RS-15-276, Report of Full Compliance with 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)

Report of Full Compliance with 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)

ML15350A414
Person / Time
Site:	Braidwood
Issue date:	12/16/2015
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-276, TAC MF0895, TAC MF0896
Download: ML15350A414 (12)

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Exelon Generation, Order No. EA-12-049 RS-15-276 December 16, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Unit 2 Facility Operating License No. NPF-77 NRC Docket No. STN 50-457

Subject:

Report of Full Compliance with 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)

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

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

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's 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 25, 2012

5. Exelon Generation Company, LLC 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 (RS-13-017)

6. Exelon Generation Company, LLC First Six-Month 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 049), dated August 28, 2013 (RS-13-113)

7. Exelon Generation Company, LLC Second Six-Month 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 049), dated February 28, 2014 (RS-14-007)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 2

8. Exelon Generation Company, LLC Third Six-Month 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 049), dated August 28, 2014 (RS-14-205)

9. Exelon Generation Company, LLC Fourth Six-Month 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 049), dated February 27, 2015 (RS-15-016)

10. Exelon Generation Company, LLC Fifth Six-Month 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 049), dated August 28, 2015 (RS-15-208)

11. NRC letter to Exelon Generation Company, LLC, Braidwood Station, Units 1 and 2 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049, (Mitigation Strategies) (TAC Nos. MF0895 and MF0896), dated December 17, 2013

12. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012

13. Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated November 26, 2014 (RS-14-320)

14. NRC letter to Exelon Generation Company, LLC, Braidwood Station, Unit Nos. 1 and 2

- 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. MF0895, MF0896), dated May 27, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed EGC 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. Specific requirements are outlined in Attachment 2 of Reference 1.

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) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Braidwood Station, Unit 2 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the 01 P. References 6, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Braidwood Station, Unit 2.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 3 The purpose of this letter is to provide the report of full compliance with the 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) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Braidwood Station, Unit 2.

Braidwood Station, Unit 2 has developed, implemented, and will maintain the 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 in response to Order EA 049. The information provided herein documents full compliance for Braidwood Station, Unit 2 with Reference 1.

OI P open items have been addressed and closed as documented in References 6, 7, 8, 9, 10, and below, and are considered complete pending NRC closure. EGC's response to the NRC Interim Staff Evaluation (ISE) open and confirmatory items identified in Reference 11 have been addressed and closed as documented in References 7, 8, 9, 10, and below, and are considered closed as documented in Reference 14. EGC's response to the NRC ISE confirmatory items identified as open in Reference 14 are addressed below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in References 10, 14, and below, and are considered complete pending NRC closure. The following tables provide completion references for each OIP open item and NRC ISE open or confirmatory item, and NRC Audit Report open item.

Overall Integrated Plan Open Items OIP Open Item Completion

Response

Reference Key Site assumptions (p.4)

Primary and secondary storage Reference 10 locations have not been selected yet; once locations are finalized implementation strategies and routes will be assessed for hazard impact.

Sequence of events (p.5)

The final timeline will be time validated Reference 10 once detailed designs are completed and updated and procedures are developed.

with this submittal as provided below Identify how strategies will be Identification of storage area and Reference 10 deployed

.7 creation of the administrative program.

Programmatic controls (p.8)

Develop an administrative program for Reference 10 FLEX responsibilities, and testing &

maintenance.

National SAFER Response Center Development of Braidwood Station's Reference 10 plan

.9 la book.

Key Reactor Parameters Identify additional parameters that are Reference 8

. multiple) needed in order to support key actions

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 4 OIP Open Item Completion

Response

Reference Key Site assumptions (p.4)

Primary and secondary storage Reference 10 locations have not been selected yet; once locations are finalized implementation strategies and routes will be assessed for hazard impact.

identified in the plant procedures/guidance or to indicate imminent or actual core damage.

Deployment Conceptual Design Develop the storage structure Reference 9 (p. multiple) conceptual design.

Maintain RCS Inventory Control, A calculation will be required for the Reference 10 Phase 2 (p.23) timing of the boration and quantity and updated required.

with this submittal as provided below Maintain Containment, Phase 1 Additional calculations will be Reference 10 (p.31) performed to evaluate containment response.

Maintain Spent Fuel Pool Cooling, Procedure development for Initial Reference 8 Phase 1 (p.39)

Spent fuel pool make-up with gravity drain from the RWST.

Maintain Spent Fuel Pool Cooling, Initial calculations were used to Reference 8 Phase 1 (p.39) determine the fuel pool timelines.

Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.

Maintain Spent Fuel Pool Cooling, Evaluation of the spent fuel pool area Reference 8 Phase 1, (p.39 and p.42) for steam and condensation will be performed and used to determine if vent path strategy is needed.

Safety Functions Support, Phase Habitability conditions will be Reference 8 2 (p.51) evaluated and a strategy will be developed to maintain Main Control Room.

