JAFP-15-0026, Fourth 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

Fourth 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

ML15058A587
Person / Time
Site:	FitzPatrick
Issue date:	02/27/2015
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, JAFP-15-0026
Download: ML15058A587 (17)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-15-0026 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Fourth 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

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 directed 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.

JAFP-15-0026 Page 2 of 2 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 endorsed 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. The purpose of this letter is to provide the fourth 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 27'h day of February, 2015.

Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF) Fourth 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. Doug Pickett, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. John B. Rhodes, President NYSERDA

JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 (14 Pages)

JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 last status report (Reference 6), 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, 2014, and are current as of January 31, 2015.

Third Six-Month Status Report -August 2014 (JAFP-14-0105)

Refine Strategy - October 2014

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.

Target Completion Revised Target Milestone Activity Status 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 Complete Perform Staffing Analysis June 2015 In progress Develop Strategies / May 2015 Started Contract with RRC Six-Month Status Report February 2014 Complete Develop Mods June 2015 Started Draft Implementing June 2016 Not Started Procedures Regional Response Center July 2015 Complete Operational Develop Storage Plan June 2015 Started Purchase FLEX Equipment Fall 2016 Not Started Issue Maintenance Fall 2016 Not Started Procedures (for FLEX equipment)

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Target Completion Revised Target Milestone Activity Status Date* Completion Date Six-Month Status Report August 2014 Complete Develop Training Plan November 2015 Not Started Refueling Outage 1 Fall 2014 Complete Six-Month Status Report February 2015 Complete Implement Training March 2016 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.

4. Changes to Compliance Method Changes to the compliance method as documented in the Overall Integrated Plan (OIP)

(Reference 1 and 3) are being considered during the preliminary design phase of the project.

The changes currently being considered are summarized below.

Page 5 of the OIP states that at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> manual control of the safety relief valves (SRVs) will take place to depressurize the reactor pressure vessel (RPV) to approximately 200-400 psig. For the proposed revised strategy this action is required at approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, per Modular Accident Analysis Program (MAAP) analysis, to stay within the safe region of the heat capacity temperature limit (HCTL) curve as long as possible.

Pages 12, 13, 17, 24 and 48 of the OIP indicate that the Reactor Core Isolation Cooling (RCIC) suction will be swapped from the Condensate Storage Tank (CST) to the torus/suppression pool. For the proposed revised strategy the RCIC suction will not be swapped to the torus/suppression pool. The RCIC suction will remain from the CST until it is depleted. Prior to the depletion of the CST, a flow path will be established from one of the installed diesel driven fire pumps to provide make up to the reactor pressure vessel.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Pages 17, 19 and 33 of the OIP state the portable pump provide injection to RPV and spent fuel pool (SFP). For the proposed revised alternate strategy a portable pump is no longer utilized. The proposed revised alternate strategy relies on using a second diesel driven fire pump to provide injection to the RPV and makeup to the SFP via the RHRSW system. This strategy is considered an alternate method of compliance because it does not utilize a portable pump per the guidelines of Section 3.2.2(13) of Nuclear Energy Institute (NEI) 12-06. Evaluations are in progress to verify that the second diesel driven fire pump and all associated components are available following all applicable beyond design basis external events (BDBEEs).

Pages 17 of the OIP states that a portable FLEX pump can also be used to make up to the CST. The replenishment of the CST is no longer part of the credited core cooling for the proposed revised strategy.

Page 24 of the OIP states that based on the containment response analysis results, containment is vented at about 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> into the event. The current containment analysis utilized in the proposed revised strategy, determined that to minimize the extent to which containment design limits are challenged, containment is vented at about 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event. The drywell and suppression chamber pressure are controlled by opening the Hardened Containment Vent System (HCVS) when the suppression chamber air space pressure reaches 10 psig.

Pages 6 and 49 of the OIP state that transition core cooling makeup flow from RCIC pump to the installed diesel-driven fire pump 76P-1 takes place at approximately 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> (based on the inventory from the CST and the torus volume). The proposed revised strategy does not swap RCIC suction to the torus/suppression pool, therefore, based on the current MAAP analysis, the transition from RCIC pump to the diesel driven fire pump takes place at around 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Page 32 of the OIP states that the FLEX pump used to provide the SFP makeup function is the same FLEX pump used to provide core cooling. The proposed revised strategy does not utilize a portable FLEX pump, instead it uses one of the diesel driven fire pumps to provide makeup to the spent fuel pool.

