ML14239A679

Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML14239A679
Person / Time
Site:	Fort Calhoun
Issue date:	08/27/2014
From:	Dean E Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, LlC-14-0108
Download: ML14239A679 (15)

Text

-~.:..

ujjjju Omaha Public Power District 444 South 1fih Street Mall Omaha, NE 68102-2247 LlC-14-0108 August 27, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Omaha Public Power District's Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

References:

See Page 3 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was effective immediately and requires the Omaha Public Power District (OPPD) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Specific requirements are described in Attachment 2 of the Order.

Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the Overall Integrated Plan (OIP),

which OPPD submitted on February 28, 2013 (Reference 4). This letter provides the third six-month status report. Updates to the Milestone Schedule made in previous status reports (References 5 and 6) have been incorporated. The enclosed Milestone Schedule supersedes the schedules provided with References 5 and 6.

The OIP (Reference 4) and subsequent six-month status reports were prepared utilizing NEI guidance (Reference 2) as endorsed with exceptions and clarifications by the NRC in Reference 3.

There are no regulatory commitments contained in this submittal.

If you should have any questions regarding this submittal, please contact Mr. Bill R.

Hansher at (402) 533-6894.

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LlC-14-0108 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 27, 2014.

Respectfully,

(!~

Edwin D. Dean III Plant Manager EDD/GEG/mle

Enclosure:

Third Six-Month Status Report for the Implementation of Order EA-12-049

U. S. Nuclear Regulatory Commission LlC-14-0108 Page 3 References

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12,2012 (ML12054A736) (NRC-12-0020)

2. Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ML12242A378)

3. 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 (ML12229A174)

4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Overall Integrated Plan 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 February 28, 2013 (ML13064A298) (LlC-13-0019)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," dated August 28, 2013 (ML13268A075) (LlC-13-0123)

6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," dated February 24, 2014 (ML14055A412) (LlC-14-0021)

LlC-14-0108 Enclosure Page 1 Fort Calhoun Station, Unit No.1 Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction The Omaha Public Power District (OPPD) developed an Overall Integrated Plan (Reference 1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments

• Control Room Heatup Calculation has been completed.

• FLEX Support Guideline Basis Documents and Executive Volume have been issued.

Although not specifically identified as a Milestone, the Draft Lower Mode FLEX Support Guidelines were issued as well.

3 Milestone Schedule Status contains an update to the Milestone Schedule (Reference 1, Enclosure, ) provided with the Overall Integrated Plan. The status of each milestone is shown, as are revised completion dates. The dates are planning dates subject to change as design and implementation details are developed. Attachment 1 is formatted to align with the table provided in the Nuclear Energy Institute's (NEI) Six-Month Status Report Template and supersedes the Milestone Schedule provided by Reference 1.

Evaluation of FLEX modifications is largely complete. However, the completion date was revised to accommodate development of a conceptual design for remote monitoring of critical safety parameters that will address beyond design basis flooding. Based on industry operating experience on the timing of FLEX storage building design and construction time windows, the target completion date for procurement of on-site FLEX equipment was extended to allow prioritization of resources for the development of FLEX modifications. The revised milestone target completion dates do not impact the implementation date of the Order.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Fort Calhoun Station Overall Integrated Plan (Reference 1). The results of the Control Room heatup calculation (see Overall Integrated Plan Open Item #2 in Section 6, below) show that control room cooling will not be required for a significantly longer period of time than was assumed in the Overall Integrated Plan timeline. OPPD is evaluating the method that will be used to establish cooling to the control room and will provide an update to the strategy in a future 6-month update.

