View source for JAFP-14-0023, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order No. EA-12-049)

{{Adams
| number = ML14059A359
| issue date = 02/28/2014
| title = Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order No. EA-12-049)
| author name = Coyle L
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000333
| license number = DPR-333
| contact person = 
| case reference number = EA-12-049, JAFP-14-0023
| document type = Letter type:JAFP, Status Report
| page count = 8
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Lawrence M. Coyle Site Vice President - JAF JAFP-14-0023 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order Number EA-12-049)
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

==Reference:==
: 1. NRC Order Number, EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
: 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 to NRC, JAFP-12-0124, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012
: 5. Entergy to NRC, JAFP-13-0025, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013
: 6. Entergy to NRC, JAFP-13-0112, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order Number EA-12-049), dated August 28, 2013

JAFP-14-0023 Page 2 of 2

==Dear Sir or Madam:==

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order [Reference 1] to James A. FitzPatrick Nuclear Power Plant (JAF). Reference 1 was immediately effective and directs JAF to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance [Reference 2] and an overall integrated plan pursuant to Section IV, Condition C.2. Reference 2 endorses industry guidance document NEI 12-06, Revision O
[Reference 3] with clarifications and exceptions identified in Reference 2. Reference 4 provided the JAF initial status report regarding mitigation strategies. Reference 5 provided the JAF overall integrated plan.
Reference 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. The purpose of this letter is to provide the second 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.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.
I declare under penalty of perjury that the foregoing is true and correct. Executed on 281h day of February, 2014.
Sincerely,
... -"=**rence M. Coyle Site Vice President LMC/CMA/mh

==Attachment:==
James A. FitzPatrick Nuclear Power Plant's (JAF) Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc:    Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Mohan Thadani, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. Francis J. Murray Jr., President NYSERDA

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (5 Pages)

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second 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 JAF developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
: 2. Milestone Accomplishments The following milestone(s) have been completed since July 31, 2013, and are current as of January 31, 2014.
First Six-Month Status Report  August 2013 (JAFP-13-0112)
: 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.
Validation/Demonstration A target completion date was added to the milestone listing for completion of the FLEX Strategy Validation/Demonstration. The validation/demonstration will be completed during the JAF modification implementation outage. This new milestone target date does not impact the Order implementation date.
Perform Staffing Analysis The target date for Perform Staffing Analysis has been revised to June 2015. While the activity is in progress it will not be completed until the implementation of modifications (non-outage) has been completed. This revised milestone target date does not impact the Order implementation date.
Milestone               Target Completion          Activity Status       Revised Target Date*                                    Completion Date 60-day Status Update                October 29, 2012            Complete Submit Overall Integrated          February 28, 2013            Complete Plan Six-Month Status Report               August 2013               Complete Refine Strategies                    December 2014               Started Perform Staffing Analysis            December 2013             In progress           June 2015 Develop Strategies /                    May 2015                 Started Contract with RRC Six-Month Status Report              February 2014              Complete Page 1 or 5

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second 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 Milestone                  Target Completion              Activity Status               Revised Target Date*                                                Completion Date Develop Mods                             June 2015                    Not Started Draft Implementing                       June 2016                    Not Started Procedures Regional Response Center                  July 2015                      Started Operational Develop Storage Plan                     June 2015                       Started Purchase FLEX Equipment                   Fall 2016                   Not Started Issue Maintenance                         Fall 2016                   Not Started Procedures (for FLEX equipment)
Six-Month Status Report                 August 2014                   Not Started Develop Training Plan                   October 2014                  Not Started Refueling Outage 1                        Fall 2014                   Not Started Six-Month Status Report                February 2015                  Not Started Implement Training                       May 2015                     Not Started Implement Mods (non-                     June 2015                    Not Started outage)
Six-Month Status Report                 August 2015                   Not Started Six-Month Status Report                February 2016                  Not Started Issue Implementing                       May 2016                     Not Started Procedures Six-Month Status Report                 August 2016                   Not Started Implement Mods (outage)                   Fall 2016                   Not Started Implement Training                        Fall 2016                   Not Started Updates Refueling Outage 2 (full                  Fall 2016                   Not Started implementation)
Validation / Demonstration                Fall 2016                   Not Started
*Target Completion Date is the last submitted date from either the overall integrated plan or a previous six-month status report.
Page 2 or 5