Page 17 of the OIP states that for the primary strategy, a modification will provide new connection points for a portable diesel generator unit to re-power the Battery Chargers 71BC-1A (or 71BC-1B), which charge the batteries and supply DC loads. The proposed revised primary strategy to repower Division A DC bus, which will provide power to required DC bus loads, will use the Temporary Station Battery Charger located in the Screenwell Building. This battery charger will be powered by a FLEX diesel generator (DG). A quick-connect type receptacle is provided at the temporary battery charger for connection from the 600 VAC FLEX DG.

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.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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

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) (Reference 4). A fourth table includes the status of each FitzPatrick Audit Question for the Mitigation Strategies (FLEX) Order.

FitzPatrick is currently in the preliminary design phase of the project. During the final design phase of the project, the status of the open items in this section will be updated to reflect the final strategies and supporting analysis; this is anticipated to be the fifth Six Month Status Report (August 2015).

Overall Integrated Plan Open Items Status OI-1: Beyond-design-basis external event impact on requirements in Entergy has existing licensing documents will be determined based on determined that update input from the industry groups and direction from the NRC. to existing licensing basis documents are not required to reflect BDBEEs.

OI-2: The structure, content and details of the Regional Response Started Center playbook will be determined.

Interim Staff Evaluation Open Items Status 3.1.1.3.A Procedural Interface (Seismic Hazard) - Evaluate the In Progress.

impacts from large internal flooding sources. (Audit This item will be Question 5) addressed by update to Audit Question (AQ)

JAF-005 response when information is available.

3.1.3.1.A Protection of FLEX Equipment (High Wind Hazard) - In Progress.

Evaluate the separation distance and the axis of This item will be separation considering the predominant path of tornados addressed by update to in the geographic area to demonstrate that at least N sets AQ JAF-001 response of FLEX equipment would remain deployable in the when information is context of a tornado missile hazard. (Audit Question 1) available.

3.1.4.2.B Deployment of FLEX Equipment (Snow, Ice and Extreme In Progress.

Cold) - Evaluate the potential impact on the UHS due to This item will be ice blockage or formation of frazil ice as a result of addressed on the extreme cold. updated AQ response spreadsheet on the ePortal when information is available.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Interim Staff Evaluation Open Items Status 3.2.3.A Containment- Verify that the implementation of Boiling In Progress.

Water Reactor Owners Group (BWROG) Emergency This item will be Procedure Guideline (EPG)/Severe Accident Guideline addressed by update to (SAG), Revision 3, including any associated plant-specific AQ JAF-017 response evaluations, has been completed in accordance with the when information is provisions of NRC letter dated January 9, 2014 (Reference available.

23 of ISE - Letter from Jack R. Davis (NRC) to Joseph E.

Pollock (NEI) dated January 9, 2014, regarding Boiling Water Reactor Containment Venting (ADAMS Accession No. ML13358A206))

Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Deployment of FLEX Equipment- Confirm that soil In Progress.

liquefaction will not impede vehicle movement following a This item will be seismic event. addressed by update to AQ JAF-002 response when information is available.

3.1.1.2.B Deployment of FLEX Equipment- Confirm final design In Progress.

features of the new storage building including the This item will be susceptibility to the loss of ac power to deploy addressed by update to equipment. AQ JAF-001 response when information is available.

3.1.1.2.C Deployment of FLEX Equipment - Confirm the storage In Progress.

locations and means of protection against the seismic This item will be hazard of the super duty pickup trucks and the two addressed by update to flatbed trailers used for deployment of FLEX equipment. AQ JAF-001 response when information is available.

3.1.1.4.A Offsite Resources- Confirm location of offsite staging In Progress.

area(s), access routes and methods of delivery of This item will be equipment to the site considering the seismic, flood, high addressed by update to wind, snow, ice and extreme cold hazards. AQ JAF-043 response when information is available.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Interim Staff Evaluation Confirmatory Items Status 3.1.3.2.A Deployment of FLEX Equipment (High Wind Hazard) - In Progress.

Confirm availability of debris removal equipment to This item will be facilitate deployment of FLEX equipment. addressed on the updated AQ response spreadsheet on the ePortal when information is available.

3.1.3.2.B Deployment of FLEX Equipment (High Wind Hazard) - In Progress.

Confirm protection of the means to move FLEX This item will be equipment. addressed by update to AQ JAF-001 response when information is available.

