View source for W3F1-2016-0003, Revised Licensing Actions and Implementation Items Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request (LAR)

{{Adams
| number = ML16018A013
| issue date = 01/18/2016
| title = Revised Licensing Actions and Implementation Items Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request (LAR)
| author name = Chisum M
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person = 
| case reference number = TAC ME7602, W3F1-2016-0003
| document type = Letter type:W
| page count = 23
| project = TAC:ME7602
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6698 mchisum@entergy.com Michael R. Chisum Vice President - Operations Waterford 3 W3F1-2016-0003 January 18, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Revised Licensing Actions and Implementation Items Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request (LAR)
Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38

==REFERENCES:==
: 1. Entergy letter W3F1-2011-0074, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition), Waterford Steam Electric Station, Unit 3 dated November 17, 2011
[ML113220230]
: 2. Entergy letter W3F1-2012-0005, Supplemental Information in Support of the NRC Acceptance Review of Waterford 3 License Amendment Request to Adopt NFPA 805, Waterford Steam Electric Station, Unit 3 dated January 26, 2012 [ML12027A049]
: 3. Entergy letter W3F1-2013-0048, Supplement to NFPA 805 License Amendment Request (LAR) Waterford Steam Electric Station, Unit 3 dated December 18, 2013 [ML13365A325]
: 4. NRC letter to Entergy dated July 13, 2015, Request for Additional Information RE: License Amendment Request to Transition to National Fire Protection Association Standard 805 (TAC NO.
ME7602) [ML15182A346]
: 5. NRC letter to Entergy dated July 21, 2015, Request for Additional Information RE: License Amendment Request to Transition to National Fire Protection Association Standard 805 (TAC NO.
ME7602) [ML15197A229]
: 6. Entergy letter W3F1-2015-0057, Responses to Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request (LAR)
Waterford Steam Electric Station, Unit 3 dated August 31, 2015.
: 7. Entergy letter W3F1-2015-0078, Revised Implementation Item Regarding Adoption of National Fire Protection Association Standard NFPA 805 License Amendment Request (LAR) Waterford Steam Electric Station, Unit 3 dated September 24, 2015

W3F1-2016-0003 Page 2

==Dear Sir or Madam:==

By letter dated November 17, 2011, as supplemented by letters dated January 26, 2012, and December 18, 2013 (References 1 through 3 respectively), Entergy Operations, Inc.
(Entergy), submitted a license amendment request (LAR) to transition its fire protection license basis at the Waterford Steam Electric Station, Unit 3, from paragraph 50.48(b) of Title 10 of the Code of Federal Regulations (10 CFR) to 10 CFR 50.48(c), "National Fire Protection Association Standard 805" (NFPA 805).
The LAR Supplement provided in Reference 3 represents changes to specified LAR Attachments and supporting calculations primarily as a result of performing extensive reanalysis utilizing only NRC-accepted methods. Two Requests for Additional Information letters were received on July 13, 2015 (Fire Modeling RAIs) and July 21, 2015 (Probabilistic Risk Analysis RAIs) via References 4 and 5. The responses to these RAIs were provided in Reference 6.
During a clarification call between the NRC and Entergy on September 21, 2015, the NRC requested that implementation item S2-22 be revised to include relevant information contained in Reference 6. The revised implementation item S2-22 was provided in Reference 7.
On January 7, 2016, the NRC project manager requested that Entergy provide updated versions of Attachment M (Licensing Condition Changes) and Attachment S (Plant Modifications and Items to be Completed During Implementation). These updated LAR attachments are provided in Enclosures 1 and 2. Enclosure 3 contains the Operating License markup of section 2.C.9, Fire Protection. Section 6.8.1 of Technical Specifications is unchanged from the markup provided in Enclosure 2 of Reference 1.
There are no new regulatory commitments contained in this submittal. If you require additional information, please contact the Regulatory Assurance Manager, John Jarrell at 504-739-6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January 18, 2016.
Sincerely, MRC/AJH

==Enclosures:==
: 1. Updated Attachment M - Licensing Condition Changes
: 2. Updated Attachment S - Plant Modifications and Items to be Completed During Implementation
: 3. Operating License Section 2.C.9 (markup)

