W3F1-2015-0003, Fourth 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

Fourth 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

ML15057A548
Person / Time
Site:	Waterford
Issue date:	02/26/2015
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, W3F1-2015-0003
Download: ML15057A548 (17)

Text

Ente ergy Operations, Inc.

17265 5 River Road Killon na, LA 70057-3093 Tel 5004-739-6660 Fax 5504-739-6678 mchissum@entergy.com Mich hael R. Chisum Site V Vice President Wate erford 3 W3F1-20 015-0003 February 26, 2015 U.S. Nucclear Regulattory Commis ssion ATTN: Document Co ontrol Desk 11555 Ro ockville Pike e

Rockville e, MD 20852 SUBJECT T: Fourthh Six Month Status Repo ort for Implem mentation off Order EA-1 12-049, Comm mission Orde er Modifying License Witth Regard To o Requireme ents for ation Strategies for Beyond-Design-B Mitiga Basis Extern nal Events W Waterford Ste eam Electrric Station, Unit U 3 (Waterrford 3)

Docke et No. 50-382 Licens se No. NPF--38

References:

1. NRC Orderr Number EA A-12-049, O Order to Modify Licenses With Regarrd To Requirements for Mitigation Stra ategies for BBeyond-Desig gn-Basis External Evvents, datedd March 12, 2 2012 (ADAMS Ac ccession No. ML12054A A736)

2. NRC Interimm Staff Guida ance JLD-IS SG-2012-01,, Compliancce with Orde er EA-12-049,, Order Modiifying Licensses with Reg gard to Requ uirements forr Mitigation Strategies S forr Beyond-De esign-Basis External Eve ents, Revision 0, dated Augu ust 29, 2012 (ADAMS Acccession No.

ML12229A174)

3. Nuclear Energy Institute e (NEI) 12-0 06, Diverse a and Flexible e Coping Strategies (FLEX)

( Impleementation G Guide, Revision 0, date ed August 2012 (ADAM MS Accessio on No. ML12 2221A205)

4. Entergy lettter to NRC, Initial Statuss Report in R Response to o March 12, 2012, 2 Comm mission Orde er Modifying Licenses with Regard to o Requirements for Mitiga ation Strateg gies for Beyo ond-Design-Basis External Evvents (Order Number EA A-12-049), d dated Octobe er 26, 2012 (W3F1-2012-0093) (AD DAMS Accesssion No. ML L12300A447 7)

5. Waterford Steam S Electrric Station, U Unit 3 letter tto NRC, Ove erall Integrated Plan P in Respponse to Marrch 12, 2012 2, Commission Order to Modify Liceenses With Regard R to Reequirements for Mitigatio on Strategiess for Beyond--Design-Bas sis External E Events, date ed Februaryy 28, 2013 (ADAMS Ac ccession No. ML13063A A266)

W3F1-20 015-0003 Page 2 of o 3 6 Waterford Steam S Electrric Station, U Unit 3 letter tto NRC, Firsst Six Monthh Status Report for Implementation o f Order EA-1 12-049, Com mmission Order Modifying Licens se With Rega ard To Requ uirements forr Mitigation Strategies for f Beyond-D Design-Basiss External E Events dated d August 28,,

2013 (ADAM MS Accessio on No. ML13 3241A281) 7 Waterford Steam S Electrric Station, U Unit 3 letter tto NRC, Se econd Six Month Statu us Report fo or Implementtation of Ord der EA-12-04 49, Commission Order Mod difying Licen nse With Reg gard To Req quirements for Mitigatio on Strategies s for Beyond d-Design-Ba asis Externall Events dated Febru uary 28, 201 14 (ADAMS Accession N No. ML14059A085) 8 Waterford Steam S Electrric Station, U Unit 3 letter tto NRC, Th hird Six Month Statu us Report fo or Implementtation of Ord der EA-12-04 49, Commission Order Mod difying Licen nse With Reg gard To Req quirements for Mitigatio on Strategies s for Beyond d-Design-Ba asis Externall Events dated Augu ust 28, 2014 (ADAMS Acccession No o. ML14241A A270)

Dear Sir or Madam:

On March 12, 2012, the t NRC issued Order Number N EA-1 12-049 (Refe erence 1) to Entergy Operations, Inc. (Enttergy). The ordero was im mmediately e effective andd required Waterford Steam Electric Statio on, Unit 3 (WWaterford 3) to t develop m mitigating stra ategy provissions for beyond-d design-basis s external events.

Referenc ce 1 required d submission n of an initiall status repoort 60 days fo ollowing issu uance of the final interrim staff guid dance (Reference 2) and d an Overall Integrated P Plan (OIP). Reference 2 endorses s industry gu uidance docu ument NEI 12-02, Revisiion 1 (Refere ence 3). Re eference 4 provided the initial status report regarding r miitigating stra tegies and R Reference 5 provided the e OIP.

