W3F1-2015-0067, 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

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

ML15239B353
Person / Time
Site:	Waterford
Issue date:	08/27/2015
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, W3F1-2015-0067
Download: ML15239B353 (20)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 mchisum@entergy.com Michael R. Chisum Site Vice President Waterford 3 W3F1-2015-0067 August 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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 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)

W3F1-2015-0067 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)

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 and 9 provided the first, second, third and fourth six-month status reports for Waterford 3 respectively. The purpose of this letter is to provide, as an attachment, the fifth six month status report for the implementation of Order EA-12-049.

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.

W3F1-2015-0067 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 27, 2015.

Sincerely, MRC/AJH

Attachment:

Waterford Steam Electric Station, Unit 3, Fifth 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 W3F1-2015-0067 Waterford Steam Electric Station, Unit 3, Fifth 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 W3F1-2015-0067 Page 1 of 16 Waterford Steam Electric Station, Unit 3, Fifth 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 7), 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 January 31, 2015, and are current as of July 31, 2015.

Fourth Six-Month Status Report - February 2015 Fifth Six-Month Status Report Complete with submission of this document in August 2015 Staffing Analysis - June 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:

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 Perform Staffing Analysis June 2015 Complete N/A Modifications:

Attachment to W3F1-2015-0067 Page 2 of 16 Revised Target Target Milestone Completion Activity Status Completion Date **

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

Procedures Create Waterford FSGs Nov 2015 Started No Change Create Maintenance Procedures Nov 2015 Started No Change Training Develop Training Plan May 2015 Complete No Change Implement Training Nov 2015 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 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 and 7).

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

Attachment to W3F1-2015-0067 Page 3 of 16 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.

A fifth table includes the FLEX-related NRC Audit Visit Open Items, which includes open items on previously issued Audit Questions that were not closed during the July 2015 NRC Audit Visit and their status.

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 NRCs 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)

In the Status columns of the following tables, the phrase This item was closed during [following]

the July 2015 NRC Audit Visit indicates that the item was closed during or following the NRC Audit and is considered closed Overall Integrated Plan Open Item Status OI1. The suction path from the TDEFWP to the WCTs would be This item was closed through a non-running ACCWS pump post-ELAP. It is during the July 2015 expected that both the TDEFWP and the currently sized EFW NRC Audit Visit.

FLEX pump (primary strategy) will have sufficient capability and/or NPSH to do so. However, this will need to be confirmed more fully as the detailed design of the primary strategy for maintaining core cooling and heat removal evolves (with SGs available).

OI2. An analysis will be needed to demonstrate that containment This item was closed pressure and temperature will stay at acceptable levels during the July 2015 throughout the ELAP event and that no containment spray NRC Audit Visit system will be required as part of FLEX.

OI3. At this stage of the conceptual design, the chemistry This item was closed effects of alternate cooling source (ACS) use on during the July 2015 secondary wetted components are unknown. NRC Audit Visit.

OI4. It is currently unclear how long gravity feed from the SITs can This item was closed be maintained during Modes 5 and 6 in Phase 1. The ability to during the July 2015 gravity feed depends upon SIT fluid height/backpressure, line NRC Audit Visit losses through the gravity flow path, and developed pressure within the RCS. If this time is sufficiently short, Waterford 3 may choose to pre-stage requisite FLEX equipment in Modes 5

Attachment to W3F1-2015-0067 Page 4 of 16 Overall Integrated Plan Open Item Status and 6.

OI5. It is expected that only the component cooling water system This item was closed and dry cooling towers will need to be made operational to during the July 2015 reject the heat load generated post-ELAP in Phase 3. NRC Audit Visit.

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

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

Interim Staff Evaluation Open Items Status 3.1.3.A Wind Hazard Screening - The licensee's response This item was closed fails to consider the warning time offered by a during the July 2015 hurricane storm for pre-staging FLEX equipment. In NRC Audit Visit.

addition, as described in NEI 12-06, Section 7.2.2, hurricanes can have a significant impact on local infrastructure, e.g., downed trees and flooding that should be considered in the interface with off- site resources.

3.2.1.1.B CENTS - Justify conformance with the limitations of the This item was closed use of CENTS by providing the CENTS-calculated during the July 2015 value of the centered one-hour moving average of the NRC Audit Visit.

flow quality at the top of the SG tubes, which corresponds to the maximum void fraction of 0.2 in SG tubes as conditions used to define termination of single phase natural circulation, and confirming that the value is less than the limit specified in the white paper dated September 24, 2013 for use in defining the onset of reflux being.

