NL-14-110, Third Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Third Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML14251A227
Person / Time
Site:	Indian Point
Issue date:	08/27/2014
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-14-110, TAC MF0744, TAC MF0745
Download: ML14251A227 (19)

Text

'% Entergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President NL-14-110 August 27, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCES:

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

Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

1.

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

2.

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

3.

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

Implementation Guide, Revision 0, dated August 2012

4.

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

5.

Entergy letter to NRC (NL-1 3-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2013

6.

Entergy letter to NRC (NL-1 3-110), 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 A

V6 \\

NL-14-110 Dockets 50-247 and 50-286 Page 2 of 3 (TAC Nos. MF0744 and MF0745), dated August 27, 2013 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

Dear Sir or Madam:

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

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

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

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

Reference 5 provided the Entergy overall integrated plan.

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

Reference 7 provided the second six-month status report. The purpose of this letter is to provide the third 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. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Affairs at (914) 254-6710.

I declarjegnder penalty of perjury that the foregoing is true and correct; executed on Augusto.-/, 2014.

Sincerely,

Attachment:

Indian Point Energy Center's Third Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc:

Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL

NL-14-110 Dockets 50-247 and 50-286 Page 3 of 3 Mr. William M. Dean, 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-14-110 INDIAN POINT ENERGY CENTER'S THIRD SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-049 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 1 of 15 Indian Point Energy Center's Third Six Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Indian Point Energy Center (IPEC), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 5), 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 January 31, 2014, and are current as of July 31, 2014:

Second Six-Month Status Report -

February 2014 Third Six-Month Status Report -

Complete with submission of this document in August 2014 N-1 Walkdown (Unit 2) - Spring 2014 Design Engineering (Unit 3) - Spring 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. The milestone listing includes Unit 2 and Unit 3 sections for unit specific milestones.

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

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

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 2 of. 15 Target Revised Target Milestone Completion Activity Status Completion Date*

Date Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Perform Staffing Analysis Nov 2014 Started Off-site FLEX Equipment Develop Strategies with RRC Oct 2015 Started Procedures PWROG issues NSSS-specific Jan 2014 Complete Issued guidelines May 2013 Validation I Demonstration May 2016 Not Started Submit Completion Report Jun 2016 Not Started Spring 2015 IPEC Unit 3 Submit Completion Report Jun 2016 Not Started IPEC Unit 2 Unit 2 Specific Milestones Modifications Engineering and Implementation N-1 Walkdown (Unit 2)

Spring 2014 Completed Design Engineering Dec 2014 Started Unit 2 Implementation Outage Apr 2016 Not Started On-site FLEX Equipment Purchase / Procure Dec 2015 Started Off-site FLEX Equipment Develop Strategies with RRC Oct 2015 Started Procedures Create Indian Point FSG Oct 2015 Not Started Create Maintenance Oct 2015 Not Started Procedures Training:

Develop Training Plan Aug 2015 Started Implement Training April 2016 Not Started

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 3 of 15 Target Revised Target Milestone Completion Activity Status Completion Date*

Date Unit 3 Specific Milestones Modifications Engineering and Implementation N-1 Walkdown (Unit 3)

Spring 2014 Completed Design Engineering Dec 2014 Completed Unit 3 Implementation Outage Apr 2015 Not Started On-site FLEX Equipment Purchase / Procure Dec 2014 Started Procedures Create Indian Point FSG Oct 2014 Started Create Maintenance Procedures Oct 2014 Started Training:

Develop Training Plan Nov 2014 Completed Implement Training Apr 2015 Started

• - Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at IPEC, changes have been identified to the compliance strategies as described in the original OIP (Reference 1).

Pages 16, 17, 28, 39, and 49 of the OIP indicate that portable FLEX equipment will be stored in the existing Unit 1 Chemical Systems Building. The Unit 1 Chemical Systems Building is no longer the selected means of storage for FLEX equipment. An existing structure will be utilized as a robust structure to house the Units 2 and 3 portable FLEX equipment. Modifications will be performed to this building to ensure that it will meet the requirements of NEI 12-06. After modified for FLEX, this building will be referred to as the FLEX Equipment Storage Building (FESB).