As discussed in previous 6-month updates, OPPD has developed an interim strategy to address beyond-design-basis (BDB) flooding. This strategy is similar to that described in Reference 1,

LlC-14-0108 Enclosure Page 2 Enclosure, Appendix B, Action 24, but involves a slightly different portable equipment configuration to accommodate issues not yet addressed by FLEX modifications. OPPD is currently revising the interim BDB flooding strategy to address the potential higher flooding levels. Some or all of the interim equipment and strategies may be incorporated into the FLEX Overall Integrated Plan. OPPD will provide the status of potential integration of the interim flood strategy into the Overall Integrated Plan in a future six-month update.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation OPPD expects to comply with the Order's implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status

1. Communicate exceptions related to Site Security Not Started Plan or Other License requirements

2. Complete Control Room Heatup Calculation Complete

3. Complete Reactor Coolant System (RCS) Makeup Not Started Evaluation with Reactor Coolant Pump (RCP)

Controlled Bleed-off (CBO) Modification

4. Develop Playbook Started

5. Complete Water Chemistry Impact Analysis and Complete review impact on the strategies

6. Complete Core Uncovery Time Evaluation with RCP Not Started CBO Isolation. (This is subtask of open item #3.)

7. Evaluate Auxiliary Building Ventilation Requirements Started with Spent Fuel Pool (SFP) Evaporation

8. Evaluate Environmental Conditions after Extended Not Started Loss of AC Power (ELAP) in critical FLEX deployment areas Draft Safety Evaluation Open / Confirmatory Items Status Interim Staff Evaluation (ISE) dated February 27, 2014 Attachment 2 of this enclosure (Reference 3). describes the status of the Open Items and Confirmatory Items from the ISE.

LlC-14-0108 Enclosure Page 3 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Overall Integrated Plan 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 February 28, 2013 (ML13064A298), (LlC-13-0019)

2. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012 (ML12054A736), (NRC-12-0020)

3. Letter from NRC (J. S. Bowen) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit 1 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NO. MF0969)" (ML14007A693) (NRC-14-0014)

Attachments: 1. FLEX Overall Integrated Implementation Plan Milestone Schedule, Revision 3

2. Status of Interim Staff Evaluation Open Items and Confirmatory Items

LlC-14-0108 Enclosure, Attachment 1 Page 1 Fort Calhoun Station EA-12-049 (FLEX) Overall Integrated Implementation Plan Milestone Schedule Revision 3 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in subsequent 6-month status reports.

Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60-Day Status Report Oct. 2012 Complete Submit Overall Integrated Plan Feb. 2013 Complete Submit 6-Month Updates:

Update 1 Aug. 2013 Complete Update 2 Feb. 2014 Complete Update 3 Aug. 2014 Complete Update 4 Feb. 2015 Not Started Update 5 Aug. 2015 Not Started Update 6 Feb. 2016 Not Started Update 7 Aug. 2016 Not Started FLEX Strategy Evaluation Nov. 2014 Started Walk-throughs or Demonstrations Nov. 2016 Not Started Perform Staffing Analysis Sep.2015 Not Started Modifications:

Modifications Evaluation Jun. 2014 Started Sep.2014 Design Engineering Aug 2015 Started Implementation Outage Oct. 2016 Not Started Storage:

Storage Design Engineering Oct. 2015 Started Storage Implementation Apr. 2016 Not Started FLEX Equipment:

Procure On-Site Equipment Aug. 2014 Started Mar. 2016 Develop Strategies with RRC Mar. 2015 Started Install Off-Site Delivery Station (if Not planned at Not planned at Necessary) this time this time Procedures:

PWROG issues NSSS-specific Jun. 2014 Complete guidelines Create Site-Specific FSGs May 2015 Not Started Create Maintenance Procedures Feb. 2015 Not Started Training:

Develop Training Plan Nov. 2014 Not Started Training Complete Sep. 2016 Not Started Full Site FLEX Implementation Oct. 2016 Started Submit Completion Report Dec. 2016 Not Started

L1C-14-0108 Enclosure, Attachment 2 Page 1 Status of Interim Staff Evaluation Open Items and Confirmatory Items OPEN ITEMS Item NRC Ref. Description Status

1. # August 2014 Update 1 3.2.1.6.B Sequence of Events- Confirm whether the CENTS code NOT STARTED ELAP reanalysis reflecting the CBO isolation Expect completion to be documented in February modification affected the SOE timeline, and if so, that 2015 Update.

the SOE timeline has been updated and the overall FLEX mitigation strategies reflect these results.

