ML16055A232

Waterford, Unit 3 - Sixth 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

ML16055A232
Person / Time
Site:	Waterford
Issue date:	02/24/2016
From:	Chisum M R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, W3F1-2016-0009
Download: ML16055A232 (11)

Text

W3F1-2016-0009 February 24, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Sixth 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. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174) 3. Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ADAMS Accession No. ML12221A205) 4. Entergy letter to NRC, "Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 26, 2012 (W3F1-2012-0093) (ADAMS Accession No. ML12300A447) 5. Waterford Steam Electric Station, Unit 3 letter to NRC, "Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (ADAMS Accession No. ML13063A266) 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 W3F1-2016-0009 Page 2 of 3 6. 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) 7. Waterford Steam Electric Station, Unit 3 letter to NRC, "Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" dated February 28, 2014 (ADAMS Accession No. ML14059A085) 8. 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) 9. Waterford Steam Electric Station, Unit 3 letter to NRC, "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" dated February 26, 2015 (ADAMS Accession No.ML15057A548) 10. Waterford Steam Electric Station, Unit 3 letter to NRC, "Fifth 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 27, 2015 (ADAMS Accession No.ML15239B353)

Dear Sir or Madam:

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

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP). Reference 2 endorses industry guidance document NEI 12-06, Revision 1 (Reference 3). Reference 4 provided the initial status report regarding mitigating strategies and Reference 5 provided the OIP. NRC Order EA-12-049 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan with regard to the requirements for mitigation strategies for beyond-design-basis external events for Waterford 3. References 6, 7, 8, 9 and 10 provided the first, second, third, fourth and fifth six-month status reports for Waterford 3 respectively. The purpose of this letter is to provide, as an attachment, the sixth six month status report for the implementation of Order EA-12-049.

W3F1-2016-0009 Page 3 of 3 There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact John Jarrell, Regulatory Assurance Manager, at (504) 739-6685. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 24, 2015. Sincerely, MRC/AJH

Attachment:

Waterford Steam Electric Station, Unit 3, Sixth 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 April.Pulvirenti@nrc.gov NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov

Attachment W3F1-2016-0009 Waterford Steam Electric Station, Unit 3, Sixth 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 W3F1-2016-0009 Page 1 of 7 Waterford Steam Electric Station, Unit 3, Sixth 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) 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 78f), 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, 2015, and are current as of January 31, 2016. Fifth Six-Month Status Report - August 2015 Sixth Six-Month Status Report - Complete with submission of this document in February 2016 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. Milestone Target Completion Date ** Activity Status Revised Target Completion Date Submit Overall Integrated Plan Feb 2013 Complete N/A Submit Six Month Updates: Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Complete N/A Update 5 Aug 2015 Complete N/A Update 6 Feb 2016 Complete N/A Perform Staffing Analysis June 2015 Complete N/A Attachment to W3F1-2016-0009 Page 2 of 7 Milestone Target Completion Date ** Activity Status Revised Target Completion Date Modifications: Engineering and Implementation N-1 Walkdowns May 2014 Complete N/A Design Engineering March 2015 Complete N/A Implementation Outage Nov 2015 Complete N/ANo Change* On-Line Modification Scope *** April 2016 Started N/A On-site FLEX Equipment Purchase March Oct 2015 Started Complete N/AMarch 2016 Procure Sept Nov 2015 Started March 2016April 2016Off-site FLEX Equipment Develop Strategies with RRC Sept 2015 CompleteStarted April 2016N/A Install Off-Site Delivery Station (if Necessary) Nov 2015 Complete / Not necessary N/A Procedures Create Waterford FSGs Nov 2015 Started March 2016 Create Maintenance Procedures Nov 2015 Started March 2016April 2016Training Develop Training Plan May 2015 Complete N/A Implement Training Nov 2015 Started February 2016 Submit Completion Report Feb 2016* Not Started August July 2016*