On Page 44 of the OIP, it is stated, "Additional equipment may be required to be powered during this event such as portable lighting and ventilation fans. These are not conveniently powered via the FLEX generator." For IPEC Unit 3 the current strategy is to restore ventilation to the control room and the battery room with the Phase 2 portable generator. Lighting panels for high priority areas (e.g.,

control building, control room, and some primary auxiliary building rooms) will also be repowered by the Phase 2 portable generator. For IPEC Unit 2, the design analysis is in progress. Restoration of the HVAC to the control room, the

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 4 of 15 battery room, and lighting panels to high priority areas with the Phase 2 generator is still to be determined.

The Phase 2 electrical strategy, as described on Pages 44 through 46 of the OIP, has changed such that the FLEX generator primary connection for IPEC Unit 3 will power Bus 5A, and for IPEC Unit 2 will power Bus 2A through a spare breaker in a "plug and play" configuration, with the secondary connections powering Bus 3A and Bus 5A through reconfiguration of terminations.

The Unit 2 electrical strategy is still in design implementation.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation IPEC 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 a listing of Audit Questions and the status of each item.

Overall Integrated Plan Open Item Status There were no open items documented in the IPEC Overall N/A Integrated Plan Interim Staff Evaluation Open Items Status 3.1.2.A Review of the licensee's new flooding level The initial flooding evaluation results and its potential impact on the assessment has been flooding hazard analyses previously provided in completed for a 500,000 their Integrated Plan and during the audit year flood and was process is identified as an Open Item. If the submitted to the NRC in flooding levels are modified based on the results Dec 2013. There are of this review, it may affect the evaluation of the currently no major deployment described in Section 3.1.2.2 of this changes in FLEX evaluation, strategy based on the flooding evaluation. This item is addressed by updated Audit Question (AQ) IPEC-006 response.

3.2.4.7.A It is noted that NEI 12-06 guidance only credits The Tank Tornado water supplies that are robust with respect to Wind/Missile Evaluation seismic events, floods, and high winds, and the is complete. This item is

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 5 of 15 Interim Staff Evaluation Open Items Status associated missiles. The licensee should addressed by updated determine if a water supply for the SGs and AQ IPEC-041 response.

RCS would be available after a tornado event by analyzing the tornado characteristics for the site compared to the separation characteristics of the tanks. This is an alternate approach from the strategies identified in NEI 12-06.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Confirm that at least one connection point for This item is addressed by the FLEX AFW pump is accessible and is updated AQ IPEC-036 located inside a building that is seismically response*.

robust as described in Consideration 2 of NEI 12-06, Section 5.3.2.

3.1.1.2.B Confirm that the pickup trucks, forklifts or any This item is addressed other equipment that will be used to deploy the on updated AQ response portable equipment for implementing FLEX spreadsheet on the strategies will be reasonably protected from the ePortal.

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 NRC Confirmatory Action access to all required areas will be assured in the event of a power failure as described in Consideration 5 of NEI 12-06, Section 5.3.2.

3.1.1.2.D Confirm that the licensee has reviewed the This item is addressed by deployment paths from the near site storage updated AQ IPEC-002 areas to the site and from the onsite storage response.

areas to the deployment location to verify that these paths are not subject to soil liquefaction concerns as described in Consideration 1 of NEI 12-06, Section 5.3.2.

3.1.1.3.A Confirm that the licensee's review of the This item is addressed by potential impacts of large internal flooding updated AQ IPEC-004 sources that are not seismically robust and do response*.

not require ac power has been completed per consideration 2 of NEI 12-06, Section 5.3.3.

3.1.1.4.A Confirm that the intermediate staging area has This item is addressed by been selected and implementing procedures updated AQ IPEC-005 have been developed, response.

3.1.2.2.A Confirm that evaluations address: whether NRC Confirmatory Action procedures have been established for actions to

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 6 of 15 Interim Staff Evaluation Confirmatory Items Status be taken upon receipt of a hurricane warning; ensuring that fuel in oil storage tanks would not be inundated or damaged by flooding; and, whether the means (e.g., trucks) for moving FLEX equipment is reasonably protected from the event.