NRC Ord der EA-12-04 49 requires submission s of o a status re eport at six-mmonth intervvals following g

submittal of the Overrall Integrate ed Plan with regard to the e requirements for mitiga ation strateg gies for beyon nd-design-ba asis external events for Waterford W 3.. Referencess 6, 7 and 8 provided the e first, secoond and third d six-month status s reportts for Waterfford 3 respecctively. The purpose of tthis letter is to o provide, ass an attachm ment, the fou urth six montth status report for the im mplementatio on of Order EA-12-049.

There are e no new commitments identified in this submitta al. Should yyou have anyy questions concerning the conte ent of this lettter, please contact c Johnn Jarrell, Reggulatory Assurance Managerr, at (504) 73 39-6685.

I declare under pena alty of perjuryy that the forregoing is truue and corre ect. Execute ed on Februa ary 26, 2015..

MRC/AJH H

W3F1-2015-0003 Page 3 of 3

Attachment:

Waterford Steam Electric Station, Unit 3, Fourth 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. 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 W3F1-2015-0003 Waterford Steam Electric Station, Unit 3, Fourth 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 W3F1-2015-0003 Page 1 of 13 Waterford Steam Electric Station, Unit 3, Fourth 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

( O I P ) (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 6), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since July 31, 2014, and are current as of January 31, 2015.

Third Six-Month Status Report August 2014 Fourth Six-Month Status Report Complete with submission of this document in February 2015 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: N/A 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 Complete N/A Update 5 Aug 2015 Not Started No Change Perform Staffing Analysis Nov 2015 Not Started June 2015

Attachment to W3F1-2015-0003 Page 2 of 13 Revised Target Target Milestone Completion Activity Status Completion Date **

Date Modifications:

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

Procedures Create Waterford FSGs Nov 2015 Started No Change Create Maintenance Procedures Nov 2015 Not Started No Change Training Develop Training Plan May 2015 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, a change was identified to the compliance strategy as described in the Overall Integrated Plan (Reference 1) and 3rd Six Month Update Report (Reference 6). The change is described below and will be incorporated into a future update.

NEI 12-06 Rev 0 stipulates that provisions for an additional set of portable on-site equipment is essential to provide reasonable assurance that N set of FLEX equipment will remain deployable to assure success of the FLEX strategies. A subset of this portable on-site equipment are hoses and cables required to implement the FLEX

Attachment to W3F1-2015-0003 Page 3 of 13 strategies. The N set of hoses and cables are protected from all extreme external hazards. As an alternate approach, an additional length of hoses and cables will be stored with the N set of equipment rather than storing a complete second set in the N+1 Storage Building. This spare capability supports the safety functional requirements beyond the minimum necessary to support the N-units on-site, and is consistent with the industry-proposed Revision 1 to NEI 12-06 draft.

The additional length of hoses and cables to be stored with the N set of equipment will be the longer of 10% of the total hose/cable run or the longest segment of hose/cable.

The 10% criteria extends separately to each size or type of hoses and cables. The hoses and cables utilized by the WF3 FLEX strategy are not one continuous hose or cable but rather are composed of smaller sections joined together to form a sufficient length.

Hoses and cables are passive devices unlikely to fail provided they are appropriately inspected and maintained. The hoses and cables for WF3 will be stored in robust storage locations within the Nuclear Plant Island Structure (NPIS), accessible following an extreme external hazard, and will be maintained in accordance with industry recommendations through the Entergy Fleet PM Basis templates. The storage of additional spare cables and hoses for WF3 along with the N set provides additional assurance that the FLEX strategy can be implemented for all events even if a segment of the hoses or cables were to be damaged during the strategy implementation.

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

Attachment to W3F1-2015-0003 Page 4 of 13 Overall Integrated Plan Open Item Status OI2. An analysis will be needed to demonstrate that containment Closed - Containment pressure and temperature will stay at acceptable levels spray will not be throughout the ELAP event and that no containment spray required as part of system will be required as part of FLEX. FLEX.

This item addressed by updated AQ WF3-030 response.

OI3. At this stage of the conceptual design, the chemistry Closed - The effects of effects of alternate cooling source (ACS) use on utilizing the FLEX secondary wetted components are unknown. cooling water sources have been evaluated and determined to have minimal impact on FLEX credited equipment. The FLEX strategy utilizes the available cooling sources in order of best quality consistent with NEI FAQ 2013-11.

