W3F1-2014-0050, Third Six-Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Waterford Steam Electric Station, Un

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

ML14241A270
Person / Time
Site:	Waterford
Issue date:	08/28/2014
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, W3F1-2014-0050
Download: ML14241A270 (19)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057 70057-3093 Tel 504 504-739-6660 Fax 504 504-739-6678 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 W3F1-2014 2014-0050 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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

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

References:

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

2. NRC Interim Staff Guidance JLD-ISG ISG-2012-01, 01, Compliance with Order EA-12-049, 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Design-Basis External Events, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174)

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

4. Entergy letter to NRC, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Beyond-Design-BasisBasis External Events (Order Number EA EA-12-049), dated October 26, 2012 (W3F1-2012 2012-0093) (ADAMS Accession No. ML12300A447)

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

W3FI -20140050 Page 2 of 3 6 waterrorci Steam Electric Station, Unit 3 letter to NRC, UR Six Month Status Reportfor Implementation of Order EA-12-049, Commission Order Modifying Ucense Wtth Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated August28, 201 3 (ADAMS Accession No. MLI 3241a281) 7 Waterford Steam Electric Station, Unit 3 letter to NRC, Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying Ucense With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events dated February 28, 2014 (ADAMS Accession No. ML14059A085)

Dear Sir or Madam:

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

Reference I required submission of an initial status report 60 days following issuan ce of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP).

Reference 2 endorses industry guidance document NEI 12-02, RevIsion I (Reference 3). Refere provided the initial status report regarding mitigating strategies and Reference nce 4 5 provided the OIR NRC Order EA-12-049 requires submission of a status report at six-month interva ls submittal of the Overall Integrated Plan with regard to the requirements for mitiga following tion strategies for beyond-design-basis external events for Waterford 3. References 6 and 7 provid ed the first and second six-month status reports for Waterford 3 respectively. The purpose of this letter is to provide, as an attachment, the third six month status report for the implementatio EA-1 2-049. n of Order There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact John Jarrell, Regulatory Assura Manager, at (504) 739-6685.

nce I declare under penalty of perjury that the foregoing is true and correct. Execut ed on August 28, 2014.

Sincerely, 7

4 stJ*

MRC1LEM

Attachment:

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

W3F1-2014-0050 Page 3 of 3 cc: Attn: Director, Office of Nuclear Reactor Regulation U. S. NRC RidsNrrMailCenter@nrc.gov Mr. Mark L. Dapas, Regional Administrator U. S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Project Manager for Waterford 3 Michael.Orenak@nrc.gov NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov

Attachment W3F1-2014-00050 Waterford Steam Electric Station, Unit 3, Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to the Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Attachment to W3F1-2014-0050 Page 1 of 15 Waterford Steam Electric Station, Unit 3, Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to the Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Waterford Steam Electric Station, Unit 3 (Waterford 3), developed an Overall Integrated Plan (Reference 1 in Section 8) documenting the diverse and flexible strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). This attachment provides a planned update of milestone accomplishments since submittal of the last status report (Reference 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 the development of the Overall Integrated Plan (OIP), and are current as of July 31, 2014.

First Six-Month Status Report August 2013 Second Six-Month Status Report February 2014 N-1 Walkdowns - May 2014 Third Six-Month Status Report Complete with submission of this document in August 2014 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. This section provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Revised Target Target Milestone Completion Activity Status Completion Date **

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

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Not Started No Change Update 5 Aug 2015 Not Started No Change Perform Staffing Analysis Nov 2015 Not Started No Change

Attachment to W3F1-2014-0050 Page 2 of 15 Revised Target Target Milestone Completion Activity Status Completion Date **

Date Modifications:

Engineering and Implementation N-1 Walkdowns May 2014 Complete N/A Design Engineering Oct 2014 Started Dec 2014 Implementation Outage Nov 2015 Not Started No Change On-site FLEX Equipment Purchase Dec 2014 Started No Change Procure Sept 2015 Started No Change Off-site FLEX Equipment Develop Strategies with RRC April 2015 Started No Change Install Off-Site Delivery Nov 2015 Not Started No Change Station (if Necessary)

Procedures Create Waterford FSGs Nov 2015 Not Started No Change Create Maintenance Procedures Nov 2015 Not Started No Change Training Develop Training Plan May 2015 Not Started No Change Implement Training Nov 2015 Not Started No Change Submit Completion Report Feb 2016* Not Started No Change

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

• • Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports 4 Changes to Compliance Method During the design phase of the Waterford 3 (WF3) FLEX project, changes were identified to the compliance strategies as described in the Overall Integrated Plan (Reference 1). The changes are summarized below. The changes will be incorporated into a future update.