• Waterford requested and received an extension beyond the fall 2015 completion outage to complete implementation of FLEX. This date corresponds to the last six month status report and provides time 60 days to compile the report following the completion of implementation activities by May 31, 2016. ** Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports *** Added to Milestone Table with this report Attachment to W3F1-2016-0009 Page 3 of 7 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (OIP) (Reference 1) and in previous documents (References 3, 5, 6, 7 and 7) 8). 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Waterford 3 received an extension of the Waterford 3 order implementation date from the completion of the fall 2015 refueling outage to no later than May 31, 2016 due to significant construction delays of the new structure on the Reactor Auxiliary Building (RAB) (Reference 9). 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table provides a summary of remaining open items following the July 2015 NRC Audit Visit as documented in the NRC's Audit report (Reference 10). Note that during the July 2015 NRC Audit Visit, the NRC utilized a spreadsheet entitled "Waterford SE Item Tracker" to maintain a status of Open Items associated with development of the NRC's Safety Evaluation. The SE Tracker numbered each item with an Audit Item No. based on the category of the Open Item. The categories were: A. ISE Open and Confirmatory Items (Audit Item OI-xxxxx or CI-xxxxx)

B. Audit Questions (Audit Item AQ. X)

C. Licensee OIP Open Items (Audit Item OIP. X) D. SFP Instrumentation RAIs (Audit Item SFP. X) E. Combined SE Template Technical Review Gaps (Audit Item SE. X) Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status OI 3.2.4.2.B Ventilation- Effects of elevated temperatures in the battery room, especially if the ELAP is due to a high temperature hazard. Calculation provided on ePortal. NRC Reviewing CI 3.1.1.3.A Seismic Procedural Interface - Seismic hazards associated with large internal flooding sources that are not seismically robust and do not require ac power, and the use of ac power to mitigate ground water in critical locations. Response provided on ePortal. NRC Reviewing CI 3.2.3.A Containment Functions Strategies - Review the results of the finalized containment analysis associated with open item OI2 of the Integrated Plan, which shows that containment functions will be (potentially) restored and maintained in response to an ELAP event. Response provided on ePortal. NRC Reviewing Attachment to W3F1-2016-0009 Page 4 of 7 Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status AQ 24 List the safety and non-safety related (portable and plant installed) systems or equipment that are credited in the ELAP analysis for consequences mitigation, and for all the systems or equipment, discuss the associated design safety functions and justify the listed systems or equipment are available and reliable to provide the design functions on demand during the ELAP. Response provided on ePortal. NRC Reviewing SE 3 Discuss how the plant specific guidance, mitigation strategies and the associated administrative controls and training program will be developed and implemented In progress, expected completion date is May 2016 SE 7 Please describe the impact of recent MOHR's SFPI equipment failures (failure of the filter coil (or choke) in particular) on the Waterford SFP level instrument.

Also, any actions/measures Waterford plans to implement to address this equipment failure. Response provided on ePortal. NRC Reviewing SE 8 Provide an evaluation of the environmental qualification of containment electrical equipment as well as the atmospheric relief valves showing that the equipment will be functional for the ELAP mission time. Response provided on ePortal. NRC Reviewing SE 18 Provide additional justification for the alternate approach to NEI 12-06 involving the use of installed spent fuel pool cooling pumps. Response provided on ePortal. NRC Reviewing SE 24 Guidance for transitioning from Phase 2 DGs to Phase 3 Turbine Generators (FSG5 Attachment 21) did not address deployment during flooded conditions. In progress, expected completion date is February 2016. SE 25 Provide an evaluation for the robustness of the "N" storage Building and the room beneath where electrical connection panel is located. Response provided on ePortal. NRC Reviewing Attachment to W3F1-2016-0009 Page 5 of 7 Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status SE 26 During the site audit walkdown, the NRC staff noticed that the SFPI cable conduits at EL. 21' of the RAB were installed side by side, 5" apart, for approximately 20'. This conduit installation does not meet the NRC Order EA-12-051, which requires The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the instruments to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure. Response provided on ePortal. NRC Reviewing SE 27 The licensee plans to use a single installed suction source and connection point for the FLEX Core Cooling pump and the CCW makeup pumps (used for spent fuel pool cooling). The staff considers this an alternative to NEI 12-06 Section 3.2.2.