W3F1-2016-0003 Page 3 cc:    Marc L. Dapas                           RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector           Frances.Ramirez@nrc.gov Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission     April.Pulvirenti@nrc.gov Attn: Dr. April Pulvirenti Washington, DC 20555-0001 Louisiana Department of Environmental   Ji.Wiley@LA.gov Quality Office of Environmental Compliance Surveillance Division P.O. Box 4312 Baton Rouge, LA 70821-4312

ENCLOSURE 1 W3F1-2016-0003 Updated Attachment M - Licensing Condition Changes

Entergy                                                 Attachment M - License Condition Changes Replace the current Waterford 3 fire protection license condition Section 9.5.1 with the standard license condition in Regulatory Position 3.1 of RG 1.205, modified as shown below. In support of this change, Waterford 3 has developed a Fire PRA during the Waterford 3 transition to NFPA 805.
A markup of the proposed changes in the Operating License is provided in Enclosure 3 of this letter.
Waterford 3 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated ___________ (and supplements dated________ ) and as approved in the safety evaluation report dated (and supplements dated________ ). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met.
The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant.
Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
M-1

Entergy                                                Attachment M - License Condition Changes Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
Fire Alarm and Detection Systems (Section 3.8);
Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
Gaseous Fire Suppression Systems (Section 3.10); and, Passive Fire Protection Features (Section 3.11).
This condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated
________ to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
(2) The licensee shall implement the modifications to its facility as described in Attachment S, Table S-1 Plant Modifications in Entergy Operations, Inc. letter W3F1-2016-0003, dated January 18, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by M-2

Entergy                                                  Attachment M - License Condition Changes completion of the first refueling outage greater than 12 months following issuance of the license amendment.
The licensee shall maintain appropriate compensatory measures in place until completion of the modification listed as S1-5, (Installation of qualified 1-hour ERFBS fire wrap barrier in Fire Area RAB 6). All other modifications listed in Table S-1 are either installed or have no associated compensatory measure.
(3) The licensee shall implement the items listed in Attachment S, Table S-2 Implementation items in Entergy Operations, Inc. letter W3F1-2016-0003, dated January 18, 2016, within 6 months following issuance of the license amendment.
M-3

ENCLOSURE 2 W3F1-2016-0003 Updated Attachment S - Plant Modifications and Items to be Completed During Implementation

Entergy                           Attachment S - Plant Modifications and Items to be Completed Table S-1 identifies plant modifications to be completed and includes a description of the modifications along with the following information:
A problem statement Risk ranking of the modification An indication if the modification is currently included in the Fire PRA Compensatory Measure in place, and A risk-informed characterization of the modification and compensatory measure The following Legend should be used when reviewing the table:
High = Modification would have an appreciable impact on reducing overall fire CDF.
Med = Modification would have a measurable impact on reducing overall fire CDF.
Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.
S-1

Entergy                                    Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank               Problem Statement                            Proposed Modification              PRA      Measure    Risk Informed Characterization S1-1        Deleted (Engineering Report WF3-FP             00001 Rev 2)
S1-2        Deleted (LAR Supplement W3F1-2013-0048)
S1-3        Deleted (LAR Supplement W3F1-2013-0048)
S1-4        Deleted (LAR Supplement W3F1-2013-0048)
S1-5    Low In Fire Area RAB 6, PRA credits a qualified 1- Waterford 3 will install an ERFBS (3M barrier  Yes       Yes            This modification is not hour fire resistance rating ERFBS fire wrap    material) in Fire Area RAB 6 EC 10818 is                                a result of fire risk barrier from fire damage.                      currently in progress. This ERFBS                                       evaluations, but is modification will provide a qualified 1- hour                           assumed in the fire LAR Source:                                    fire resistance rating.                                                 PRA model for Fire Attachment A & C (NEI-04-02 Table B-1                                                                                  Area RAB 6.
VFDR 3.11.5 In accordance with station directives, compensatory measures per FP-001-015 have been established as STATUS: ERFBS installed in RAB 6 via Work                                                                              appropriate.
Orders 155876, 155870 & 155866.
S1-6        Deleted (LAR Supplement W3F1-2013-0048)
S1-7        Deleted (RAI PRA 43f).
Waterford 3                                                                                                                            S-2