The SFP makeup strategy is being changed to credit installed component cooling water makeup pumps to supply coolant to the spent fuel pool via hardened piping. The use of component cooling water makeup to provide SFP makeup in lieu of portable pumps for the Phase 2 strategy would be an alternate method to NEI 12-06 for meeting the Order.

Attachment to W3F1-2014-0050 Page 3 of 15 There are two redundant pumps, both will be capable of being powered from either electrical train. The pumps and associated electrical distribution are protected from all applicable extreme external hazards and are contained within the Reactor Auxiliary Building (RAB). Operation of the pumps and alignment of all valves would be external to the SFP area. The pumps are capable of 600 gpm flow, which significantly exceeds the makeup rates required for SFP makeup (< 150 gpm). The source of coolant for the component cooling water makeup pumps will be either the RWSP or the WCT basins via FLEX temporary hoses and system tie-ins. The final SFP makeup strategy will be reported upon in the Fourth Six Month Update when design has been completed.

The RCS makeup strategy is being reconsidered to credit the installed charging pumps to supply coolant to the reactor coolant system. FLEX tie-ins would remain available for use by Phase 3 equipment and by the FLEX Core Cooling Pump during Modes 5 and 6 with the steam generators not available. The use of the installed charging pumps to supply coolant to the reactor coolant system in lieu of portable pumps for the Phase 2 strategy would be an alternate method to NEI 12-06 for meeting the Order.

As discussed in the OIP, the charging pumps are capable of providing 44 gpm each, which exceeds the 25 gpm makeup required to maintain natural circulation and shutdown margin within the RCS. There are three charging pumps, of which two of the three can be powered from either electrical train. The charging pumps are protected from all applicable extreme external hazards and are contained within the RAB. The use of the charging pumps for RCS makeup rather than a portable pump reduces the difficulty of deploying RCS makeup early in the event when resources are challenged and site access is limited. The final RCS makeup strategy will be reported upon in the Fourth Six Month Update when design has been completed.

The strategy of drawing WCT basin water through a non-running ACCWS pump is being changed to instead establish a gravity drain path directly to TDEFW pump suction, bypassing the non-running ACCWS pump and high point piping. The associated water transfer strategy to replenish the WCT basins from the Mississippi River is being reconsidered and will be reported upon in the Fourth Six Month Update when design has been completed.

As discussed in WF3 Interim Staff Evaluation and Audit Report Section 3.0 (ADAMS Accession No. ML13220A402) and identified as ISE Confirmatory Item 3.1.1.2.B, the NRC concluded that:

Entergy does not conform to the NEI 12-06 guidance for provision of a means to move the spare or "N+1" set of FLEX equipment that is reasonably protected from the event. However, through the audit process the NRC understands that Entergy recognizes that this could result in the unavailability of the site FLEX capability (N) under certain conditions. Entergy plans to impose additional unavailability controls for the pre-staged set of equipment. With the associated equipment unavailability controls, the NRC staff concludes that corresponding level of equipment availability is consistent with the intent of NEI 12-06, and that this would be acceptable as an alternate approach to the guidance of NEI 12-06. Therefore, based on the current understanding of Entergy's plans for unavailability controls for the "N" and "N+1" sets of equipment, the NRC staff views the proposed approach as conditionally acceptable Entergy is utilizing the following alternate method to NEI 12-06 to meet the Order.