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second 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
: 4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan
[Reference 1 and 3].
: 5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF 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 tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes the status of each FitzPatrick Audit Question for the Mitigation Strategies (FLEX) Order.
Overall Integrated Plan Open Items                              Status OI-1: Beyond-design-basis external event impact on                        Not Started requirements in existing licensing documents will be determined based on input from the industry groups and direction from the NRC.
OI-2: The structure, content and details of the Regional                    Started Response Center playbook will be determined.
Interim Staff Evaluation Open Items                              Status The U.S. Nuclear Regulatory Commission (NRC) has                              N/A not issued an Interim Staff Evaluation for JAF; therefore, there are no open items for the Interim Staff Evaluation identified at this time.
Interim Staff Evaluation Confirmatory Items                          Status The U.S. Nuclear Regulatory Commission (NRC) has                              N/A not issued an Interim Staff Evaluation for JAF; therefore, there are no confirmatory items for the Interim Staff Evaluation identified at this time.
Audit Questions                    Status            Completion or Target Date JAF-001                                    In progress                 August 2015 JAF-002                                    In progress                 August 2015 JAF-003                                    In progress                 August 2015 Page 3 or 5

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second 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 Audit Questions                Status         Completion or Target Date JAF-004                              In progress              August 2015 JAF-005                              In progress              August 2015 JAF-006                              In progress              August 2015 JAF-008                              In progress              August 2015 JAF-009                              In progress              August 2015 JAF-010                              In progress              August 2015 JAF-011                              In progress              August 2015 JAF-012                              In progress              August 2015 JAF-013                              In progress              August 2015 JAF-014                              In progress              August 2015 JAF-015                                Closed JAF-016                                Closed JAF-017                              In progress              August 2015 JAF-018                                Closed JAF-019                              In progress              August 2015 JAF-021                                Closed JAF-022                              In progress              August 2015 JAF-023                              In progress              August 2015 JAF-026                                Closed JAF-027                              In progress              August 2015 JAF-028                              In progress              August 2015 JAF-029                                Closed JAF-031                              In progress              August 2015 JAF-032                                Closed JAF-033                              In progress              August 2015 JAF-034                                Closed JAF-035                              In progress              August 2015 JAF-036                                Closed JAF-037                                Closed JAF-038                                Closed JAF-040                              In progress              August 2015 JAF-043                                Closed JAF-046                                Closed JAF-049                                Closed JAF-050                              In progress              August 2015 JAF-052                                Closed JAF-053                                Closed JAF-055                                Closed JAF-056                              In progress              August 2015 JAF-057                                Closed Page 4 or 5

JAFP-14-0023 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Second 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 Audit Questions                     Status             Completion or Target Date JAF-058                                      Closed JAF-059                                      Closed JAF-060                                   In progress                 August 2015 JAF-061                                   In progress                 August 2015 JAF-062                                   In progress                 August 2015 JAF-063                                      Closed JAF-064                                   In progress                 August 2015 JAF-065                                   In progress                 August 2015 JAF-066                                   In progress                 August 2015 JAF-068                                      Closed JAF-069                                   In progress                 August 2015 JAF-071                                      Closed JAF-072                                      Closed JAF-073                                      Closed
: 7. Potential Interim Staff Evaluation Impacts The NRC has not yet issued an interim staff evaluation for JAF; therefore, there are no potential impacts to the Interim Staff Evaluation identified at this time.
: 8. References
: 1. Entergy to NRC, JAFP-13-0025, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013.
: 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 to NRC, JAFP-13-0112, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order Number EA-12-049), dated August 28, 2013.
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