Attachment to W3F1-2015-0067 Page 5 of 16 Interim Staff Evaluation Open Items Status 3.2.1.2.A RCP Seal Leakage - Justification of less than 15 This item was closed gpm per RCP seal leakage in analysis. during the July 2015 NRC Audit Visit. .

3.2.1.2.B RCP generic seal question regarding: (1) the analysis This item was closed used to determine the leakage rate, (2) cold leg during the July 2015 subcooling, (3) leakage flow path characteristics after NRC Audit Visit.

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 was closed 17601 states that decay heat is per ANS [American during the July 2015 Nuclear Society] 5.1-1979 + 2 sigma, or equivalent. NRC Audit Visit.

Address the applicability of assumption 4 to Waterford.

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

3.2.1.8.A Core Sub-Criticality- Regarding boron mixing, the This item was closed NRC staff has not yet accepted the PWROG during the July 2015

[Pressurized Water Reactor Owners Group] position NRC Audit Visit.

paper on boron mixing. Therefore, additional technical justification will be needed to resolve this issue, both generically and on a plant-specific basis.

3.2.4.2.A Ventilation - Adequacy of ventilation in the control This item was closed room to protect energized equipment throughout the during the July 2015 entire ELAP event, especially if the ELAP is due to NRC Audit Visit.

high temperature hazard.

3.2.4.2.B Ventilation- Effects of elevated temperatures in the This item was statused battery room, especially if the ELAP is due to a high as Open during the July temperature hazard. 2015 NRC Audit Visit.

See the July 2015 NRC Audit Visit FLEX Related Open Items table (below) Audit Item OI 3.2.4.2.B for status.

Attachment to W3F1-2015-0067 Page 6 of 16 Interim Staff Evaluation Open Items Status 3.2.4.2.C Ventilation - Hydrogen concentration in the battery This item was closed rooms during recharging during the July 2015 NRC Audit Visit.

3.2.4.2.D Ventilation - Loss of ventilation and any potential This item was closed impacts on the necessary equipment in the TDEFW during the July 2015 pump room. NRC Audit Visit.

3.2.4.4.A Lighting - Review the licensee's assessment of the This item was closed habitability/accessibility requirements to ensure during the July 2015 lighting is appropriately addressed. NRC Audit Visit.

3.2.4.8.A Electrical Power Sources/Isolation and Interactions- This item was closed Provide a summary of the sizing calculations used to during the July 2015 determine the adequacy of the FLEX generators used NRC Audit Visit.

to power plant electrical equipment.

3.2.4.10.A Load Reduction to Conserve DC Power - The This item was closed licensee's Integrated Plan on Page 7 identifies dc during the July 2015 load shed at hour 1 and 4. With regard to the load NRC Audit Visit.

shedding 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 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).

Attachment to W3F1-2015-0067 Page 7 of 16 Interim Staff Evaluation Confirmatory Items Status 3.1.1.1.A Seismic Protection - Licensee to ensure that: 1) seismic This item was interactions to ensure equipment is not damaged by non- closed during the seismically robust equipment or structures for portable July 2015 NRC equipment that will be stored outside; 2) how large FLEX Audit Visit.

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 was Reactor Coolant System (RCS) inventory control during the closed during the final phase is yet to be determined (TBD). July 2015 NRC Audit Visit.

3.1.1.2.B Seismic Protection - Protection of the tow vehicle used to This item was move the spare or "N+1" FLEX generator. (Also tied into to closed during the the ability to move equipment in the flooding context July 2015 NRC discussed in Section 3.1.2.2 and wind protection for the Audit Visit.

vehicle discussed in Section 3.1.3.2) 3.1.1.3.A Seismic Procedural Interface - Seismic hazards associated This item was with large internal flooding sources that are not seismically statused as Open robust and do not require ac power, and the use of ac power during the July to mitigate ground water in critical locations. 2015 NRC Audit Visit. See the July 2015 NRC Audit Visit FLEX Related Open Items table (below) Audit Item CI 3.1.1.3.A for status.

3.1.1.4.A Seismic Off site resources - The licensee has not yet This item was identified the local staging area and method of transportation closed during the to the site. July 2015 NRC Audit Visit.