Attachment to W3F1-2014-0050 Page 4 of 15 If only N sets of equipment are protected and deployable under the required conditions, and a required protected component of the N portable equipment becomes unavailable, NEI 12-06, Section 11.5.3.f would be applied. NEI 12-06, Section 11.5.3.f states:

If portable equipment becomes unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

For example, consider a portable pump (N) stored in a structure designed to protect the equipment from the hypothetical flood, while the spare pump (+1) is stored in a location below the flood level which could not be relocated prior to the arrival of potentially damaging flood levels (NEI 12-06, Section 6.2.3.1). Upon discovery of the unavailability of the hazard-protected pump (N), the licensee would initiate action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the site FLEX capability (N) associated with the pump and implement compensatory measures within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (NEI 12-06, section 11.5.3.f). The initiation action would typically involve initiation of a work authorization. Available options to restore site FLEX capability might include restoring the availability of the pump (N), or moving the (+1) pump to a location protected from the hypothetical flood, or moving the (+1) pump to a location from which it could be further moved prior to the arrival of a potentially damaging flood level. If the (+1) pump was moved to a hazard-protected location, the licensee would exit the actions of Section 11.5.3.f, but would still continue with the actions of 11.5.3.b (Portable equipment may be unavailable for 90 days provided that the site FLEX capability (N) is available) until the N+1 capability was restored.

Additionally see updated response on the ePortal to Audit Question WF3-004 that reflects this strategy.

Consistent with the OIP and ISE, Waterford will pre-stage a FLEX Diesel Generator within a new enclosure on the RAB roof. The finalized location of this enclosure is the RAB +41 roof located on the plant east side next to the train B WCTs. The enclosure will meet the plant design basis for high winds and tornado missiles, will be seismically robust, and is above the site maximum flood elevation. Pre-staging the FLEX Diesel Generator within this enclosure is an alternate method to NEI 12-06 for meeting the Order as the generator is not portable. This strategy is prudent for Waterford due to the extreme external flooding potential that could challenge deployment of a portable generator from an exterior robust storage building. A second +1 diesel generator will be stored within the +1 Storage Building, consistent with the previously described alternate method.

Similar to the FLEX Diesel Generator, and consistent with the OIP and ISE, the FLEX Core Cooling Pump will be pre-staged on the -35 el. of the RAB and is robust for all extreme external hazards. However, the pump has been changed to be non-portable, and installed at its deployment location near the TDEFW pump. The use of a non-portable pump is an alternate method to NEI 12-06 for meeting the Order. Due to the weight of the pump and size of a trailer, mounting of the pump on a trailer and storing on the -35 el. would present significant challenges to the operators to deploy this pump by the time the FLEX Diesel Generator is available to supply power to the pump. The pump

Attachment to W3F1-2014-0050 Page 5 of 15 is capable of receiving power from either electrical train via FLEX temporary cables, and will be utilized to provide flow to either the SGs via FLEX tie-in connections on EFW piping or the RCS via FLEX tie-in connections on HPSI piping dependent on the initial mode that the event occurs. A second +1 FLEX Core Cooling Pump will be stored within the N+1 storage building, consistent with the previously described alternate method.

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

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table provide a summary and status of any open items documented in the overall integrated plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes a listing of Audit Questions and the status of each item.

Overall Integrated Plan Open Item Status OI1. The suction path from the TDEFWP to the WCTs would be Closed - The suction through a non-running ACCWS pump post-ELAP. It is path has been expected that both the TDEFWP and the currently sized EFW evaluated and is FLEX pump (primary strategy) will have sufficient capability insufficient for the FLEX and/or NPSH to do so. However, this will need to be confirmed strategy. Change to the more fully as the detailed design of the primary strategy for strategy includes new maintaining core cooling and heat removal evolves (with SGs modifications to allow a available). gravity drain from WCTs directly to the TDEFW suction, bypassing the non-running ACCWS pump and any high points in the associated piping.

OI2. An analysis will be needed to demonstrate that containment In Progress -

pressure and temperature will stay at acceptable levels Preliminary results throughout the ELAP event and that no containment spray indicate that system will be required as part of FLEX. containment spray will not be required as part of FLEX.

This item will be addressed by update to AQ WF3-030 response when information is finalized.

OI3. At this stage of the conceptual design, the chemistry In Progress - This OIP effects of alternate cooling source (ACS) use on Open Item will be

Attachment to W3F1-2014-0050 Page 6 of 15 Overall Integrated Plan Open Item Status secondary wetted components are unknown. updated when information is available OI4. It is currently unclear how long gravity feed from the SITs can Closed - The SITs are be maintained during Modes 5 and 6 in Phase 1. The ability to assumed to be not gravity feed depends upon SIT fluid height/backpressure, line available in Modes 5 losses through the gravity flow path, and developed pressure and 6.

within the RCS. If this time is sufficiently short, Waterford 3 RCS makeup will be may choose to pre-stage requisite FLEX equipment in Modes 5 provided by the new and 6. FLEX Core Cooling Pump in Modes 5 and 6.