Entergy                                      Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank               Problem Statement                           Proposed Modification          PRA      Measure       Risk Informed Characterization S1-8    Med NFPA 72E section 3-4.3 code non-             Waterford 3 will install a modification to   Yes       No       This modification is not a result of compliance identified heat detectors in fire remove existing fire detection heat                             fire risk evaluations, but is assumed areas listed below have incorrect (lower     detectors and add new (UL listed) heat                          in the fire PRA model for the temperature) factory set point trip range    detectors with factory set point trip                           appropriate Fire Area detection settings for the normal and accident design  settings as described below:                                    systems.
temperatures for the applicable fire areas.
The following six fire areas and systems are DG-A & B Fire Areas RAB 15 & RAB 16 identified below:                            heat detectors (120 degrees F trip set                          This modification will be completed point) will be replaced with new heat                           to meet NFPA 805 Code
: 1) Diesel Generator A RM (Fire Area RAB      detectors with intermediate temperature                         requirements.
16; Room No. 221)                            class (175 to 249 degree F) in the two
: 2) Diesel Generator B RM (Fire Area RAB      DG rooms.
15; Room No. 222)
: 3) Turbine Lube Oil Tank (TGB Elevation      Two TGB fire areas heat detectors (135
            +15).                                        degree F trip set point) will be replaced with heat detectors with intermediate
: 4) Hydrogen Seal Oil Unit (TGB Elevation     temperature class (175 to 249 degree F)
            +40)                                         in the four TGB fire areas; Turbine Lube
: 5) S/G Feed Water Pump A (TGB Elevation      Oil Tank, Hydrogen Seal Oil Unit, S/G
            +15).                                        Feed Water Pump A, S/G Feed Water
: 6) S/G Feed Water Pump B (TGB Elevation      Pump B systems.
            +15).
LAR Source:
Attachment A (NEI-04-02 Table B-1)
VFDR 3.8.2-1 STATUS: Implemented via Engineering Change EC 36048.
: 1) Diesel Generator A RM (WO 386162 -
installed and functionally tested)
: 2) Diesel Generator B RM (WO 386162 -
installed and functionally tested)
: 3) Turbine Lube Oil Tank (WO 386140 -
installed and ready for testing)
: 4) Hydrogen Seal Oil Tank (WO 386140 -
installed and ready for testing)
: 5) S/G Feed Water Pump A (WO 386140 -
installed and ready for testing)
: 6) S/G Feed Water Pump B (WO 386140 -
installed and ready for testing)
Waterford 3                                                                                                                           S-3

Entergy                                       Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank                Problem Statement                           Proposed Modification              PRA      Measure       Risk Informed Characterization S1-9     Low Trouble and ground fault signals from the       Waterford 3 will install a modification to     No        No       The fire alarm following automatic sprinkler systems transmit  upgrade the fire alarm detection system to                        signaling system is not dual signals which do not identify the correct  correct identified deficiencies.                                  credited in the Fire sprinkler systems at the main control room fire                                                                   PRA.
alarm panel.                                    This modification affects the fire detection panel Cerberus/Pyrotronics (UL listed)                            This modification will These areas are listed below:                   transmitters.                                                     be completed to meet NFPA 805 Code
: 1) Unit Auxiliary Transformer 3A & Main                                                                           requirements.
Transformer 3A (Transformer Yard).
: 2) Unit Auxiliary Transformer 3B & Main Transformer 3B (Transformer Yard).
: 3) Turbine Lube Oil Tank (TGB Elevation +15; Sprinkler System FPM-5).
: 4) Hydrogen Seal Oil Unit (TGB Elevation
                +40, Sprinkler System FPM-6).
: 5) S/G Feed Water Pump B (TGB Elevation
                +15; Sprinkler System FPM-8).
: 6) Under Mezzanine Floor (TGB Elevation
                +15, Wet Pipe Sprinkler System FPM-10A).
: 7) Under Mezzanine Floor (TGB Elevation
                +15, Wet Pipe Sprinkler System FPM-10B).
LAR Source:
Attachment A (NEI-04-02 Table B-1)
VFDR 3.8.1-1 STATUS: Implemented via Engineering Change EC 36048.
All installed and ready for testing.
WO 386167 for 1) and 2), and WO 386140; for 3) through 7).
Waterford 3                                                                                                                                S-4