Specifically, Table D-1 provides guidance on primary and alternate connections and states that injection points are, "required to inject through separate divisions/trains, i.e., should not have both connections in one division/train. "While the licensee has multiple injection paths for core cooling downstream of the FLEX manifold, all cooling water delivery paths must be routed through the single WCT outlet and connection point. Therefore, both the primary and alternate methods share a common connection. Response provided on ePortal. NRC Reviewing 7 7PotentialInterimStaffEvaluationImpacts There are no additional items that have a potential impact on the Interim Staff Evaluation.

Attachment to W3F1-2016-0009 Page 6 of 7 8 In addition to the items discussed in Section 6, the item discussed below has a potential impact on the Interim Staff Evaluation: As discussed in the Third Six Month Update (Reference 6), an updated sequence of events timing for the SFP cooling strategy was in development and has been finalized, consistent with the response to SE 18. The updated strategy provides for SFP makeup and spray capability during Phase 2, prior to reaching SFPI Level 3. Details of the strategy are presented in the response to SE 18, provided on the ePortal. 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). 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 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) 7. Waterford Steam Electric Station, Unit 3 letter to NRC, "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" dated February 26, 2015 (ADAMS Accession No.ML15057A548) 8. Waterford Steam Electric Station, Unit 3 letter to NRC, "Fifth 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 27, 2015 (ADAMS Accession No.ML15239B353)

Attachment to W3F1-2016-0009 Page 7 of 7

9. NRC letter to Waterford Steam Electric Station, "Waterford Steam Electric Station, Unit 3 - Relaxation of the Schedule Requirements for Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (TAC No. MF0977)" dated October 4, 2015 (ADAMS Accession No. ML15245A344) 10. NRC letter to Waterford Steam Electric Station, "Waterford Steam Electric Station, Unit 3 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0977 and MF0946)" dated October 6, 2015 (ADAMS Accession No. ML15272A398) 10.

W3F1-2016-0009 February 24, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Sixth 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. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174) 3. Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ADAMS Accession No. ML12221A205) 4. Entergy letter to NRC, "Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 26, 2012 (W3F1-2012-0093) (ADAMS Accession No. ML12300A447) 5. Waterford Steam Electric Station, Unit 3 letter to NRC, "Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (ADAMS Accession No. ML13063A266) 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 W3F1-2016-0009 Page 2 of 3 6. 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) 7. Waterford Steam Electric Station, Unit 3 letter to NRC, "Second Six Month Status Report for Implementation of Order EA-12-049, Commission Order Modifying License With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" dated February 28, 2014 (ADAMS Accession No. ML14059A085) 8. 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) 9. Waterford Steam Electric Station, Unit 3 letter to NRC, "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" dated February 26, 2015 (ADAMS Accession No.ML15057A548) 10. Waterford Steam Electric Station, Unit 3 letter to NRC, "Fifth 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 27, 2015 (ADAMS Accession No.ML15239B353)

Dear Sir or Madam:

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

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP). Reference 2 endorses industry guidance document NEI 12-06, Revision 1 (Reference 3). Reference 4 provided the initial status report regarding mitigating strategies and Reference 5 provided the OIP. NRC Order EA-12-049 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan with regard to the requirements for mitigation strategies for beyond-design-basis external events for Waterford 3. References 6, 7, 8, 9 and 10 provided the first, second, third, fourth and fifth six-month status reports for Waterford 3 respectively. The purpose of this letter is to provide, as an attachment, the sixth six month status report for the implementation of Order EA-12-049.