3.1.4.2.A Deployment of FLEX Equipment (Snow, Ice and Extreme In Progress.

Cold) - Confirm availability of snow removal equipment to This item will be facilitate deployment of FLEX equipment. addressed by update to AQ JAF-001 response when information is available.

3.2.1.1.A Computer Code Used for Extended Loss of AC Power In Progress.

(ELAP) Analysis - Benchmarks need to be identified and This item will be discussed which demonstrate that Modular Accident addressed by update to Analysis Program (MAAP) is an appropriate code for the AQ JAF-009 response simulation of an ELAP event at JAF. when information is available.

3.2.1.1.B Computer Code Used for ELAP Analysis -Confirm that In Progress.

the collapsed level remains above Top of Active Fuel This item will be (TAF) and the cool down rate is within technical addressed by update to specifications limits. AQ JAF-012 response when information is available.

3.2.1.1.C Computer Code Used for ELAP Analysis - Confirm that In Progress.

MAAP was used in accordance with Sections 4.1, 4.2, This item will be 4.3, 4.4, and 4.5 of the June 2013 position paper addressed by update to (ADAMS Accession No. ML13190A201). AQ JAF-010 response when information is available.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.1.1.D Computer Code Used for ELAP Analysis - Confirm that In Progress.

the licensee, in using MAAP, identified and justified the This item will be subset of key modeling parameters cited from Tables 4-1 addressed by update to through 4-6 of the "MAAP Application Guidance, Desktop AQ JAF-011 response Reference for Using MAAP Software, Revision 2" when information is (Electric Power Research Institute Report 1 020236). available.

3.2.1.1.E Computer Code Used for ELAP Analysis - Confirm that In Progress.

the specific MAAP analysis case that was used to This item will be validate the timing of mitigating strategies in the addressed by update to Integrated Plan has been identified and is available for AQ JAF-009 response NRC staff to review. Alternately, a comparable level of when information is information has been included in the supplemental available.

response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached {the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within technical specifications limits.

3.2.1.2.A Recirculation Pump Seal Leakage Models - Confirm the In Progress.

seal leakage model used in the updated MAAP analysis This item will be (which will address the MAAP code limitations when addressed by update to used for ELAP analysis). Evaluate the seal leakage rate AQ JAF-014 response model used, the details of the seal qualification tests and when information is supporting test data, and leakage rate pressure- available.

dependence.

3.2.1.3.A Sequence of Events (SOE) - Confirm the SOE timeline In Progress.

after reanalysis using the MAAP code which will address This item will be the limitations when used for the ELAP analysis. addressed by updated AQ JAF-012 response when information is available.

3.2.1.4.A Systems and Components for Consequence Mitigation - In Progress.

Confirm sizing of the FLEX pumps and 600 Vac FLEX This item will be diesel generator (DG) and the 4160 Vac generator to be addressed by update to obtained from the RRC. AQ JAF-022 response when information is available.

3.2.1.5.A Monitoring Instrumentation and Controls- Confirm ac This item is addressed powered torus temperature, pressure and level and by updated AQ JAF-drywell temperature and pressure instrumentation is 006 response.

modified to remain powered during an ELAP.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.1.8.A Use of Portable Pumps - Confirm that the use of raw In Progress.

water from Lake Ontario for long term core and spent fuel This item will be pool cooling strategies is acceptable. addressed by update to AQ JAF-023 response when information is available.

3.2.2.A Spent Fuel Pool Cooling - Confirm the method of This item is addressed ventilation and power requirements, if any, of the spent by updated AQ JAF-fuel pool area. 028 response.

3.2.4.2.A Ventilation (Equipment Cooling) - Confirm that additional In Progress.

evaluations of the RCIC room temperature demonstrate This item will be that an acceptable environment is maintained during the addressed by update to transition phase both for equipment in the room and AQ JAF-031 response habitability for operators who may need to enter the when information is room. available.

3.2.4.2.B Ventilation (Equipment Cooling) - Confirm that In Progress.

evaluations of the battery room temperature demonstrate This item will be that an acceptable environment, during both high addressed by update to ambient temperature and during extreme cold ambient AQ JAF-069 response temperature, is maintained during Phases 2 and 3. when information is available.

3.2.4.2.C Ventilation (Equipment Cooling) - Confirm the required In Progress.

ventilation flow or the size of the portable fans to This item will be maintain acceptable environmental conditions in the DC addressed by update to equipment room. AQ JAF-061 response when information is available.