OI5. It is expected that only the component cooling water system In Progress - This OIP and dry cooling towers will need to be made operational to Open Item will be reject the heat load generated post-ELAP in Phase 3. updated when information However, this must be investigated more fully to confirm is available.

such. Notably, only 60% of the dry cooling tower fan motors are currently missile protected and none of the wet cooling tower (WCT) fan motors are missile protected. If more than 60% of dry cooling tower (DCT) capacity is needed to support Phase 3, DCT and/or WCT fan motors may need to be missile protected. Currently available information follows:

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

Interim Staff Evaluation Open Items Status 3.1.3.A Wind Hazard Screening - The licensee's response The site takes fails to consider the warning time offered by a considerable actions hurricane storm for pre-staging FLEX equipment. In depending on the addition, as described in NEI 12-06, Section 7.2.2, severity of an incoming hurricanes can have a significant impact on local storm or flood, up to infrastructure, e.g., downed trees and flooding that and including should be considered in the interface with off- site conducting a plant resources. shutdown followed by a cooldown to Mode 5. At least one set of FLEX

Attachment to W3F1-2014-0050 Page 7 of 15 Interim Staff Evaluation Open Items Status equipment is protected from all hazards (robust per NEI 12-

06) and is pre-staged by design.

3.2.1.1.B CENTS - Justify conformance with the limitations of the The site-specific use of CENTS by providing the CENTS-calculated CENTS cases have value of the centered one-hour moving average of the been preliminarily re-flow quality at the top of the SG tubes, which evaluated to conform to corresponds to the maximum void fraction of 0.2 in SG the limitations of the tubes as conditions used to define termination of single use of CENTS. The phase natural circulation, and confirming that the value transition to reflux is less than the limit specified in the white paper dated cooling considered is September 24, 2013 for use in defining the onset of based on the flow reflux being. quality at the top of the SG U-tubes. The transition is assumed to occur once the flow quality exceeds 0.10 based on a one hour center moving average.

This is in conformance with the use of CENTS as approved by the NRC in ML13276A555 (e.g., CENTS analysis is utilized to project when the transition to reflux cooling is projected and strategy based actions are taken prior to this transition to provide makeup).

Revised response to AQ WF3-017 has been provided on the ePortal.

3.2.1.2.A RCP Seal Leakage - Justification of less than 15 As reported in Second gpm per RCP seal leakage in analysis. Six Month Update, the RCP seal leakage for Waterford is assumed to be no greater than 15 gpm per RCP.

3.2.1.2.B RCP generic seal question regarding: (1) the analysis This item addressed by used to determine the leakage rate, (2) cold leg updated AQ WF3-018

Attachment to W3F1-2014-0050 Page 8 of 15 Interim Staff Evaluation Open Items Status subcooling, (3) leakage flow path characteristics after response.

seal failure, (4) seal performance at high temperatures, (5) isolation of controlled bleed off lines, and (6) pressure dependent seal leakage rates.

3.2.1.3.A Decay Heat -Assumption 4 on page 4-13 of WCAP- This item addressed by 17601 states that decay heat is per ANS [American updated AQ WF3-021 Nuclear Society] 5.1-1979 + 2 sigma, or equivalent. response.

Address the applicability of assumption 4 to Waterford.

If the ANS 5.1- 1979 + 2 sigma model is used in the Waterford ELAP analysis, address the adequacy of the use of the decay heat model in terms of the plant-specific values of the following key parameters: (1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics (addressing whether they are based on the beginning of the cycle, middle of the cycle, or end of the cycle). If a different decay heat model is used, describe the specific model and address the adequacy of the model and the analytical results.

3.2.1.8.A Core Sub-Criticality- Regarding boron mixing, the The NRC has accepted NRC staff has not yet accepted the PWROG the PWROG position

[Pressurized Water Reactor Owners Group] position paper on boron mixing paper on boron mixing. Therefore, additional technical per ML13276A183.

justification will be needed to resolve this issue, both Waterford conforms to generically and on a plant-specific basis. the industry boron mixing position.

