoses and power cables would be stored to assure proper protection from a seismic event.

3.1.1.2.A Seismic Deployment - Protection of the connection points for In Progress Reactor Coolant System (RCS) inventory control during the final phase is yet to be determined (TBD).

3.1.1.2.B Seismic Protection - Protection of the tow vehicle used to In Progress move the spare or "N+1" FLEX generator. (Also tied into to the ability to move equipment in the flooding context discussed in Section 3.1.2.2 and wind protection for the vehicle discussed in Section 3.1.3.2) 3.1.1.3.A Seismic Procedural Interface - Seismic hazards associated In Progress with large internal flooding sources that are not seismically robust and do not require ac power, and the use of ac power to mitigate ground water in critical locations.

3.1.1.4.A Seismic Off site resources - The licensee has not yet In Progress identified the local staging area and method of transportation to the site.

3.1.2.2.A Flooding Deployment- Implementation of flooding In Progress persistence into their FLEX strategies for pre-event staging

Attachment to W3F1-2014-0014 Page 7 of 10 Interim Staff Evaluation Confirmatory Items Status of FLEX equipment.

3.1.2.3.A Flooding Procedural Interface- Deployment of portable In Progress equipment in flooded conditions not incorporated into flood procedures or the need to deploy temporary flood barriers and extraction pumps necessary to support deployment.

3.1.3.2.A Wind Deployment - Whether procedures and programs will In Progress include taking proactive actions such as testing, connecting, and readying exposed portable equipment to reduce the potential for wind impacts.

3.2.1.1.A CENTS - Verify the use of CENTS in the ELAP analysis for In Progress Waterford is limited to the flow conditions before reflux boiling initiates. This includes providing a justification for how the initiation of reflux boiling is defined.

3.2.1.4.A Initial Values for Key Plant Parameters and Assumptions- In Progress Review analysis of UHS [Ultimate Heat Sink] (licensee open (see related item OI5) information in Section 7) 3.2.3.A Containment Functions Strategies - Review the results of the In Progress finalized containment analysis associated with open item OI2 of the Integrated Plan, which shows that containment functions will be (potentially) restored and maintained in response to an ELAP event.

3.2.4.4.B Communications - Confirm that upgrades to the site's In Progress communications systems have been completed.

3.2.4.5.A Protected and Internal Locked Area Access- Verify access In Progress plans are incorporated into FLEX strategies.

3.2.4.6.A Personnel Habitability - Review the licensee's assessment of In Progress the habitability/accessibility requirements in all critical areas.

3.2.4.7.A Water Sources -Verify the evaluation of the suction path from In Progress the TDEFWP to the WCTs [Wet Cooling Towers] through a non-running ACCWS [Auxiliary Component Cooling Water System] pump post-ELAP confirms it is viable.

3.2.4.7.B Water Sources - Description of how the licensee would get In Progress water from the Mississippi River to the FLEX pumps.

3.2.4.8.B Electrical Power Sources/Isolation and Interactions - In Progress Licensee to provide the level of detail of the FLEX instrumentation to ensure that electrical equipment remains protected (from an electrical standpoint- e.g., power fluctuations). Also, confirm electrical isolation to ensure that the portable/FLEX diesel generators are isolated from Class 1 E diesel generators to prevent simultaneously supplying power to same Class 1 E bus.

3.2.4.9.A Portable Equipment Fuel - Diesel fuel oil supply for the diesel In Progress

Attachment to W3F1-2014-0014 Page 8 of 10 Interim Staff Evaluation Confirmatory Items Status driven pump and how continued operation to ensure core cooling is maintained. Diesel fuel oil supply (e.g., fuel oil storage tank volume, supply pathway, etc.) for the FLEX generators and how continued operation to ensure core and SFP cooling is maintained indefinitely (i.e., Phase 2 and 3).

3.2.4.9.B Portable Equipment Fuel - Discuss how fuel quality will be In Progress maintained.