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 Closed - The WF3 FLEX and dry cooling towers will need to be made operational to strategy extends Phase 2 reject the heat load generated post-ELAP in Phase 3. coping by continuing to However, this must be investigated more fully to confirm feed the SGs with either such. Notably, only 60% of the dry cooling tower fan motors the NSRC equipment or are currently missile protected and none of the wet cooling the onsite FLEX Water tower (WCT) fan motors are missile protected. If more than Transfer Pumps.

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

Attachment to W3F1-2015-0003 Page 5 of 13 Overall Integrated Plan Open Item Status 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 fails The site takes to consider the warning time offered by a hurricane considerable actions storm for pre-staging FLEX equipment. In addition, as depending on the described in NEI 12-06, Section 7.2.2, hurricanes can severity of an incoming have a significant impact on local infrastructure, e.g., storm or flood, up to and downed trees and flooding that should be considered including conducting a in the interface with off- site resources. plant shutdown followed by a cooldown to Mode

5. At least one set of FLEX 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 CENTS use of CENTS by providing the CENTS-calculated value cases have been re-of the centered one-hour moving average of the flow evaluated to conform to quality at the top of the SG tubes, which corresponds to the limitations of the use the maximum void fraction of 0.2 in SG tubes as of CENTS. The conditions used to define termination of single phase transition to reflux natural circulation, and confirming that the value is less cooling considered is than the limit specified in the white paper dated based on the flow September 24, 2013 for use in defining the onset of quality at the top of the reflux being. 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

Attachment to W3F1-2015-0003 Page 6 of 13 Interim Staff Evaluation Open Items Status strategy based actions are taken prior to this transition to provide makeup).

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

See also response to AQ WF3-019.

3.2.1.2.A RCP Seal Leakage - Justification of less than 15 gpm As reported in Second 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, consistent with WCAP-17601-P. This item addressed by AQ WF3-018 response.

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 AQ WF3-018 response.

subcooling, (3) leakage flow path characteristics after 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 AQ WF3-021 response.

Nuclear Society] 5.1-1979 + 2 sigma, or equivalent.

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.

Attachment to W3F1-2015-0003 Page 7 of 13 Interim Staff Evaluation Open Items Status 3.2.1.8.A Core Sub-Criticality- Regarding boron mixing, the NRC The NRC has accepted staff has not yet accepted the PWROG [Pressurized the PWROG position Water Reactor Owners Group] position paper on boron paper on boron mixing mixing. Therefore, additional technical justification will per ML13276A183.

be needed to resolve this issue, both generically and on Waterford conforms to a plant-specific basis. the industry boron mixing position. This item addressed by AQ WF3-017 response.

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 addressed by habitability/accessibility requirements to ensure updated AQ WF3-034 lighting is appropriately addressed. response.

3.2.4.8.A Electrical Power Sources/Isolation and Interactions- This item addressed by Provide a summary of the sizing calculations used to updated AQ WF3-041 determine the adequacy of the FLEX generators used response.

to power plant electrical equipment.

3.2.4.10.A Load Reduction to Conserve DC Power - The This item addressed by licensee's Integrated Plan on Page 7 identifies dc load updated AQ WF3-041 shed at hour 1 and 4. With regard to the load shedding response.

of the dc bus in order to conserve battery capacity:

a. Provide the dc load profile for the mitigation strategies to maintain core cooling, containment, and SFP cooling during all modes of operation. In your response, describe any load shedding that is assumed to occur and the actions necessary to 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

Attachment to W3F1-2015-0003 Page 8 of 13 Interim Staff Evaluation Open Items Status 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 AQ seismically robust equipment or structures for portable WF3-001 response.

equipment that will be stored outside; 2) how large FLEX 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 to assure proper protection from a seismic event.

3.1.1.2.A Seismic Deployment - Protection of the connection points for This item addressed Reactor Coolant System (RCS) inventory control during the by updated AQ WF3-final phase is yet to be determined (TBD). 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 AQ the ability to move equipment in the flooding context WF3-004 response.

discussed in Section 3.1.2.2 and wind protection for the 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 is partially 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.

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

Attachment to W3F1-2015-0003 Page 9 of 13 Interim Staff Evaluation Confirmatory Items Status 3.1.2.2.A Flooding Deployment- Implementation of flooding In Progress - This item persistence into their FLEX strategies for pre-event staging is partially addressed of FLEX equipment. by updated AQ WF3-007 response.

3.1.2.3.A Flooding Procedural Interface- Deployment of portable This item addressed equipment in flooded conditions not incorporated into flood by updated AQ WF3-procedures or the need to deploy temporary flood barriers 009 response.

and extraction pumps necessary to support deployment.

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

potential for wind impacts.

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 WF3-020 the initiation of reflux boiling is defined. response.