3.2.4.2.A Ventilation - Adequacy of ventilation in the control This item addressed by room to protect energized equipment throughout the updated AQ WF3-032 entire ELAP event, especially if the ELAP is due to response.

high temperature hazard.

3.2.4.2.B Ventilation- Effects of elevated temperatures in the This item addressed by battery room, especially if the ELAP is due to a high updated AQ WF3-032 temperature hazard. response.

3.2.4.2.C Ventilation - Hydrogen concentration in the battery This item addressed by rooms during recharging updated AQ WF3-032 response.

3.2.4.2.D Ventilation - Loss of ventilation and any potential This item addressed by impacts on the necessary equipment in the TDEFW updated AQ WF3-032 pump room. response.

3.2.4.4.A Lighting - Review the licensee's assessment of the This item is addressed habitability/accessibility requirements to ensure by updated AQ WF3-

Attachment to W3F1-2014-0050 Page 9 of 15 Interim Staff Evaluation Open Items Status lighting is appropriately addressed. 034 response.

3.2.4.8.A Electrical Power Sources/Isolation and Interactions- In Progress - Revised Provide a summary of the sizing calculations used to response to associated determine the adequacy of the FLEX generators used AQ WF3-041 provided to power plant electrical equipment. on Entergy ePortal on 10/30/13.

3.2.4.10.A Load Reduction to Conserve DC Power - The In Progress - An licensee's Integrated Plan on Page 7 identifies dc updated AQ WF3-041 load shed at hour 1 and 4. With regard to the load response addresses shedding of the dc bus in order to conserve battery part c. of this item.

capacity: The remaining parts of

a. Provide the dc load profile for the mitigation this item will be strategies to maintain core cooling, containment, addressed by update to and SFP cooling during all modes of operation. In AQ WF3-041 response your response, describe any load shedding that is when information is assumed to occur and the actions necessary to available.

complete each load shed. Also provide a detailed discussion on the loads that will be shed from the dc bus, the equipment location (or location where the required action needs to be taken), and the required operator actions necessary and the time to complete each action. In your response, explain which functions are lost as a result of shedding each load and discuss any impact on defense-in- depth strategies and redundancy.

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

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

Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Seismic Protection - Licensee to ensure that: 1) seismic This item is interactions to ensure equipment is not damaged by non- addressed by seismically robust equipment or structures for portable updated AQ WF3-equipment that will be stored outside; 2) how large FLEX 001 response.

equipment such as pumps and power supplies stored inside seismic structures is appropriately secured to protect them during a seismic event; and, 3) where other portable equipment such as hoses and power cables would be stored

Attachment to W3F1-2014-0050 Page 10 of 15 Interim Staff Evaluation Confirmatory Items Status to assure proper protection from a seismic event.

3.1.1.2.A Seismic Deployment - Protection of the connection points for This item is Reactor Coolant System (RCS) inventory control during the addressed by final phase is yet to be determined (TBD). update to AQ WF3-003 response.

3.1.1.2.B Seismic Protection - Protection of the tow vehicle used to This item is move the spare or "N+1" FLEX generator. (Also tied into to addressed by the ability to move equipment in the flooding context updated AQ WF3-discussed in Section 3.1.2.2 and wind protection for the 004 response.

vehicle discussed in Section 3.1.3.2) 3.1.1.3.A Seismic Procedural Interface - Seismic hazards associated In Progress - This with large internal flooding sources that are not seismically item will be robust and do not require ac power, and the use of ac power addressed by to mitigate ground water in critical locations. updated AQ WF3-005 response when information is available.

3.1.1.4.A Seismic Off site resources - The licensee has not yet This item is identified the local staging area and method of transportation addressed by to the site. updated AQ WF3-006 response.

3.1.2.2.A Flooding Deployment- Implementation of flooding In Progress - This persistence into their FLEX strategies for pre-event staging item will be of FLEX equipment. addressed by update to AQ WF3-007 response when information is available.

3.1.2.3.A Flooding Procedural Interface- Deployment of portable In Progress - This equipment in flooded conditions not incorporated into flood item will be procedures or the need to deploy temporary flood barriers addressed by and extraction pumps necessary to support deployment. update to AQ WF3-009 response when information is available.