Entergy                                       Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank               Problem Statement                               Proposed Modification              PRA      Measure        Risk Informed Characterization S1-10   Low NFPA 20 section 626.f code non-compliance         Waterford 3 will install a modification for a   No        No       The subject flood was identified for the Fire Pump Diesel           steel battery rack in accordance with site                         protection of diesel fire Engine A & B start batteries.                     requirements that will elevate the                                 pump battery bank is batteries to protect them from potential                           not credited in the Fire The batteries are installed on the floor in each flooding.                                                           PRA.
diesel pump room which is subject to flooding via a water pipe rupture or water leak in one                                                                        This modification will be of the diesel pump rooms.                                                                                            completed to meet NFPA 805 Code LAR Source:                                                                                                          requirements.
Attachment A (NEI-04-02 Table B-1)
VFDR 3.5.3-2 STATUS: Complete EC 36049 implemented via WO 386172 S1-11   Low NFPA 20 section 514.e.2 code non-                 Waterford 3 will install or modify as           No        No       The subject electrical compliance was identified for the electrical fire necessary alarm supervisory relays and                             fire pump motor pump motor. One phase of the three phase          associated circuits for the 480VAC three                           remote supervisory motor starter does not have the remote            phase electrical fire pump motor to                                circuit is not credited in supervisory or monitor function to detect a       provide the remote supervisory or monitor                          the Fire PRA.
cable fault, however locally in the fire pump     function to detect a cable fault.
house at the pump controller all three motor                                                                         This modification will phases are locally supervised.                                                                                       be completed to meet NFPA 805 Code LAR Source:                                                                                                          requirements.
Attachment A (NEI-04-02 Table B-1)
VFDR 3.5.3-2 STATUS: Complete EC 36049 implemented via WO 386172 Waterford 3                                                                                                                                     S-5

Entergy                                      Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank                Problem Statement                            Proposed Modification             PRA      Measure       Risk Informed Characterization S1-12   Low NFPA 50A section 6-61.613 code non-             Waterford 3 will install a modification to     No       No        The subject outdoor bulk compliance was identified in outdoor bulk       upgrade the electrical installation at the                        hydrogen storage area is not hydrogen storage area.                          bulk hydrogen storage area to comply will                         credited in the Fire PRA.
Article 501 of the National Electrical Code Electrical equipment, components, and           for Class I, Division 2.                                          This modification will be installation methods are not in accordance                                                                        completed to meet with Article 501 of the National Electrical                                                                       NFPA 805 Code Code for Class I, Division 2.                                                                                     requirements.
LAR Source:
Attachment A (NEI-04-02 Table B-1)
VFDR 3.3.7.1-1 STATUS: Complete EC 36047 implemented via WO 386032 S1-13   Low NFPA 50A sections 4-42.423 and 8-82 code        Waterford 3 will install a modification to    No         No       The subject outdoors bulk non-compliances were identified in outdoor      identify and replace the vent pipe caps with                      hydrogen storage area is bulk hydrogen storage areas.                    the correct material.                                             not credited by the PRA.
Ten plastic caps are installed on the top of each (hydrogen safety relief device ten total)                                                                    This modification will be vent pipe to prevent water and moisture from                                                                      completed to meet collecting and freezing in the winter that will                                                                   NFPA 805 Code interfere with proper operation of the device.                                                                    requirements.
Code section 4-42.423 requires the vent piping to be designed to prevent moisture from collecting and causing freezing of the safety relief devices; however code section 8-82 requires no combustible material within 15 feet of containers which includes the plastic caps.
LAR Source:
Attachment A (NEI-04-02 Table B-1)
VFDR 3.3.7.1-1 STATUS: Complete EC 36047 implemented via WO 386032-02 Waterford 3                                                                                                                                S-6