3.2.4.3.A Heat Tracing - Confirm completion of walkdowns and In Progress.

evaluation of where heat tracing may be needed for This item will be freeze protection of equipment or instruments used in the addressed by update to ELAP mitigation strategies. AQ JAF-035 response when information is available.

3.2.4.4.A Lighting - Confirm need for additional portable lighting, In Progress.

such as dc powered lights. This item will be addressed by update to AQ JAF-036 response when information is available.

3.2.4.4.B Communications - Confirm that upgrades to the site's NRC Confirmatory communication system have been completed. Action Page 8 of 14

JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Interim Staff Evaluation Confirmatory Items Status 3.2.4.8.A Electrical Power Sources - Confirm the technical basis In Progress.

for the selection and size of the FLEX generators to be This item will be used in support of the coping strategies. addressed by update to AQ JAF-050 response when information is available.

3.2.4.10.A Load Reduction to Conserve DC Power - Confirm final In Progress.

load shed list and the evaluation of any potential adverse This item will be effects of shedding those loads. addressed by update to AQ JAF-052 response when information is available.

3.2.4.10.B Load Reduction to Conserve DC Power - Confirm the In Progress.

final dc load profile with the required loads and the This item will be finalized minimum battery voltage. addressed by update to AQ JAF-066 response when information is available.

3.2.4.10.C Load Reduction to Conserve DC Power- Confirm time In Progress.

after the ELAP for connecting the FLEX DG to the battery This item will be chargers. addressed by update to AQ JAF-052 response when information is available.

3.4.A Off-site Resources- Confirm that NEI 12-06, Section 12.2 In Progress.

guidelines 2 through 10 are addressed, or that an This item will be appropriate alternative is justified. addressed by update to AQ JAF-043 response when information is available.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Completion or Status Questions Target Date In progress - This AQ response will be updated when information is available (associated with ISE Open Item JAF-001 August 2015 3.1.3.1.A and ISE Confirmatory Items 3.1.1.2.B, 3.1.1.2.C, 3.1.3.2.B, 3.1.4.2.A)

In progress - This AQ response will be updated when August 2015 JAF-002 information is available (associated with ISE Confirmatory Item 3.1.1.2.A)

In progress - This AQ response will be updated when August 2015 JAF-003 information is available In progress - This AQ response will be updated when August 2015 JAF-004 information is available In progress - This AQ response will be updated when August 2015 JAF-005 information is available (associated with ISE Open Item 3.1.1.3.A)

Updated response available on the ePortal (associated Closed JAF-006 with ISE Confirmatory Item 3.2.1.5.A)

In progress - This AQ response will be updated when August 2015 JAF-008 information is available In progress - This AQ response will be updated when August 2015 JAF-009 information is available (associated with ISE Confirmatory Items 3.2.1.1.A, 3.2.1.1.E)

In progress - This AQ response will be updated when August 2015 JAF-010 information is available (associated with ISE Confirmatory Item 3.2.1.1.C)

In progress - This AQ response will be updated when August 2015 JAF-011 information is available (associated with ISE Confirmatory Item 3.2.1.1.D)

In progress - This AQ response will be updated when August 2015 JAF-012 information is available (associated with ISE Confirmatory Items 3.2.1.1.B, 3.2.1.3.A)

In progress - This AQ response will be updated when August 2015 JAF-013 information is available In progress - This AQ response will be updated when August 2015 JAF-014 information is available (associated with ISE Confirmatory Item 3.2.1.2.A)

JAF-015 Response available on the ePortal Closed JAF-016 Response available on the ePortal Closed Page 10 of 14

JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Completion or Status Questions Target Date In progress - This AQ response will be updated when JAF-017 information is available (associated with ISE Open Item August 2015 3.2.3.A)

JAF-018 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-019 information is available JAF-021 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-022 information is available (associated with ISE Confirmatory Items 3.2.1.4.A)

In progress - This AQ response will be updated when August 2015 JAF-023 information is available (associated with ISE Confirmatory Item 3.2.1.8.A)

JAF-026 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-027 information is available Updated response available on the ePortal (associated Closed JAF-028 with ISE Confirmatory Item 3.2.2.A)

JAF-029 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-031 information is available (associated with ISE Confirmatory Item 3.2.4.2.A)

JAF-032 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-033 information is available JAF-034 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-035 information is available (associated with ISE Confirmatory Item 3.2.4.3.A)