3.2.1.A Confirm which analysis performed in WCAP-This item is addressed by 17601-P is being applied to Indian Point. Also updated AQ IPEC-012 confirm the licensee has adequately justified the response*.

use of that analysis by identifying and evaluating the important parameters and assumptions demonstrating that they are representative of Indian Point and appropriate for simulating the ELAP transient.

3.2.1. 1.A Confirm that the licensee is using NOTRUMP In Progress.

and has taken into account its limitations.

This item will be Reliance on the NOTRUMP code for the ELAP addressed by update to analysis of Westinghouse plants is limited to the AQ IPEC-012 response flow conditions prior to reflux condensation when Information is initiation. This includes specifying an acceptable available.

definition for reflux condensation cooling.

3.2.1.3.A Confirm that the licensee has satisfactorily This item is addressed by addressed the applicability of Assumption 4 on updated AQ IPEC-013 page 4-13 of WCAP-1 7601 which states that response.

decay heat is per ANS 5.1-1979 + 2 sigma, or equivalent. If the ANS 5.1-1979 + 2 sigma model is used in the Indian Point ELAP analysis, address the adequacy of the use of the decay heat model in terms of the plant-specific values of the following key parameters:

(1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics (addressing whether they are based on the beginning of the cycle, middle of the cycle, or end of the cycle). If a different decay heat model is used, describe the specific model and address the adequacy of the model and the analytical results.

3.2.1.6.A Confirm that the licensee has finalized its This item is addressed by strategy for controlling the RCS pressure to updated AQ IPEC-035 prevent nitrogen from escaping from the safety response*.

I injection accumulators into the RCS until the

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 7 of 15 Interim Staff Evaluation Confirmatory Items Status isolation valves can be closed.

3.2.1.8.A The PWROG submitted to NRC a position paper, dated August 15, 2013, which provides This item is addressed by test data regarding boric acid mixing under updated AQ IPEC-050 single-phase natural circulation conditions and response*.

outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

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

the required times are consistent with the results of the ELAP analysis. Confirm that the licensee discussed the analyses that are used to determine the required flow rate and corresponding total developed head for each of the portable pumps and also to justify that that the required capacities of each of the above-discussed portable pumps are adequate to maintain core cooling and sub-criticality during phases 2 and 3 of ELAP. Confirm that the licensee has included a discussion and justification of computer codes/methods and assumptions used in the analyses above.

3.2.1.9.B Confirm that the licensee has provided an This item is addressed by evaluation that demonstrates flow through a 2-updated AQ IPEC-036 inch connection will be sufficient to provide response*.

adequate flow to maintain the SG level using the alternate SG FLEX pump.

3.2.2.A Confirm that the licensee has satisfactorily This item is addressed by explained the strategy to provide a secondary updated AQ IPEC-034 connection for SFP makeup if the building is response*.

inaccessible, and explain where these valves are and if access to these valves will be available during an ELAP event.

3.2.3.A Confirm that a containment evaluation has been This item is addressed by completed and, based on the results of this updated AQ responsel*.

evaluation; required actions to ensure

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 8 of 15 Interim Staff Evaluation Confirmatory Items Status maintenance of containment integrity and required instrument function will be developed.

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

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

3.2.4.2.B Confirm that hydrogen concentration in the This item is addressed by battery rooms during battery recharging would updated AQ IPEC-047 be maintained at an acceptable level, response*.

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

can be implemented successfully.

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

operators will be capable of FLEX strategy execution under adverse temperature conditions. Examples of areas of concern are the control room, TDABFW pump room, SFP area, and charging pump room.

3.2.4.7.B Confirm that the licensee has evaluated the This item is addressed by acceptability of the missile protection for the updated AQ IPEC-041 Unit 2 BAST.

response.

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

been established and that the total fuel usage has been calculated to demonstrate that sufficient fuel with margin exists on site.

3.2.4.1 0.A Confirm that analysis of the following aspects of This item is addressed by the dc power requirements have been identified updated AQ IPEC-026 and evaluated:

response*.

a.

The dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool cooling;

b.

The loads that will be shed from the dc bus, the equipment location (or location where the required action needs to be taken), and the required operator actions

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 9 of 15 Interim Staff Evaluation Confirmatory Items Status and the time to complete each action

c.