3.1.2.2.A Flooding Deployment- Implementation of flooding This item was persistence into their FLEX strategies for pre-event staging closed during the of FLEX equipment. July 2015 NRC Audit Visit.

3.1.2.3.A Flooding Procedural Interface- Deployment of portable This item was equipment in flooded conditions not incorporated into flood closed during the procedures or the need to deploy temporary flood barriers July 2015 NRC and extraction pumps necessary to support deployment. Audit Visit.

Attachment to W3F1-2015-0067 Page 8 of 16 Interim Staff Evaluation Confirmatory Items Status 3.1.3.2.A Wind Deployment - Whether procedures and programs will This item was include taking proactive actions such as testing, connecting, closed during the and readying exposed portable equipment to reduce the July 2015 NRC potential for wind impacts. Audit Visit.

3.2.1.1.A CENTS - Verify the use of CENTS in the ELAP analysis for This item was Waterford is limited to the flow conditions before reflux closed during the boiling initiates. This includes providing a justification for how July 2015 NRC the initiation of reflux boiling is defined. Audit Visit.

3.2.1.4.A Initial Values for Key Plant Parameters and Assumptions- This item was Review analysis of UHS [Ultimate Heat Sink] (licensee open closed during the item OI5) July 2015 NRC Audit Visit.

3.2.3.A Containment Functions Strategies - Review the results of the This item was finalized containment analysis associated with open item OI2 statused as Open of the Integrated Plan, which shows that containment during the July functions will be (potentially) restored and maintained in 2015 NRC Audit response to an ELAP event. Visit. See the July 2015 NRC Audit Visit FLEX Related Open Items table (below) Audit Item CI 3.2.3.A for status.

3.2.4.4.B Communications - Confirm that upgrades to the site's This item was communications systems have been completed. closed during the July 2015 NRC Audit Visit.

3.2.4.5.A Protected and Internal Locked Area Access- Verify access This item was plans are incorporated into FLEX strategies. closed during the July 2015 NRC Audit Visit.

3.2.4.6.A Personnel Habitability - Review the licensee's assessment of This item was the habitability/accessibility requirements in all critical areas. closed during the July 2015 NRC Audit Visit.

3.2.4.7.A Water Sources -Verify the evaluation of the suction path from This item was the TDEFWP to the WCTs [Wet Cooling Towers] through a closed during the non-running ACCWS [Auxiliary Component Cooling Water July 2015 NRC System] pump post-ELAP confirms it is viable. Audit Visit.

3.2.4.7.B Water Sources - Description of how the licensee would get This item was water from the Mississippi River to the FLEX pumps. closed during the July 2015 NRC Audit Visit.

Attachment to W3F1-2015-0067 Page 9 of 16 Interim Staff Evaluation Confirmatory Items Status 3.2.4.8.B Electrical Power Sources/Isolation and Interactions - This item was Licensee to provide the level of detail of the FLEX closed during the instrumentation to ensure that electrical equipment remains July 2015 NRC protected (from an electrical standpoint- e.g., power Audit Visit.

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 was driven pump and how continued operation to ensure core closed during the cooling is maintained. Diesel fuel oil supply (e.g., fuel oil July 2015 NRC storage tank volume, supply pathway, etc.) for the FLEX Audit Visit.

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 was maintained. closed during the July 2015 NRC Audit Visit.

Audit Question Completion or Status Open Items Target Date WF3-001 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.1.1.A)

WF3-002 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-003 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.1.2.A)

WF3-004 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.1.2.B)

WF3-005 This item was closed during the July 2015 NRC Audit Closed Visit.(Associated with ISE Confirmatory Item 3.1.1.3.A)

WF3-006 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.1.4.A)

WF3-007 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.2.2.A)

WF3-008 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-009 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.2.3.A)

Attachment to W3F1-2015-0067 Page 10 of 16 Audit Question Completion or Status Open Items Target Date WF3-010 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-011 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-012 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.1.3.2.A)

WF3-013 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-014 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-015 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-017 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Items 3.2.1.1.B, &

3.2.1.8.A)

WF3-018 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Item 3.2.1.2.A &

3.2.1.2.B)

WF3-019 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Item 3.2.1.1.B)

WF3-020 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.1.1.A)

WF3-021 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Item 3.2.1.3.A)

WF3-022 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-023 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-024 This item was statused as Open during the July 2015 NRC Audit Visit. See the July 2015 NRC Audit Visit See AQ 24 FLEX Related Open Items table (below) Audit Item AQ 24 for status.