Entergy                                       Attachment S - Plant Modifications and Items to be Completed Table S-1 Plant Modifications In Fire Compensatory Item   Rank               Problem Statement                           Proposed Modification            PRA      Measure        Risk Informed Characterization S1-14   High The Waterford PRA analysis consider that the To offset a potential fire risk, the office  Yes        No       This configuration personnel offices and other combustible      contents and occupants will be moved or                          change is credited in the materials presently in Fire Area RAB 27      transferred to alternate locations and the                       fire PRA model. The (RAB+7) needed to be removed to address      area will be returned to an acceptable                           modification provides a the impact of potential fire scenarios.      configuration, absent combustibles.                              decrease from the threat of the effects of a fire STATUS: Complete EC 50625 implemented                                                                         originating from a fire in under WO 383445                                                                                               RAB 27.
SI-15        Deleted (Engineering Report WF3-FP              00001 Rev 2)
Waterford 3                                                                                                                              S-7

Entergy                                           Attachment S - Plant Modifications and Items to be Completed Table S-2, Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program.
Table S-2 Implementation Items Item                                                        Description                                                         LAR Section / Source S2-1    Replace Fire Brigade Personal Alert Safety System devices with units that meet Fire Code NFPA 600 - 2000          Attachment A (NEI-04-02 B-1 Table)
Edition and NFPA 1982.                                                                                            VFDR 3.4.1(a)(1)-1 STATUS: Complete (LRLAR-2011-00182-CA 31)
S2-2    Revise plant documents to include clear guidance that conduits used for electrical raceways shall be metal        Attachment A (NEI-04-02 B-1 Table) and thin walled metallic tubing shall not be used in accordance with the requirements of this section.            VFDR 3.3.5.2 Appropriate station electrical specifications will be updated to specify only metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables.
STATUS: Plant document revisions specified in this table item are assigned and tracked by Waterford 3 LRLAR-2011-182 CA 9.
S2-3    Revise Bulk Hydrogen System vendor/plant documentation and perform periodic inspections and preventive            Attachment A (NEI-04-02 B-1 Table) maintenance in accordance with NFPA 50A.                                                                          VFDR 3.3.7.1-1 STATUS: Complete (CR-WF3-2011-06349 CA 3)
S2-4    Provide appropriate means to alert personnel for NFPA 50A Bulk Hydrogen System for all personnel on               Attachment A (NEI-04-02 B-1 Table) hazards of hydrogen flames.                                                                                       VFDR 3.3.7.1-3 STATUS: Complete (CR-WF3-2011-06349 CA 5)
S2-5    Update Pre-Fire Strategies and necessary plant documents to: 1) Include a description of areas for flooding.      Attachment A (NEI-04-02 B-1 Table)
: 2) Identify areas containing redundant safe shutdown equipment susceptible to water damage from fire              VFDR 3.4.2.1 brigade fire suppression activities. 3) Revise fire brigade training plans to address judicious use of fire hose  RAI FPE 15 streams to limit water damage to redundant safe shutdown equipment.
STATUS: Complete (LRLAR-2011-0182 CA 4 & WLP-FPFB-IFB01 Slide 161)
S2-6    Revise plant test procedures to perform air flow tests on deluge sprinkler systems where it is not practical to   Attachment A (NEI-04-02 B-1 Table) perform full flow tests and document trip time for deluge system actuation.                                       VFDR 3.9.1(2)-2 STATUS: Complete (CR-WF3-2011-06349 CA 28 & 42)
Waterford 3                                                                                                                                                        S-8