The basis for the minimum dc bus voltage that is required to ensure proper operation of all required electrical equipment.

3.4.A Confirm that the 480V portable/FLEX This item is addressed by generators are adequately sized to supply loads updated AQ IPEC-031 assumed for implementing Phase 2 strategies.

response*.

• The response to the ISE Confirmatory Item addresses Unit 3 only. Once the Unit 2 design analysis and evaluations are completed, the responses will be updated to include Unit 2.

Audit Completion or Questions Status Target Date IPEC-002 Updated response available on the ePortal (ISE Confirmatory Item 3.1.11.2.D)

IPEC-003 Closed*

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.1.1.3.A)

IPEC-004 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.1.1.3.A)

IPEC-005 Updated response available on the ePortal (ISE Confirmatory Item 3.1.1.4.A)

I PEC-006 Updated response available on the ePortal (ISE Open Item 3.1.2.A)

IPEC-008 Closed*

IPEC-009 Updated response available on the ePortal IPEC-010 Updated response available on the ePortal IPEC-01 1 Closed*

IPEC Unit 3 -Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.A)

IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE IPEC-012 Confirmatory Item 3.2.1.A)

In progress - This AQ response will be updated when February 2015 information is available (ISE Confirmatory Item 3.2.1.1.A)

IPEC-013 Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.3.A)

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 10 of 15 Audit Completion or Questions Status Target Date IPEC-014 Closed*

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.9.A)

IPEC-017 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.1.9.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.2.A)

IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE I PEC020 Confirmatory Item 3.2.4.2.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.6.A)

IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.4.6.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.3.A)

IPEC-021 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.4.3.A)

IPEC-022 Updated response available on the ePortal IPEC-023 Closed*

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.9.A)

IPEC-025 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.4.9.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.10.A)

IPEC-026 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.4.10.A)

IPEC-027 Closed*

IPEC-028 Closed*

IPEC-029 IPEC Unit 3 - Updated response available on the

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 11 of 15 Audit Status Completion or Questions Target Date ePortal IPEC Unit 2 - In progress-This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.4.A)

IPEC-031 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.4.A)

IPEC-032 Closed*

IPEC Unit 3 - Updated response available on the ePortal IPEC-033 IPEC Unit 2 - In progress-This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.2.A)

IPEC-034 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.2.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.6.A)

IPEC-035 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.1.6.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.1.1.2.A)

IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE IPEC-036 Confirmatory Item 3.1.1.2.A)

IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.9.B)

IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.1.9.8)

IPEC-037 Closed*

Updated response available on the ePortal (ISE Open IPEC-041 Item 3.2.4.7.A)

Updated response available on the ePortal (ISE

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 12 of 15 Audit Status Completion or Questions Target Date Confirmatory Item 3.2.4.7.B)

IPEC Unit 3 - Updated response available on the ePortal IPEC-042 IPEC Unit 2 - In progress-This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal IPEC-043 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal IPEC-045 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal IPEC-046 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.4.2.B)

IPEC-047 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.4.2.B)

IPEC Unit 3 - Updated response available on the ePortal IPEC-048 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available IPEC-049a Updated response available on the ePortal*

IPEC Unit 3 - Updated response available on the ePortal IPEC-049b IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available IPEC-049c Closed*

IPEC-049d Closed*

IPEC-049e Closed*

IPEC-049f Closed*

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 13 of 15 Audit Status Completion or Questions Target Date IPEC-049g Closed*

IPEC-049h Closed*

IPEC-049i Updated response available on the ePortal IPEC Unit 3 - Updated response available on the ePortal (ISE Confirmatory Item 3.2.1.8.A)

IPEC-050 IPEC Unit 2 - In progress - This AQ response will be February 2015 updated when information is available (ISE Confirmatory Item 3.2.1.8.A)

In progress - This AQ response will be updated when February 2015 information is available

• Closed indicates that Entergy's response is complete.

7 Potential Interim Staff Evaluation Impacts The following items indicate a change and/or update to the items identified in this section during the 2nd Six-Month Status Report.