W3F1-2016-0009 Page 3 of 3 There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact John Jarrell, Regulatory Assurance Manager, at (504) 739-6685. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 24, 2015. Sincerely, MRC/AJH

Attachment:

Waterford Steam Electric Station, Unit 3, Sixth 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 April.Pulvirenti@nrc.gov NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov

Attachment W3F1-2016-0009 Waterford Steam Electric Station, Unit 3, Sixth 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 W3F1-2016-0009 Page 1 of 7 Waterford Steam Electric Station, Unit 3, Sixth 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) 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 78f), 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, 2015, and are current as of January 31, 2016. Fifth Six-Month Status Report - August 2015 Sixth Six-Month Status Report - Complete with submission of this document in February 2016 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. Milestone Target Completion Date ** Activity Status Revised Target Completion Date Submit Overall Integrated Plan Feb 2013 Complete N/A Submit Six Month Updates: Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Complete N/A Update 5 Aug 2015 Complete N/A Update 6 Feb 2016 Complete N/A Perform Staffing Analysis June 2015 Complete N/A Attachment to W3F1-2016-0009 Page 2 of 7 Milestone Target Completion Date ** Activity Status Revised Target Completion Date Modifications: Engineering and Implementation N-1 Walkdowns May 2014 Complete N/A Design Engineering March 2015 Complete N/A Implementation Outage Nov 2015 Complete N/ANo Change* On-Line Modification Scope *** April 2016 Started N/A On-site FLEX Equipment Purchase March Oct 2015 Started Complete N/AMarch 2016 Procure Sept Nov 2015 Started March 2016April 2016Off-site FLEX Equipment Develop Strategies with RRC Sept 2015 CompleteStarted April 2016N/A Install Off-Site Delivery Station (if Necessary) Nov 2015 Complete / Not necessary N/A Procedures Create Waterford FSGs Nov 2015 Started March 2016 Create Maintenance Procedures Nov 2015 Started March 2016April 2016Training Develop Training Plan May 2015 Complete N/A Implement Training Nov 2015 Started February 2016 Submit Completion Report Feb 2016* Not Started August July 2016*

• Waterford requested and received an extension beyond the fall 2015 completion outage to complete implementation of FLEX. This date corresponds to the last six month status report and provides time 60 days to compile the report following the completion of implementation activities by May 31, 2016. ** Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports *** Added to Milestone Table with this report Attachment to W3F1-2016-0009 Page 3 of 7 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (OIP) (Reference 1) and in previous documents (References 3, 5, 6, 7 and 7) 8). 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Waterford 3 received an extension of the Waterford 3 order implementation date from the completion of the fall 2015 refueling outage to no later than May 31, 2016 due to significant construction delays of the new structure on the Reactor Auxiliary Building (RAB) (Reference 9). 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table provides a summary of remaining open items following the July 2015 NRC Audit Visit as documented in the NRC's Audit report (Reference 10). Note that during the July 2015 NRC Audit Visit, the NRC utilized a spreadsheet entitled "Waterford SE Item Tracker" to maintain a status of Open Items associated with development of the NRC's Safety Evaluation. The SE Tracker numbered each item with an Audit Item No. based on the category of the Open Item. The categories were: A. ISE Open and Confirmatory Items (Audit Item OI-xxxxx or CI-xxxxx)

B. Audit Questions (Audit Item AQ. X)

C. Licensee OIP Open Items (Audit Item OIP. X) D. SFP Instrumentation RAIs (Audit Item SFP. X) E. Combined SE Template Technical Review Gaps (Audit Item SE. X) Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status OI 3.2.4.2.B Ventilation- Effects of elevated temperatures in the battery room, especially if the ELAP is due to a high temperature hazard. Calculation provided on ePortal. NRC Reviewing CI 3.1.1.3.A Seismic Procedural Interface - Seismic hazards associated with large internal flooding sources that are not seismically robust and do not require ac power, and the use of ac power to mitigate ground water in critical locations. Response provided on ePortal. NRC Reviewing CI 3.2.3.A Containment Functions Strategies - Review the results of the finalized containment analysis associated with open item OI2 of the Integrated Plan, which shows that containment functions will be (potentially) restored and maintained in response to an ELAP event. Response provided on ePortal. NRC Reviewing Attachment to W3F1-2016-0009 Page 4 of 7 Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status AQ 24 List the safety and non-safety related (portable and plant installed) systems or equipment that are credited in the ELAP analysis for consequences mitigation, and for all the systems or equipment, discuss the associated design safety functions and justify the listed systems or equipment are available and reliable to provide the design functions on demand during the ELAP. Response provided on ePortal. NRC Reviewing SE 3 Discuss how the plant specific guidance, mitigation strategies and the associated administrative controls and training program will be developed and implemented In progress, expected completion date is May 2016 SE 7 Please describe the impact of recent MOHR's SFPI equipment failures (failure of the filter coil (or choke) in particular) on the Waterford SFP level instrument.