Entergy                                        Attachment S - Plant Modifications and Items to be Completed Table S-2 Implementation Items Item                                                      Description                                                       LAR Section / Source S2-7  Revise plant documents to address concerns associated with equipment being taken out of service during          Attachment D NPO modes. This procedure revision will provide guidelines for actions to be taken in specific fire areas when components or system trains are taken out of service. For those fire areas where the credited KSF system or equipment has been taken out of service the following guidelines will be included in plant procedures.
Prohibition or limitation of hot work.
Prohibition or limitation of combustible materials, and/or Establishment of additional fire watches as appropriate.
Utilizing the above outlined approaches to alleviate the identified "pinch points, the credited KSFs can be maintained.
STATUS: In Progress (LRLAR-2012-255 CA 61)
S2-8  Revise Entergy Procedure EN-DC-127, Control of Hot Work and Ignition Sources, and EN-DC-161, Control of Combustibles, to provide controls to limit the likelihood of a cable fire or a transient fire identified in the Attachment C Defense in Depth Report WF3-FP-13-00004.
STATUS: In Progress (CR-WF3-2014-0640 CA 14)
S2-9  Deleted (LAR Supplement W3F1-2013-0048)
S2-10  Develop and implement the NFPA 805 monitoring program per NFPA 805 Section 2.6.                                 LAR Section 4.6 STATUS: In Progress S2-11  Develop Fire Protection Design Basis Document as described in NFPA 805, Section 2.7.1.2 and necessary           LAR Section 4.7.1 supporting documentation as described in NFPA 805, Section 2.7.1.3. This is part of transition to 10 CFR 50.48(c) to ensure program implementation. A cross-reference to supporting documents will also be established.
STATUS : Complete (LRLAR-2012-0255 CA 50)
S2-12  Revise the Configuration Control Procedures to reflect NFPA 805 licensing basis requirements.                   LAR Section 4.7.2 STATUS: Complete (LRLAR-2011-0182 CA 17)
Waterford 3                                                                                                                                      S-9

Entergy                                          Attachment S - Plant Modifications and Items to be Completed Table S-2 Implementation Items Item                                                      Description                                                         LAR Section / Source S2-13  Several NFPA 805 document types such as: NSCA Supporting Information, Non-Power Mode NSCA                         LAR Section 4.7.2 Treatment, etc., generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be             RAI SS 01.01 modeled after the existing processes for similar types of documents and databases. System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play. This includes update of the Safe Shutdown Analysis.
STATUS: In Progress (WF3-CR-2014-0640 CA 14, LRLAR 2012-255 CA 61, LRLAR 2012-255 CA 48)
S2-14  Revise Entergy EN-DC-330, Fire Protection Program Procedures to reflect the applicable Quality Assurance          LAR Section 4.7.3 requirements of NFPA 805, section 2.7.3.
STATUS: In Progress (CR-WF3-2014-2029 CA 4)
S2-15  Post-transition, for personnel performing fire modeling or Fire PRA development and evaluation, Waterford 3       LAR Section 4.7.3 will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.
STATUS: Complete (WTHQN 2014-0019 CA33, 34 & 35.)
S2-16  Revise plant administrative procedures/documents to require periodic inspection of transformer oil collection     Attachment A (NEI-04-02 B-1 Table) basins and drain paths to ensure that they are free of debris and capable of performing their design function. VFDR 3.3.9-1 STATUS: In Progress (LRLAR-2011-0182 CA 32)
S2-17   Update the recovery action feasibility process against the criteria of FAQ 07-0030 including the incorporate of  Attachment G, Step 4 Results drills into the fire protection program to ensure all feasibility criteria in FAQ 07-0030 are addressed for NSCA RAIs SS 08.01, SS 12 and NPO recovery actions STATUS: Complete (WF3-CR-2014-640 CA 14)
S2-18   Develop or revise necessary plant procedures/documents to address requirements of NFPA 241, Section 5.1          Attachment A (NEI-04-02 B-1 Table) for Thermit Welding and revise Engineering Report WF3-FP-10-00021 "WF3 Code Compliance Report for NFPA 51B" to include compliance with NFPA 241 "Safeguarding Construction, Alteration, and Demolition             VFDR 3.3.1.3.1 Operations" - 2000 Edition.
STATUS: Complete (LRLAR-2011-0182 CA 22)
S2-19   Update the NSCA, engineering and PRA documentation to address transition to additional criteria in NEI 00-       RAI SS 02.01 01, Revision 2.
STATUS: Complete (LRLAR-2012-0255 CA 22 & 31)
Waterford 3                                                                                                                                                 S-10