WF3-025 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.4.7.A)

WF3-026 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-027 This item was closed during the July 2015 NRC Audit Closed Visit.

Attachment to W3F1-2015-0067 Page 11 of 16 Audit Question Completion or Status Open Items Target Date WF3-028 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-029 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-030 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.3.A)

WF3-031 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-032 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated 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 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.4.6.A)

WF3-034 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Item 3.2.4.4.A)

WF3-035 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.4.5.A)

WF3-036 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.4.7.B)

WF3-038 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Item 3.2.4.8.B)

WF3-039 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Confirmatory Items 3.2.4.9.A and 3.2.4.9.B)

WF3-040 This item was closed during the July 2015 NRC Audit Closed Visit.

WF3-041 This item was closed during the July 2015 NRC Audit Closed Visit. (Associated with ISE Open Items 3.2.4.8.A &

3.2.4.10.A)

• Closed indicates that Entergys response is complete.

Attachment to W3F1-2015-0067 Page 12 of 16 July 2015 NRC Audit Visit FLEX-Related Open Items Audit Item Licensee Input Needed Item Description Status Reference or NRC Action to Close OI 3.2.4.2.B Ventilation- Effects of Open elevated temperatures in In progress, the battery room, especially expected if the ELAP is due to a high completion date is temperature hazard. September 2015 CI 3.1.1.3.A Seismic Procedural Open Interface - Seismic hazards In progress, associated with large expected internal flooding sources completion date is that are not seismically September 2015 robust and do not require ac power, and the use of ac power to mitigate ground water in critical locations.

CI 3.2.3.A Containment Functions Open Strategies - Review the Pending NRC results of the finalized review, no further containment analysis Entergy action associated with open item required.

OI2 of the Integrated Plan, which shows that containment functions will be (potentially) restored and maintained in response to an ELAP event.

AQ 24 List the safety and non- Open safety related (portable and In progress, plant installed) systems or expected equipment that are credited completion date is in the ELAP analysis for September 2015 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.

Attachment to W3F1-2015-0067 Page 13 of 16 July 2015 NRC Audit Visit FLEX-Related Open Items Audit Item Licensee Input Needed Item Description Status Reference or NRC Action to Close SE 3 Discuss how the plant Open specific guidance, In progress, mitigation strategies and expected the associated completion date is administrative controls and September 2015 training program will be developed and implemented SE 7 Please describe the impact Open of recent MOHRs SFPI Generic issue with equipment failures (failure MOHRs SFPI of the filter coil (or choke) equipment in particular) on the failures. No Waterford SFP level further Entergy instrument. Also, any action required.

actions/measures Waterford plans to implement to address this equipment failure.

SE 8 Provide an evaluation of Open the environmental In progress, qualification of containment expected electrical equipment as well completion date is as the atmospheric relief September 2015 valves showing that the equipment will be functional for the ELAP mission time.

SE 18 Provide additional Open justification for the alternate In progress, approach to NEI 12-06 expected involving the use of completion date is installed spent fuel pool September 2015 cooling pumps.

SE 24 Guidance for transitioning Open from Phase 2 DGs to In progress, Phase 3 Turbine expected Generators (FSG5 completion date is Attachment 21) did not September 2015 address deployment during flooded conditions.

Attachment to W3F1-2015-0067 Page 14 of 16 July 2015 NRC Audit Visit FLEX-Related Open Items Audit Item Licensee Input Needed Item Description Status Reference or NRC Action to Close SE 25 Provide an evaluation for Open the robustness of the N In progress, storage Building and the expected room beneath where completion date is electrical connection panel September 2015 is located.

SE 26 During the site audit Open walkdown, the NRC staff In progress, noticed that the SFPI cable expected conduits at EL. 21 of the completion date is RAB were installed side by September 2015 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.

SE 27 The licensee plans to use a Open single installed suction In progress, source and connection expected point for the FLEX Core completion date is Cooling pump and the September 2015 CCW makeup pumps (used for spent fuel pool

Attachment to W3F1-2015-0067 Page 15 of 16 July 2015 NRC Audit Visit FLEX-Related Open Items Audit Item Licensee Input Needed Item Description Status Reference or NRC Action to Close 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.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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

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

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

Attachment to W3F1-2015-0067 Page 16 of 16

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)

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)