3.2.1.4.A Initial Values for Key Plant Parameters and Assumptions- NRC Confirmatory Review analysis of UHS [Ultimate Heat Sink] (licensee open Action item OI5) This item is related to OI5, which has been closed.

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 updated AQ WF3-030 functions will be (potentially) restored and maintained in 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 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 AQ WF3-033 response.

3.2.4.7.A Water Sources -Verify the evaluation of the suction path from NRC Confirmatory the TDEFWP to the WCTs [Wet Cooling Towers] through a Action non-running ACCWS [Auxiliary Component Cooling Water This item is related to System] pump post-ELAP confirms it is viable. OI1, which has been closed.

Attachment to W3F1-2015-0003 Page 10 of 13 Interim Staff Evaluation Confirmatory Items Status 3.2.4.7.B Water Sources - Description of how the licensee would get This item is addressed water from the Mississippi River to the FLEX pumps. by updated AQ WF3-036 response.

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 AQ instrumentation to ensure that electrical equipment remains WF3-038 response.

protected (from an electrical standpoint- e.g., power 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 AQ cooling is maintained. Diesel fuel oil supply (e.g., fuel oil WF3-039 response.

storage tank volume, supply pathway, etc.) for the FLEX 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 AQ WF3-039 response.

Audit Question Completion or Status Open Items Target Date WF3-001 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.1.1.1.A)

WF3-002 In progress - Updated response available on the ePortal See ePortal August 2015 WF3-003 Updated response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.1.1.2.A)

WF3-004 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.1.1.2.B)

WF3-005 In Progress - Updated response available on the ePortal See ePortal (associated with ISE Confirmatory Item 3.1.1.3.A) August 2015 WF3-006 In Progress - Updated response available on the ePortal See ePortal (associated with ISE Confirmatory Item 3.1.1.4.A)

WF3-007 In progress - Updated response available on the ePortal See ePortal (associated with ISE Confirmatory Item 3.1.2.2.A) August 2015 WF3-008 Closed* Response available on the ePortal See ePortal

Attachment to W3F1-2015-0003 Page 11 of 13 Audit Question Completion or Status Open Items Target Date WF3-009 Updated response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.1.2.3.A)

WF3-010 Closed* Response available on the ePortal See ePortal WF3-011 Closed* Response available on the ePortal See ePortal WF3-012 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.1.3.2.A)

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

WF3-018 Updated response available on the ePortal (associated See ePortal with ISE Open Item 3.2.1.2.A & 3.2.1.2.B)

WF3-019 Closed* Response available on the ePortal (associated See ePortal with ISE Open Item 3.2.1.1.B)

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

WF3-021 Closed* Response available on the ePortal (associated See ePortal with ISE Open Item 3.2.1.3.A)

WF3-022 Closed* Response available on the ePortal See ePortal WF3-023 Updated response available on the ePortal See ePortal WF3-024 Updated response available on the ePortal See ePortal WF3-025 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.2.4.7.A)

WF3-026 Updated response available on the ePortal See ePortal WF3-027 Closed* Response available on the ePortal See ePortal WF3-028 In Progress - Updated response available on the ePortal. See ePortal August 2015 WF3-029 Updated response available on the ePortal See ePortal WF3-030 Updated response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.2.3.A)

WF3-031 Updated response available on the ePortal See ePortal

Attachment to W3F1-2015-0003 Page 12 of 13 Audit Question Completion or Status Open Items Target Date WF3-032 Updated response available on the ePortal (associated See ePortal with ISE Open Items 3.2.4.2.A, 3.2.4.2.B, 3.2.4.2.C, 3.2.4.2.D)

WF3-033 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.2.4.6.A)

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

WF3-035 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.2.4.5.A)

WF3-036 In progress - Updated response available on the ePortal See ePortal August (associated with ISE Confirmatory Item 3.2.4.7.B) 2015 WF3-038 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Item 3.2.4.8.B)

WF3-039 Closed* Response available on the ePortal (associated See ePortal with ISE Confirmatory Items 3.2.4.9.A and 3.2.4.9.B)

WF3-040 Updated response available on the ePortal See ePortal WF3-041 Updated response available on the ePortal (associated See ePortal with 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 item discussed below has a potential impact on the Interim Staff Evaluation.

WF3 has determined that the available, robust water sources for ELAP response are adequate to extend coping to greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, after which NSRC equipment would be available and in place to replenish the necessary water inventories. In order to provide margin to the final strategy, additional water transfer capability is staged onsite.

Water sources, and water transfer from the Mississippi River to the plant, are discussed by the ISE in Section 3.2.4.7.

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 W3F1-2015-0003 Page 13 of 13

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)

6. Waterford Steam Electric Station, Unit 3 letter to NRC, 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 dated August 28, 2014 (ADAMS Accession No. ML14241A270)