1. ISE/TER Section 3.1.1.1, Page 6, Item 3, the TER states "On pages 16, 27, 38 and 46 of the Integrated Plan the licensee stated that the storage location of IPEC's FLEX equipment is the existing Unit 1 Chemical Systems Building." Unit 1 Chemical Systems Building is no longer the selected means of storage for FLEX equipment. Indian Point will utilize an existing structure to house the Units 2 and 3 portable FLEX equipment. Modifications will be made to this structure to comply with the requirements of NEI 12-06. After modified for FLEX, this existing structure will be referred as the FLEX Equipment Storage Building (FESB).

2. ISE/TER Section 3.1.1.2, Page 7 and Section 3.1.2.2, Page 13, the TER states "On page 17 of the Integrated Plan, the licensee specified that deployment from the Unit 1 Chemical Systems Building would necessitate...". Unit 1 Chemical Systems Building is no longer selected/accepted means of storage for FLEX equipment. Indian Point will utilize an existing structure to house the Units 2 and 3 portable FLEX equipment. Modifications will be made to this structure to comply with the requirements of NEI 12-06. After modified for FLEX, this existing structure will be referred as the FLEX Equipment Storage Building (FESB).

3. ISE/TER Section 3.1.4.1, Page 20, the TER states "On pages 17, 27, 39 and 47 of the Integrated Plan, the licensee stated that portable equipment would be maintained in climate controlled storage locations to protect it from snow, ice and extreme cold." A climate controlled storage location for the portable equipment is no longer considered. The current plan is to have one FLEX storage building..

There is no heating or air conditioning system for the selected storage facility. For an extreme cold event, the minimum indoor temperature within the first eight hours following the event is approximately -6°F which is within the plant's design basis low temperature. Equipment which cannot tolerate storage in the low

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 14 of 15 temperature conditions has been provided with block heaters. The current plan is Diesel Fuel stored with the FLEX equipment will be exposed to the cold temperature of approximately -6°F (as determined in IP-CALC-14-00033) at the end of eight hours following a BDBEE. The plan is that gelling of the diesel fuel will not be a concern following the BDBEE because the fuel procured at Indian Point 2, will conform to a cloud point of 10°F below the regional temperatures provided in ASTM D975-06. The lowest regional temperature (January is considered for conservatism) for the New York area provided in Table X5.1 of ASTM D975 is approximately 3°F (-16 0C). Therefore, the fuel procured at IP2 would have a rated cloud point of approximately -70F. As the rated cloud point is below the temperatures it will see inside the storage building, gelling of the fuel is not a concern.

4. ISE/TER Section 3.2.1.6, Page 32, the TER states "RCS boration is required for shutdown margin at 23.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />." The current analysis indicates that time for boration (beyond that provided by SI Accumulators) is 22.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for IPEC Unit 3 and 20.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for IPEC Unit 2.

5. ISE/TER Section 3.2.1.9, Page 35, the TER states "This pump will provide core make-up such that a limited period of two phase natural circulation cooling occurs...." Current strategy for IPEC Unit 3 would prevent the two phase condition from occurring (based on injection need time of 16.11 hrs per WCAP-17601 -P Table 5.2.2-1).

6. ISE/TER Section 3.2.4.3, Page 40, the TER states "...the licensee did not adequately address heat tracing." IP-CALC-1 3-00058 addresses the issue of heat tracing for IPEC Unit 3. Draft calculation IP-CALC-14-00043 addresses the issue of heat tracing for IPEC Unit 2. The preliminary results determine that the tanks are relatively immune to freezing.

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

1. Entergy letter to NRC (NL-1 3-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013

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

3. Entergy letter to NRC (NL-1 3-110), 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), dated August 27, 2013

4. NRC letter to Entergy, Indian Point Nuclear Generating Unit Nos. 2 and 3 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order

NL-14-110 Dockets 50-247 and 50-286 Attachment Page 15 of 15 EA-12-049 (Mitigation Strategies) (TAC Nos. MF0744 and MF0745), dated January 24, 2014

5. Entergy letter to NRC (NL-14-031), Indian Point Energy Center's Second Six-Month Status Report for the Implementation of Order EA-1 2-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated February 27, 2014.