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)

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)

ML14059A359
Person / Time
Site:	FitzPatrick
Issue date:	02/28/2014
From:	Coyle L Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, JAFP-14-0023
Download: ML14059A359 (8)

Text

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 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

Dear Sir or Madam:

JAFP-14-0023 Page 2 of 2 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 Page 1 or 5

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 Date*

Activity Status Revised Target Completion Date 60-day Status Update October 29, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Six-Month Status Report August 2013 Complete Refine Strategies December 2014 Started Perform Staffing Analysis December 2013 In progress June 2015 Develop Strategies /

Contract with RRC May 2015 Started Six-Month Status Report February 2014 Complete

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 Page 2 or 5 Milestone Target Completion Date*

Activity Status Revised Target Completion Date Develop Mods June 2015 Not Started Draft Implementing Procedures June 2016 Not Started Regional Response Center Operational July 2015 Started Develop Storage Plan June 2015 Started Purchase FLEX Equipment Fall 2016 Not Started Issue Maintenance Procedures (for FLEX equipment)

Fall 2016 Not Started 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-outage)

June 2015 Not Started Six-Month Status Report August 2015 Not Started Six-Month Status Report February 2016 Not Started Issue Implementing Procedures May 2016 Not Started Six-Month Status Report August 2016 Not Started Implement Mods (outage)

Fall 2016 Not Started Implement Training Updates Fall 2016 Not Started Refueling Outage 2 (full implementation)

Fall 2016 Not Started 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.

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 Page 3 or 5

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 requirements in existing licensing documents will be determined based on input from the industry groups and direction from the NRC.

Not Started OI-2: The structure, content and details of the Regional Response Center playbook will be determined.

Started Interim Staff Evaluation Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has not issued an Interim Staff Evaluation for JAF; therefore, there are no open items for the Interim Staff Evaluation identified at this time.

N/A Interim Staff Evaluation Confirmatory Items Status The U.S. Nuclear Regulatory Commission (NRC) has not issued an Interim Staff Evaluation for JAF; therefore, there are no confirmatory items for the Interim Staff Evaluation identified at this time.

N/A 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

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 Page 4 or 5 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

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 Page 5 or 5 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.