CONFIRMATORY ITEMS Item NRC Ref. Description Status I

1. # August 2014 Update I 1 3.1.1.1.A Protection of FLEX equipment (seismic hazard)- IN PROGRESS Confirm that all FLEX equipment stored in the auxiliary Expect completion of design documentation by building and the new FLEX Support Building (FSB) are February 2016 Update. Expect completion of seismically restrained to ensure equipment is not i building and placement of FLEX equipment by I damaged during a seismic event and that the FLEX August 2016 Update. I equipment is not damaged by non-seismically robust equipment due to seismic interactions.

2 3.1.1.2.A Deployment of FLEX equipment (seismic hazard) - IN PROGRESS Confirm that deployment pathways for the FLEX Expect completion of design documentation by I portable equipment are not susceptible to soil February 2016 Update. Expect completion of liquefaction. building and placement of FLEX equipment by August 2016 Update.

I

LlC-14-0108 Enclosure, Attachment 2 Page 2 Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 3 3.1.1.3.A Procedural Interfaces (seismic) - Confirm the licensee IN PROGRESS develops (1) methods and locations for alternate Expect completion to be documented in August monitoring of key parameters; (2) guidance on critical 2015 Update.

actions to perform until alternate indications can be obtained; and (3) guidance on control of critical equipment without control power.

4 3.1.1.4.A Off-site Resources - Confirm the location of the off-site NOT STARTED staging area(s) and acceptability of.the ~ccess rout~s Expect completion of Regional Response Center considering the seismic, flooding, high wind, snow, Ice, "Playbook" by February 2016 Update.

and extreme cold hazard.

S 3.1.2.2.A Deployment (flood) - Confirm the m~thod .of ~ccess~ng IN PROGRESS the ultimate heat sink (UHS), the MIssouri River, uSing A conceptual design has been developed to FLEX equipment during high river levels or a~er floo~ install a FLEX well that will provide a means to waters inundate the site up to the current design basIs provide makeup water to the Steam Generators, flood elevation of 1,014 foot elevation is addressed.

RCS and Spent Fuel Pool via a submersible The plan does not identify the deployed location of the pump. Alternately, submersible pumps procured fire truck or river drafting pump nor how they are for the interim Beyond Design Basis flooding may accessed and monitored by plant operators, be used to access flood waters if the FLEX well considering the site's flooded condition.

is not considered a viable option.

Expect completion of design documentation by August 2015 Update. Expect completio~ of well and/or and final placement of FLEX eqUipment for flooding response by August 2016 Update.

6 3.1 .3.1.A Protection of FLEX Equipment (high wind hazard)- IN PROGRESS Confirm the design code used for the FSB for the high Expect completion of design documentation by wind hazard and the method of protection of the N+ 1 February 2016 Update. Expect completion of FLEX equipment from tornado borne missiles is building by August 2016 Update.

acceptable.

LlC-14-0108 Enclosure, Attachment 2 Page 3 Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 7 3.2.1.1.A CENTS - Confirm that the use of CENTS in the ELAP NOT STARTED analysis for FCS is limited to the flow conditions before Documentation of application of CENTS reflux boiling initiates. This includes providing a limitations regarding reflux boiling will be justification for how the initiation of reflux boiling is specifically addressed in the nuclear steam .

defined. Confirm that the reanalysis for the case with supply system (NSSS) timing analysis that will be the CSO isolated conforms to the above limitations.

performed to address Open Item #1.

8 3.2.1.2.S RCP Seal Leakage Rates - Confirm the selection and NOT STARTED justification for the seal leakage rates assumed in the Documentation of the effects of isolation of CSO ELAP analysis from the initiation of the ELAP event to on RCS leak rates will be specifically addressed the time frame when subcooling in the RCS cold legs in the NSSS timing analysis that will be decreases to less than 50°F. Confirm the calculated performed to address Open Item #1.

maximum temperature and pressure, and minimum subcooling in the RCS cold legs during the ELAP before isolation of the CSO. Confirm the seal leakage rates per RCP before and after isolation of the CSO used in the ELAP reanalysis for determination of the SOE and associated time limes.