Completion or Audit Question Open Items Status Target Date WF3-001 In progress August 2014 WF3-002 In progress August 2014 WF3-003 In progress August 2014 WF3-004 Closed*

WF3-005 In progress August 2014 WF3-006 In progress August 2014 WF3-007 In progress February 2015 WF3-008 Closed*

WF3-009 In progress August 2014 WF3-010 Closed*

WF3-011 Closed*

WF3-012 In progress August 2014 WF3-013 Closed*

WF3-014 Closed*

WF3-015 Closed*

WF3-017 In progress February 2015 WF3-018 In progress February 2015 WF3-019 In progress February 2015 WF3-020 In progress February 2015 WF3-021 In progress August 2014 WF3-022 In progress August 2014 WF3-023 In progress August 2014 WF3-024 In progress August 2014 WF3-025 In progress August 2014 WF3-026 Closed*

Attachment to W3F1-2014-0014 Page 9 of 10 Completion or Audit Question Open Items Status Target Date WF3-027 In progress February 2015 WF3-028 Closed*

WF3-029 Closed*

WF3-030 In progress February 2015 WF3-031 Closed*

WF3-032 In progress August 2014 WF3-033 In progress August 2014 WF3-034 In progress August 2014 WF3-035 In progress August 2014 WF3-036 In progress August 2014 WF3-038 In progress August 2014 WF3-039 In progress August 2014 WF3-040 In progress February 2015 WF3-041 In progress August 2014

• Closed indicates that Entergys response is complete.

7 Potential Interim Staff Evaluation Impacts In addition to the items identified in Section 6, the items discussed below have potential impact on the Interim Staff Evaluation.

• Waterford has identified a non-conservatism in a supporting calculation (CN-SEE-II-12-38) to the Spent Fuel Pool (SFP) cooling strategy for the normal fuel offload scenario as described in the Waterford Overall Integrated Plan (Reference 1); this has been documented in the Waterford corrective action program as CR WF3 2014 0296. The Waterford Overall Integrated Plan (Reference 1) discusses the scenario on pages 45 and 47 of 108. The Interim Staff Evaluation and Audit Report for Waterford (Reference 3) references the affected strategy in Section 3.2.2 on pages 44 and 45 of 65. The timing associated with the time to boil of the SFP and the time by which makeup must be established to the SFP for normal fuel offload will be reduced once the non-conservatism is addressed. The updated sequence of events timing will be reported in Third Six-Month Status Report. The supporting calculation for fuel in transfer or full core off-load was unaffected by this condition and remains conservative and bounding for the sizing of the FLEX SFP makeup pump.

• The following additional items were identified that could impact the Interim Staff Evaluation (ISE):

Attachment to W3F1-2014-0014 Page 10 of 10

• All references to "approximately 58 gpm" will be changed to "60 gpm". The OIP stated "...no greater than approximately 58 gpm in phase 1." (See also ISE Open Item 3.2.1.2.A in Section 6)

• The ISE states that PWROG position paper on boron mixing has not been accepted.

Subsequent to the issuance of the WF3 ISE the NRC endorsed the PWROG position paper on boron mixing (ADAMS Accession No.: ML13276A183). (See also ISE Open Item 3.2.1.8.A in Section 6)

• The EFW secondary strategy involving a secondary diesel pump and a diesel booster pump is being reconsidered. Instead, a diverse suction and discharge path are planned to be provided for the primary EFW FLEX pump and the +1.

• The amount of equipment to be stored in the N+1 building has yet to be finalized.

• The strategy to repower the dry cooling tower train and a component cooling water pump is being reconsidered; the proposed plan is to extend phase 2 strategy indefinitely. The plant would transition to other water sources whenever such resources are available such that a long term strategy is not required once plant is stable. (See also OIP open item OI5 in Section 6)

• The strategy of switching over to WCT basin through non-running ACCWS pump is being reconsidered to instead using the water transfer pump to fill the CSP from the WCT. The TDEFWP would continue to draw directly from the CSP for the duration of the event. (See also OIP open item OI1 in Section 6)

• The decay heat and makeup requirements for core cooling via the steam generators are being reevaluated.

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

1. Waterford Steam Electric Station, Unit 3 letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013 (ADAMS Accession No. ML13063A266)

2. NRC Order Number EA-12-049, Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No. ML12054A736).

3. Waterford Steam Electric Station, Unit 3 letter to NRC, First Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated February 28, 2013. (ADAMS Accession No. ML13241A281)

4. NRC letter to Entergy Operations, Inc. - Waterford Steam Electric Station, Unit 3 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049 (Mitigation Strategies) (TAC No. MF0977), dated November 22, 2013 (ADAMS Accession No. ML13220A402)