W3F1-2013-0050, 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

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

ML13241A281
Person / Time
Site:	Waterford
Issue date:	08/28/2013
From:	Jacobs D Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, W3F1-2013-0050
Download: ML13241A281 (7)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 djacob2@entergy.com Donna Jacobs Vice President - Operations Waterford 3 W3F1-2013-0050 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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 Waterford Steam Electric Station, Unit 3 (Waterford 3)

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

References:

1. 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)

2. 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)

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc.

(Entergy). Reference 1 was immediately effective and required Waterford Steam Electric Station, Unit 3 (Waterford 3), to develop mitigating strategy provisions for beyond-design-basis external events. In response, Waterford 3 developed and submitted an Overall Integrated Plan (Reference 2) which specified periodic updates during the implementation of the plan.

The purpose of this letter is to provide, as an attachment, the first six month status report for the implementation of Order EA-12-049 with regard to the requirements for mitigation strategies for beyond-design-basis external events for Waterford 3.

W3F1-2013-0050 Page 2 of 2 There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact Bryan Pellegrin, Licensing Manager (acting), at (504) 739-6203.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 28, 2013.

Sincerely, DJ/WH

Attachment:

Waterford Steam Electric Station, Unit 3, First 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 cc: Attn: Director, Office of Nuclear Reactor Regulation U. S. NRC RidsNrrMailCenter@nrc.gov Mr. Steven Reynolds, Regional Administrator (acting)

U. S. NRC, Region IV RidsRgn4MailCenter@nrc.gov NRC Project Manager for Waterford 3 Kaly.Kalyanam@nrc.gov NRC Senior Resident Inspector for Waterford 3 Marlone.Davis@nrc.gov

Attachment W3F1-2013-0050 Waterford Steam Electric Station, Unit 3, First 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 W3F1-2013-0050 Page 1 of 4 Waterford Steam Electric Station, Unit 3, First 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 Reference 2. This attachment provides a planned 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 the development of the Overall Integrated Plan (Reference 1), and are current as of July 30, 2013.

None.

3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan (Reference 1). 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 Activity Target Milestone Completion Status Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Not Started No Change Update 3 Aug 2014 Not Started No Change 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 W3F1-2013-0050 Page 2 of 4 Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications:

Engineering and Implementation N-1 Walkdowns May 2014 Not Started No Change Design Engineering Oct 2014 Not Started No Change Implementation Outage Nov 2015 Not Started No Change On-site FLEX Equipment Purchase Dec 2014 Not Started No Change Procure Sept 2015 Not Started No Change Off-site FLEX Equipment Develop Strategies with RRC Dec 2013 Not Started No Change Install Off-Site Delivery Station (if Nov 2015 Not Started No Change 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 Nov 2015 Not Started Feb 2016*

• This date corresponds to the last 6 month update and provides time to compile the report following the completion of the Fall 2015 Implementation Outage.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

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.

Attachment to W3F1-2013-0050 Page 3 of 4 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Overall Integrated Plan Open Item Status OI1. The suction path from the TDEFWP to the WCTs would be Not Started through a non-running ACCWS pump post-ELAP. It is expected that both the TDEFWP and the currently sized EFW FLEX pump (primary strategy) will have sufficient capability and/or NPSH to do so. However, this will need to be confirmed more fully as the detailed design of the primary strategy for maintaining core cooling and heat removal evolves (with SGs available).

OI2. An analysis will be needed to demonstrate that containment Not Started pressure and temperature will stay at acceptable levels throughout the ELAP event and that no containment spray system will be required as part of FLEX.

OI3. At this stage of the conceptual design, the chemistry effects of Not Started alternate cooling source (ACS) use on secondary wetted components are unknown.

OI4. It is currently unclear if and how long gravity feed from the Not Started RWSP can be maintained during Modes 5 and 6 in Phase 1. If this time is sufficiently short, Waterford 3 may choose to pre-stage requisite FLEX equipment in Modes 5 and 6.

OI5. It is expected that only the component cooling water system and Not Started dry cooling towers will need to be made operational to reject the heat load generated post-ELAP in Phase 3. However, this must be investigated more fully to confirm 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 (Reference 50, Pg 18). 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.

Attachment to W3F1-2013-0050 Page 4 of 4 7 Potential Draft Safety Evaluation Impacts The NRC has not yet issued draft safety evaluations for Waterford 3; therefore, there are no potential impacts to the Draft Safety Evaluation identified at this time.

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)

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).