Safety Functions Support, Phase Critical ventilation assets may be Reference 9 2 (p.51) required to support DDAF pumps, station battery rooms, miscellaneous electric equipment rooms, and fuel handling building personnel habitability and/or component survivability. Specific analyses of these rooms will be performed.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 5 Interim Staff Evaluation Open Items ISE Open Item Completion Response Reference Item No. 3.2.1.8.A Reference 10 and updated with this submittal as provided below Interim Staff Evaluation Confirmatory Items ISE Confirmatory Item Completion Response Reference Item No. 3.1.1.1.A Reference 10 Item No. 3.1.1.3.A Reference 9 Item No. 3.1.1AA Reference 10 Item No. 3.1.5.1.A Reference 9 Item No. 3.1.5.3.A Reference 9 Item No. 3.2.1.A Reference 10 Item No. 3.2.1.1.A Reference 10 Item No. 3.2.1.1.13 Reference 9 Item No. 3.2.1.1.0 Reference 9 Item No. 3.2.1.1.D Reference 9 Item No. 3.2.1.2.13 Reference 10 and updated with this submittal as provided below Item No. 3.2.1.2.E Reference 10 Item No. 3.2.1.3.A Reference 10 Item No. 3.2.1AA Reference 10 Item No. 3.2.1.4.13 Reference 9 Item No. 3.2.1.5.A Reference 8 Item No. 3.2.1.6.A Reference 10 and updated with this submittal as provided below Item No. 3.2.1.6.13 Reference 9 Item No. 3.2.1.9.A Reference 9 Item No. 3.2.2.A Reference 9 Item No. 3.2.3.A Reference 10 Item No. 3.2.3.13 Reference 10 Item No. 3.2.4.1.A Reference 9 Item No. 3.2.4.2.A Reference 9 Item No. 3.2.4.2.13 Reference 9 Item No. 3.2.4.3.A Reference 9 Item No. 3.2.4.4.A Reference 10 Item No. 3.2.4.6.A Reference 8 Item No. 3.2.4.7.A Reference 10 and updated with this submittal as provided below Item No. 3.2.4.8.A Reference 9 Item No. 3.2.4.9.A Reference 10 Item No. 3.2.4.10.A Reference 9

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 6 NRC Audit Report Open Items Audit Open Item Completion Response Reference SE#9 Reference 10 SE # 10 1

Reference 10 1

1 The following table documents completion of the final remaining open items. As previously stated, EGC provides the response for the following items and considers them to be complete for Braidwood Station, Unit 2.

Item Description Reference 01113 Open Item The site FLEX procedures have been developed and validated consistent with Sequence of events (pg. 5) the NEI FLEX validation process. The Complete The final timeline will be time results have been compared to the site validated once detailed designs Phase 2 staffing study. The comparison are completed and procedures confirmed that site existing emergency are developed.

response resources are sufficient to perform the required plant actions and implement the multi-unit event response strategies.

OIP Open Item Westinghouse Calculation CN-LIS-15-034, Complete Byron and Braidwood Stations Reactor Maintain RCS Inventory Control, Coolant System ELAP Inventory Control Phase 2 (p. 23)

Analysis with SHIELD Reactor Coolant Pump Seal Packages, is complete and A calculation will be required for provides a minimum time of 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> to the timing of the boration and the end of single-phase natural circulation quantity required.

and 186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br /> until Core Uncovery occurs.

Westinghouse Calculation CN-LIS-15-039, Byron and Braidwood Stations Reactor Coolant System ELAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages, provides a bounding calculation that determines boration would start by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> into the ELAP with a minimum of 6000 gallons of 2300ppm borated water injected.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 7 ISE 013.2.1.8.A Braidwood will abide by the position expressed by the Nuclear Regulatory Core Subcriticality-The NRC Commission (NRC) staff in the letter dated staff has not endorsed the January 8, 2014 regarding the boron industry-proposed position mixing issue for Pressurized Water paper regarding boron mixing.

Reactors (PWRs). The NRC letter states The licensee has indicated that that the NRC staff has reviewed the Braidwood is planning on information submitted to date and following this methodology.

concluded that use of the industry Thus, further resolution of this approach dated August 15, 2013, entitled issue will be necessary in the

'Westinghouse Response to NRC Generic next phase of the audit process.

Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)," Agency wide Documents Access and Management System (ADAMS) Accession Number ML13235A135, (being withheld from public disclosure for proprietary reasons) is acceptable with clarifications listed in the letter.

The analysis demonstrates that the Flexible and Diverse Coping Strategies (FLEX) Reactor Coolant System (RCS) make-up pump is capable of meeting an injection time line to ensure adequate sub-criticality for both the maximum seal leakage and no seal leakage scenarios including the appropriate time delay margin. Calculation CN-LIS-1 5-39 was completed on September 14, 2015 to ensure the site Fukushima strategy remains viable.

Calculation CN-LIS-1 5-34 has extended the RCS inventory loss of single phase natural circulation to 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br />.