3.1.3.2.A Wind Deployment - Whether procedures and programs will This item include taking proactive actions such as testing, connecting, addressed by and readying exposed portable equipment to reduce the updated AQ WF3-potential for wind impacts. 012 response.

3.2.1.1.A CENTS - Verify the use of CENTS in the ELAP analysis for This item is Waterford is limited to the flow conditions before reflux addressed by boiling initiates. This includes providing a justification for how updated AQ WF3-the initiation of reflux boiling is defined. 020 response.

Attachment to W3F1-2014-0050 Page 11 of 15 Interim Staff Evaluation Confirmatory Items Status 3.2.1.4.A Initial Values for Key Plant Parameters and Assumptions- This item is related Review analysis of UHS [Ultimate Heat Sink] (licensee open to OI5, which is in item OI5) progress.

3.2.3.A Containment Functions Strategies - Review the results of the This item is finalized containment analysis associated with open item OI2 addressed by of the Integrated Plan, which shows that containment update to AQ WF3-functions will be (potentially) restored and maintained in 030 response.

response to an ELAP event.

3.2.4.4.B Communications - Confirm that upgrades to the site's NRC Confirmatory communications systems have been completed. Action 3.2.4.5.A Protected and Internal Locked Area Access- Verify access This item is plans are incorporated into FLEX strategies. addressed by updated AQ WF3-035 response.

3.2.4.6.A Personnel Habitability - Review the licensee's assessment of This item is the habitability/accessibility requirements in all critical areas. addressed by update to AQ WF3-033.

3.2.4.7.A Water Sources -Verify the evaluation of the suction path from This item is related the TDEFWP to the WCTs [Wet Cooling Towers] through a to OI1, which has non-running ACCWS [Auxiliary Component Cooling Water been closed.

System] pump post-ELAP confirms it is viable.

3.2.4.7.B Water Sources - Description of how the licensee would get In Progress (See water from the Mississippi River to the FLEX pumps. related information in Section 4) - This item will be addressed by update to AQ WF3-036 response when information is available.

3.2.4.8.B Electrical Power Sources/Isolation and Interactions - This item is Licensee to provide the level of detail of the FLEX addressed by instrumentation to ensure that electrical equipment remains updated AQ WF3-protected (from an electrical standpoint- e.g., power 038 response.

fluctuations). Also, confirm electrical isolation to ensure that the portable/FLEX diesel generators are isolated from Class 1 E diesel generators to prevent simultaneously supplying power to same Class 1 E bus.

3.2.4.9.A Portable Equipment Fuel - Diesel fuel oil supply for the diesel This item is driven pump and how continued operation to ensure core addressed by cooling is maintained. Diesel fuel oil supply (e.g., fuel oil updated AQ WF3-storage tank volume, supply pathway, etc.) for the FLEX 039 response.

Attachment to W3F1-2014-0050 Page 12 of 15 Interim Staff Evaluation Confirmatory Items Status generators and how continued operation to ensure core and SFP cooling is maintained indefinitely (i.e., Phase 2 and 3).

3.2.4.9.B Portable Equipment Fuel - Discuss how fuel quality will be This item is maintained. addressed by updated AQ WF3-039 response.

Audit Question Completion or Status Open Items Target Date WF3-001 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.1.1.1.A)

WF3-002 In progress - This AQ response will be updated when February 2015 information is available WF3-003 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.1.1.2.A)

WF3-004 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.1.1.2.B)

WF3-005 In progress - This AQ response will be updated when February 2015 information is available (ISE Confirmatory Item 3.1.1.3.A)

WF3-006 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.1.1.4.A)

WF3-007 In progress - This AQ response will be updated when February 2015 information is available (ISE Confirmatory Item 3.1.2.2.A)

WF3-008 Updated response available on the ePortal See ePortal WF3-009 In progress - This AQ response will be updated when February 2015 information is available (ISE Confirmatory Item 3.1.2.3.A)

WF3-010 Closed* N/A WF3-011 Updated response available on the ePortal See ePortal WF3-012 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.1.3.2.A)

WF3-013 Updated response available on the ePortal See ePortal WF3-014 Updated response available on the ePortal See ePortal WF3-015 Closed* N/A WF3-017 Updated response available on the ePortal (ISE Open See ePortal Items 3.2.1.1.B, 3.2.1.2.B & 3.2.1.8.A)