In progress - This AQ response will be updated when August 2015 JAF-036 information is available (associated with ISE Confirmatory Item 3.2.4.4.A)

JAF-037 Response available on the ePortal Closed JAF-038 Response available on the ePortal Closed Page 11 of 14

JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Completion or Status Questions Target Date In progress - This AQ response will be updated when August 2015 JAF-040 information is available In progress - This AQ response will be updated when August 2015 JAF-043 information is available (associated with ISE Confirmatory Items 3.1.1.4.A, 3.4.A)

JAF-046 Response available on the ePortal Closed JAF-049 Response available on the ePortal Closed In progress - This AQ response will be updated when JAF-050 information is available (associated with ISE August 2015 Confirmatory Item 3.2.4.8.A)

In progress - This AQ response will be updated when JAF-052 information is available (associated with ISE August 2015 Confirmatory Items 3.2.4.10.A, 3.2.4.10.C)

JAF-053 Response available on the ePortal Closed JAF-055 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-056 information is available JAF-057 Response available on the ePortal Closed JAF-058 Response available on the ePortal Closed JAF-059 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-060 information is available In progress - This AQ response will be updated when August 2015 JAF-061 information is available (associated with ISE Confirmatory Item 3.2.4.2.C)

In progress - This AQ response will be updated when August 2015 JAF-062 information is available JAF-063 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-064 information is available In progress - This AQ response will be updated when August 2015 JAF-065 information is available In progress - This AQ response will be updated when August 2015 JAF-066 information is available (associated with ISE Confirmatory Item 3.2.4.10.B)

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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 Completion or Status Questions Target Date JAF-068 Response available on the ePortal Closed In progress - This AQ response will be updated when August 2015 JAF-069 information is available (associated with ISE Confirmatory Item 3.2.4.2.B)

JAF-071 Response available on the ePortal Closed JAF-072 Response available on the ePortal Closed JAF-073 Response available on the ePortal Closed

• Closed indicates that Entergys response is complete.

7. Potential Interim Staff Evaluation Impacts As discussed in Section 4, changes to the compliance method as documented in the Overall Integrated Plan (Reference 1 and 3) are being considered during the preliminary design phase of the project. In addition to the compliance method items identified in Section 4, the items discussed below have potential impact on the Interim Staff Evaluation if adopted in the final design.

ISE/TER Section 3.2.1.8, Page 34, the TER states, the existing installed RCIC pump will draw water from either the suppression pool or the CST, and inject water into the reactor pressure vessel. For the proposed revised strategy, the RCIC pump will draw water from the CST and its suction will not swap to the suppression pool.

ISE/TER Section 3.2.1.8, Page 34, the TER states, in Phase 2, the licensee stated that a portable FLEX pump can be used to draw water from the intake bay and pump it through a temporary hose connected to the RHRSW system. The Phase 2 proposed revised strategy does not utilize a portable pump to provide core cooling. The proposed revised strategy utilizes one of the diesel driven fire pumps to provide injection to the RPV with suction from the intake bay.

ISE/TER Section 3.2.1.8, Page 34, the TER states, This portable pump can also be used to provide makeup water to the CST. For the proposed revised strategy, replenishment of the CST is no longer part of the credited FLEX strategy.

ISE/TER, Section 3.2.4.7, Page 47, the TER states, The licensee stated that during an ELAP, at approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> event time, operators will manually transfer RCIC suction to the SP. The RCIC suction path will remain aligned to the SP until the SP temperature reaches about 170 degrees Fahrenheit. This is expected to occur at approximately 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> event time. Operators will then shift the RCIC suction path back to the CSTs. The licensee stated that the combined water volumes of the SP and the CSTs are expected to provide core cooling for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> without refilling the CSTs. The proposed revised strategy does not swap suction from the CST to the suppression pool.

Based on this proposed revised strategy, the CST inventory is expected to provide core cooling for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. At this time core cooling will be provided by water supplied from one of the diesel driven fire pumps with suction from the intake bay.

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JAFP-15-0026 Attachment James A. FitzPatrick Nuclear Power Plants (JAF) Fourth 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

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

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.

4. NRC letter, James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF1077), dated February 21, 2014

5. Entergy to NRC, 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 Number EA 049), dated February 28, 2014

6. Entergy to NRC, JAFP-14-0105, Third 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 049), dated August 28, 2014 Page 14 of 14