9 3.2.1.3.A Decay Heat - Confirm the key physics parameters used NOT STARTED for each of the decay heat evaluation scenarios to Documentation of the validity of the design inputs ensure that the FCS ELAP response is conservative will be provided in the NSSS timing analysis that relative to the ANS standard.

will be performed to address Open Item #1 .

10 3.2.1.4.A Initial Values for Key Plant Parameters and NOT STARTED Assumptions- Confirm which inputs and assumptions Documentation of the validity of the design inputs are appropriate relative to being plant specific or and assumptions will be provided in the NSSS derived from WCAP-17601-P.

timing analysis that will be performed to address Open Item #1 .

LlC-14-0108 Enclosure, Attachment 2 Page 4 Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 11 3.2.1.5.A Monitoring Instrumentation and Controls - Confirm IN PROGRESS suitability of emergency feedwater storage tank The ability to monitor EFWST level locally will be (EFWST) level monitoring instrumentation considering addressed as part of the alternate monitoring the environmental conditions in the auxiliary building locations conceptual design discussed in Item following an ELAP event.

1. 3.

12 3.2.1.5.8 Monitoring Instrumentation and Controls - Confirm NOT STARTED suitability of existing or replacement safety injection Environmental conditions inside containment tank (SIT) level instrumentation considering the .

following an ELAP event will be established as environmental conditions in the containment following part of the NSSS analysis that will be conducted an ELAP event. to address Open Item #1. It is expected that the current instrumentation will be qualified to continue to operate in the predicted environment.

In the event that the instruments cannot be qualified, a modification will be initiated to replace one or more with qualified instruments.

13 3.2.1.8.A Core Sub-Criticality - Confirm that the reanalysis NOT STARTED discussed in Confirmatory Item 3.2.1.1.A continues to Documentation of the validity of the boron-mixing align with the generic resolution for boron mixing under model during natural circulation conditions will be natural circulation conditions potentially involving two-provided in the NSSS timing analysis that will be phase flow, in accordance with the Pressurized-Water performed to address Open Item #1.

Reactor Owners Group position paper, dated August 15,2013 (ADAMS Accession No. ML13235A135 (nonpublic for proprietary reasons)), and subject to the conditions provided in the NRC endorsement letter dated January 8, 2014 (ADAMS Accession No. ML13276A183) following SOE and FLEX mitigation strategy impacting changes.

LlC-14-0108 Enclosure, Attachment 2 PageS Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 14 3.2.4.1.A Equipment Cooling (Water) - Confirm installed charging NOT STARTED pumps can operate during an ELAP considering the Expect completion to be documented in February loss of support equipment.

2015 Update.

15 3.2.4.2.A Equipment Cooling (Ventilation) - Confirm that the NOT STARTED licensee addresses environmental conditions in the Expect completion to be documented in August vicinity of and access to all deployed FLEX equipment 2015 Update.

in the auxiliary building, to ensure continuous equipment operation and acceptable human performance.

16 3.2.4.2.8 Equipment Cooling (Ventilation) - Confirm that the IN PROGRESS licensee addresses environmental conditions in the Expect completion to be documented in February main control room (CR) and the need for ventilation 2015 Update.

prior to re-establishing power to the CR ventilation fans using the FLEX DG at approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> after the ELAP as indicated on the SOE timeline.

17 3.2.4.2.C Equipment Cooling (Ventilation) - Confirm the NOT STARTED acceptability of the battery room temperatures (extreme Expect completion to be documented in August hot or extreme cold) on battery performance.

2015 Update.

18 3.2.4.2.D Equipment Cooling (Ventilation) - Confirm the NOT STARTED acceptability of the hydrogen buildup in the battery Expect completion to be documented in August room during charging.

2015 Update.

19 3.2.4.4.A Ughting- Confirm the lighting provisions for all areas NOT STARTED within the auxiliary building where FLEX equipment is Expect completion to be documented in August deployed as well as the outdoor areas where FLEX 2015 Update.

equipment is deployed.