WF3-018 Updated response available on the ePortal (ISE Open See ePortal

Attachment to W3F1-2014-0050 Page 13 of 15 Audit Question Completion or Status Open Items Target Date Item 3.2.1.2.A & 3.2.1.2.B)

WF3-019 Updated response available on the ePortal (ISE Open See ePortal Item 3.2.1.2.B)

WF3-020 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.1.1.A)

WF3-021 Updated response available on the ePortal (ISE Open See ePortal Item 3.2.1.3.A)

WF3-022 Updated response available on the ePortal See ePortal WF3-023 In progress - This AQ response will be updated when February 2015 information is available WF3-024 In progress - This AQ response will be updated when February 2015 information is available WF3-025 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.4.7.A)

WF3-026 Updated response available on the ePortal See ePortal WF3-027 Updated response available on the ePortal See ePortal WF3-028 In progress - Changes to the FLEX strategy necessitate February 2015 an updated response to this AQ when information is available.

WF3-029 Updated response available on the ePortal See ePortal WF3-030 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.3.A)

WF3-031 Closed* N/A WF3-032 Updated response available on the ePortal (ISE Open See ePortal Items 3.2.4.2.A, 3.2.4.2.B, 3.2.4.2.C, 3.2.4.2.D)

WF3-033 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.4.6.A)

WF3-034 Updated response available on the ePortal (ISE Open See ePortal Item 3.2.4.4.A)

WF3-035 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.4.5.A)

WF3-036 In progress - This AQ response will be updated when February 2015 information is available (ISE Confirmatory Item 3.2.4.7.B)

WF3-038 Updated response available on the ePortal (ISE See ePortal Confirmatory Item 3.2.4.8.B)

WF3-039 Updated response available on the ePortal (ISE See ePortal

Attachment to W3F1-2014-0050 Page 14 of 15 Audit Question Completion or Status Open Items Target Date Confirmatory Items 3.2.4.9.A and 3.2.4.9.B)

WF3-040 In progress - This AQ response will be updated when February 2015 information is available WF3-041 In progress - Partial updated response available on the February 2015 ePortal (ISE Open Item 3.2.4.10.A (c.)). The remainder of this AQ response will be updated when information is available (ISE Open Items 3.2.4.8.A & 3.2.4.10.A)

• Closed indicates that Entergys response is complete.

7 Potential Interim Staff Evaluation Impacts In addition to the changes to compliance methods identified in Section 4 and the items identified in Section 6, the items discussed below have potential impact on the Interim Staff Evaluation.

During design finalization, Waterford has identified an error in a supporting calculation to the Maintain Core Cooling & Heat Removal strategy as described in the Waterford Overall Integrated Plan (Reference 1). The Waterford Overall Integrated Plan (Reference 1) discusses the scenario on pages 7, 13, 28 and 76. The Interim Staff Evaluation and Audit Report for Waterford (Reference 4) references the affected strategy in Section 3.2.1 on pages 27, 30 through 36, 40 and 41 of 65. The initial plant cooldown target temperature set to preclude nitrogen injection from the SITs included a non-conservative input for initial SIT volume. To preclude nitrogen injection early in the event response (prior to when the SITs can be isolated), the cooldown strategy is being revised. The overall strategy will be a two stage cooldown, where the first stage will be an early cooldown to a cold leg temperature of approximately 456°F. The second stage of the cooldown will occur after restoring power to the charging pumps and SIT isolation valves to preclude nitrogen intrusion into the RCS. The updated cooldown strategy will be reflected in a future OIP update.

As stated in the Second Six Month Update (Reference 5), an updated sequence of events timing is required for the SFP cooling strategy for Modes 1 through 4. The calculation to determine the updated timing is in progress and the results will be reported in a future OIP update.

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

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

Attachment to W3F1-2014-0050 Page 15 of 15

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

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

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

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12- 049 (Mitigation Strategies) (TAC No. MF0977), dated November 22, 2013 (ADAMS Accession No. ML13220A402)

5. Waterford Steam Electric Station, Unit 3 letter to NRC, Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated February 28, 2014 (ADAMS Accession No. ML14059A085)