Entergy                                         Attachment S - Plant Modifications and Items to be Completed Table S-2 Implementation Items Item                                                      Description                                                       LAR Section / Source S2-20   Following completion of updated FREs, evaluate revised list of Recovery Actions for feasibility using the      RAIs SS 08.01, SS 13 criteria of FAQ-07-0030 and revise Attachments C, G, S and W.
STATUS: Complete (W3F1-2013-0048)
S2-21   The FPRA has a mission time of 24-hours. Update plant procedures to satisfy the FPRA mission times for         LAR section 4.7.1 N2 accumulators III, IV, V, VI, VII and VIII.
STATUS: In Progress (LRLAR-2012-0255 CA 48)
S2-22   Verify the validity of the reported change in risk subsequent to completion of all PRA-credited modifications, LAR section 4.8.2 procedures updates, and implementation items matches the as-built, as-operated plant. The reported change-in-risk will meet the following considerations:.
: 1. Methods and guidance contained in NUREG/CR-7150 Volume 2 in addressing circuit failure         RAIs PRA S15 & PRA S17 probability.
: 2. Assessment of SOKC contributions in order to represent the mean value CDF and LERF as          RAI PRA S18.b.01 described in Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant - Specific Changes to the Licensing Basis, Revision 2, dated May 2011.
: 3. Updated fire-modeling for secondary ignition impacts with Hot Gas Layer (HGL) development      RAI FM S01.b.01 and Multi-Compartment Analysis (MCA) as described in response to FM RAI S01.b.01.
: 4. Updated fire-modeling for impacts due to re-assessment of the elevation of transient combustibles as presented in response to FM RAI S01.f.01.                                      RAI FM S01.f.01 STATUS: In Progress (LRLAR-2012-0255 CA 62.)
Waterford 3                                                                                                                                      S-11

ENCLOSURE 3 W3F1-2016-0003 Operating License Section 2.C.9 (markup)
: 8. Emergency Preparedness (Section 13.3, SSER 8)
In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 CFR Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency preparedness, the provisions of 10 CFR Section 50.54(s)(2) will apply.
: 9. Fire Protection (Section 9.5.1, SSER 8)
EOI shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 36 and as approved in the SER through Supplement 9, subject to the following provision:
INSERT 1 EOI may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely effect the ability to achieve and maintain safe shutdown in the event of fire.
: 10. Post-Fuel-Loading Initial Test Program (Section 14, SSER 10)
Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.
: 11. Emergency Response Capabilities (Section 22, SSER 8)
EOI shall comply with the requirements of Supplement 1 to NUREG-0737 for the conduct of a Detailed Control Room Design Review (DCRDR).
Prior to May 1, 1985, the licensee shall submit for staff review and approval the DCRDR Summary Report, including a description of the process used in carrying out the function and task analysis performed as a part of both the DCRDR and the Procedures Generation Package efforts.
: 12. Reactor Coolant System (RCS) Depressurization Capability (Section 5.4.3, SSER 8)
By June 18, 1985, the licensee shall submit the results of confirmatory tests regarding the depressurization capability of the auxiliary pressurizer spray (APS) system. This information must demonstrate that the APS system can perform the necessary depressurization to meet the steam generator single-tube rupture accident acceptance criteria (SRP 15.6.3) with loop charging isolation valve failed open. Should the test results fail to demonstrate that the acceptance criteria are met, the licensee must provide for staff review and approval, justification for interim operation, and a schedule for corrective actions.

INSERT 1 Waterford 3 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated ___________ (and supplements dated________ ) and as approved in the safety evaluation report dated (and supplements dated________ ). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met.
The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant.
Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the

INSERT 1 (continued) component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
Fire Alarm and Detection Systems (Section 3.8);
Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
Gaseous Fire Suppression Systems (Section 3.10); and, Passive Fire Protection Features (Section 3.11).
This condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated
________ to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
(2) The licensee shall implement the modifications to its facility as described in Attachment S, Table S-1 Plant Modifications in Entergy Operations, Inc letter W3F1-2016-0003, dated January 18, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by completion of the first refueling outage greater than 12 months following issuance of the license amendment.
The licensee shall maintain appropriate compensatory measures in place until completion of the modification listed as S1-5, (Installation of qualified 1-hour ERFBS fire wrap barrier in Fire Area RAB 6). All other modifications listed in Table S-1 are either installed or have no associated compensatory measure.
(3) The licensee shall implement the items listed in Attachment S, Table S-2 Implementation items in Entergy Operations, Inc letter W3F1-2016-0003, dated January 18, 2016, within 6 months following issuance of the license amendment.}}