Also, any actions/measures Waterford plans to implement to address this equipment failure. Response provided on ePortal. NRC Reviewing SE 8 Provide an evaluation of the environmental qualification of containment electrical equipment as well as the atmospheric relief valves showing that the equipment will be functional for the ELAP mission time. Response provided on ePortal. NRC Reviewing SE 18 Provide additional justification for the alternate approach to NEI 12-06 involving the use of installed spent fuel pool cooling pumps. Response provided on ePortal. NRC Reviewing SE 24 Guidance for transitioning from Phase 2 DGs to Phase 3 Turbine Generators (FSG5 Attachment 21) did not address deployment during flooded conditions. In progress, expected completion date is February 2016. SE 25 Provide an evaluation for the robustness of the "N" storage Building and the room beneath where electrical connection panel is located. Response provided on ePortal. NRC Reviewing Attachment to W3F1-2016-0009 Page 5 of 7 Remaining Open Items from July 2015 NRC Audit Visit per Audit Report (Reference 10) Audit Item Reference Item Description Status SE 26 During the site audit walkdown, the NRC staff noticed that the SFPI cable conduits at EL. 21' of the RAB were installed side by side, 5" apart, for approximately 20'. This conduit installation does not meet the NRC Order EA-12-051, which requires The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the instruments to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure. Response provided on ePortal. NRC Reviewing SE 27 The licensee plans to use a single installed suction source and connection point for the FLEX Core Cooling pump and the CCW makeup pumps (used for spent fuel pool cooling). The staff considers this an alternative to NEI 12-06 Section 3.2.2.

Specifically, Table D-1 provides guidance on primary and alternate connections and states that injection points are, "required to inject through separate divisions/trains, i.e., should not have both connections in one division/train. "While the licensee has multiple injection paths for core cooling downstream of the FLEX manifold, all cooling water delivery paths must be routed through the single WCT outlet and connection point. Therefore, both the primary and alternate methods share a common connection. Response provided on ePortal. NRC Reviewing 7 7PotentialInterimStaffEvaluationImpacts There are no additional items that have a potential impact on the Interim Staff Evaluation.

Attachment to W3F1-2016-0009 Page 6 of 7 8 In addition to the items discussed in Section 6, the item discussed below has a potential impact on the Interim Staff Evaluation: As discussed in the Third Six Month Update (Reference 6), an updated sequence of events timing for the SFP cooling strategy was in development and has been finalized, consistent with the response to SE 18. The updated strategy provides for SFP makeup and spray capability during Phase 2, prior to reaching SFPI Level 3. Details of the strategy are presented in the response to SE 18, provided on the ePortal. 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). 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 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) 7. Waterford Steam Electric Station, Unit 3 letter to NRC, "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" dated February 26, 2015 (ADAMS Accession No.ML15057A548) 8. Waterford Steam Electric Station, Unit 3 letter to NRC, "Fifth 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 27, 2015 (ADAMS Accession No.ML15239B353)

Attachment to W3F1-2016-0009 Page 7 of 7

9. NRC letter to Waterford Steam Electric Station, "Waterford Steam Electric Station, Unit 3 - Relaxation of the Schedule Requirements for Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (TAC No. MF0977)" dated October 4, 2015 (ADAMS Accession No. ML15245A344) 10. NRC letter to Waterford Steam Electric Station, "Waterford Steam Electric Station, Unit 3 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0977 and MF0946)" dated October 6, 2015 (ADAMS Accession No. ML15272A398) 10.