LlC-14-0108 Enclosure, Attachment 2 Page 6 Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 20 3.2.4.4.8 Communications- Confirm that upgrades to the site's IN PROGRESS communications systems have been completed.

Expect completion to be documented in August 2015 U~date.

21 3.2.4.5.A Protected and Internal Locked Area Access - Confirm NOT STARTED how the provisions for access to protected areas and Expect completion to be documented in internally locked areas are incorporated into the FLEX mitigation strategies. August 2015 Update.  :

22 3.2.4.7.A Water Sources- Confirm that the licensee addresses COMPLETE ,

the impacts of water chemistry from the various onsite A water chemistry evaluation (SL-011688, sources for potential use in FLEX strategy installed and "Evaluation of Alternate Cooling Water Sources portable equipment.

for Use in Mitigating a Beyond Design Basis I

External Event") was conducted to determine the viability of existing water sources to support FLEX makeup needs regarding maintenance of heat transfer and corrosion resistance. FLEX I strategies use insights from this report to prioritize water sources and determine when and I how to utilize Regional Response Center equipment.

23 3.2.4.8.A Electrical Power Sources- Confirm the technical basis IN PROGRESS for the selection and size of the FLEX generators to be Expect completion to be documented in February used in support of, the coping strategies and the 2015 Update.

planned approach for fault protection and electrical separation between existing power sources and the FLEX power sources.

LlC-14-0108 Enclosure, Attachment 2 Page?

Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 24 3.2.4.9.A Portable Equipment Fuel - Confirm the total fuel IN PROGRESS consumption needs when FLEX equipment designs are Expect completion to be documented in February finalized.

2015 Update.

25 3.2.4.10.A Load Reduction to Conserve DC Power- Confirm if the ON HOLD non-1 E battery modification becomes a plan revision to OPPD has evaluated the ELAP capabilities of extend the battery life of the existing Class 1 E current class 1E DC batteries, along with other batteries and that any changes to the FLEX mitigation applications requiring portable generators to strategies have been incorporated.

support FLEX strategies and has concluded that restoration of power to a battery charger prior to depletion of the current batteries provides more benefits than adding a non-1 E battery to increase the depletion time on the 1E batteries. OPPD has placed this modification on hold pending the completion of the design for EC 60820, "2016 RFO Electrical Connections - FLEX." Once the successful design of the FLEX electrical distribution strategy is assured, OPPD will cancel the non-1 E battery modification.

LlC-14-0108 Enclosure, Attachment 2 Page 8 Status of Interim Staff Evaluation Open Item or Confirmatory Items Item NRC Ref. Description Status

1. # August 2014 Update 26 3.3.1.A Use of Portable Pumps- Confirm that the number of IN PROGRESS FLEX pumping equipment for accessing the UHS OPPD currently plans to install a qualified well as during the Phase 2 coping strategies meets the spare a diverse means of supplying UHS water. The (N+ 1) capability. One fire truck and two river ~rafting use of the river drafting pumps and/or the fire pumps are provided to access the UHS. Confirm truck would then become the second "qualified" whether the river drafting pumps alone can achieve the strategy for accessing the UHS. This approach mitigation strategy objectives (without the use of the.

is consistent with NEI 12-06, Section 3.2.2, which fire truck) during both the flooded and non-flooded site states, "it is also acceptable to have multiple conditions. Alternately, confirm implementation of a strategies to accomplish a function." EC 64447 qualified well as a diverse alternate source of a long is being developed to design the FLEX well. If, term water supply.

during the design process, it is determined th~t a qualified well cannot be constructed, OPPD will re-evaluate the capabilities of the existing draft pump/fire truck strategy to ensure that the N+ 1 requirement is met.

Expect completion of design documentation by August 2015 Update. Expect completio~ of well and/or and final placement of FLEX equipment for flooding response by August 2016 Update.

27 3.4.A Off-Site Resources- Confirm how conformance with IN PROGRESS NEI 12-06, Section 12.2 guidelines 2 through 10 will be Expect completion of Regional Response Center met.

"Playbook" by February 2016 Update.