The Braidwood Overall Integrated Plan (OIP) Attachment 1 A, Action Item 15 shows that the high pressure FLEX pumps are available between 11 and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> following the Beyond-Design -Basis External Event (BDBEE) which meets the timing requirements. Therefore, the boron mixing criteria are met.

Complete

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 8 ISE CI 3.2.11.2.13 Braidwood Station has installed the Westinghouse reactor coolant pump Reactor Coolant Pump (RCP)

(RCP) SHIELD Passive Thermal Seal Leakage - In some plant Shutdown Seals (SDS) (Generation 111).

designs, the cold legs could The SHIELD SDSs have been installed in experience temperatures as all 4 RCPs on Unit 2 during A2R18 and high as 580 OF before cooldown will be installed on Unit 1 in the fall of 2016 commences. This is beyond the during Al R19.

qualification temperature The qualification testing of the shutdown (550°F) of the O-rings used in seal was performed at conditions based the RCP seals. For those on a cold leg temperature of 571 OF. The Westinghouse designs, a maximum shutdown seal temperature discussion should be provided remains below the shutdown seal to justify that (1) the integrity of temperatures experienced during the associated O-rings will be qualification testing.

maintained at the temperature conditions experienced during Following a loss of AC power, it is possible the ELAP event, and (2) the seal for the RCS cold leg temperature to leakage rate of 21 gpm/seal exceed 571 OF for short periods of time used in the ELAP is adequate without the shutdown seal heating up and acceptable.

beyond the temperatures experienced during qualification testing. This is due to the significant thermal inertia of the massive reactor coolant pump internals and pressure boundary. The evaluation documented in Westinghouse Letter LTR-CDA-15-11 concludes that even if the cold leg temperature is 581 OF for the first 3000 seconds (50 minutes) following ELAP initiation, the maximum fluid temperature at the reactor coolant pump seal inlet remains below the temperatures experienced during shutdown seal qualification testing. Auxiliary Feedwater flow to the steam generators will be initiated at approximately 30 minutes into the ELAP event. Following the restoration of Auxiliary Feedwater flow to the steam generators and prior to initiating plant cooldown, cold leg temperature will be dictated by the Main Steam Safety Valves. Cold leg temperature will remain less than 571 OF during this period based on the lowest Main Steam Safety Valve setting of 1175 psig adjusted for setting tolerance and lift setpoint testing uncertainty.

Westinghouse LTR-RES-13-153 Complete

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 9 Documentation of 7228C Compound 0-Rings at FLAP Conditions, concludes with a high level of confidence, that the integrity of the RCS O-rings will be maintained at the temperature conditions experienced during the ELAP event.

ISE CI 3.2.1.6.A There was one change based on the Complete Westinghouse calculation CN-LIS-15-40, Sequence of Events - Confirm Byron and Braidwood Stations Delayed that the final timeline has been AFW FLEX Studies, which resulted in less time validated after detailed time to SG dry out. The time to isolate the designs are completed and SG PORVs and to start the "B" AF Pump procedures are developed. The was shortened. Braidwood Procedure results may be provided in a steps and directions have been updated.

future 6-month update.

This change was revalidated and updated in the Time Sensitive Actions Procedure.

The timeline was updated using the times documented in the Westinghouse calculations.

The revised timeline, previously provided in Attachment A of the 6-month updates, has been validated and the changes required do not impact the time or margins documented for Braidwood Station Unit 2.

ISE CI 3.2.4.7.A Complete Westinghouse Calculation CN-LIS-15-40, Water Sources - Justify the time Byron and Braidwood Stations Delayed at which SG dryout will occur.

AFW FLEX Studies, provided bounding information that the shorest time to SG dry out would be 2702 seconds, or 45 minutes on Unit 2 and 3777 seconds, or 63 minutes on Unit 1.

MILESTONE SCHEDULE ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Contract with National SAFER Response Center April 30, 2015 Submit 6 Month Updates:

Update 1 1

August 28, 2013

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 10 Milestone Completion Date Update 2 February 28, 2014 Update 3 August 28, 2014 Update 4 February 27, 2015 Update 5 August 28, 2015 Modification Development:

Phases 1 and 2 modifications October 16, 2015 National SAFER Response Center Operational September 11, 2014 Procedure Development:

Strategy procedures October 16, 2015 Validate Procedures (NEI 12-06, Sect. 11.4.3)

October 16, 2015 Maintenance procedures October 16, 2015 Staffing analysis May 29, 2014 Modification Implementation Phases 1 and 2 modifications October 16, 2015 Storage plan and construction April 16, 2015 FLEX equipment acquisition April 16, 2015 Training completion April 16, 2015 Unit 2 implementation date October 22, 2015 ORDER EA-1 2-049 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Braidwood Station, Unit 2 as well as the site OIP response submittal (Reference 5), the 6-Month Status Reports (References 6, 7, 8, 9, and 10), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies - Complete Braidwood Station, Unit 2 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items.

The Braidwood Station, Units 1 and 2, Final Integrated Plan for mitigating strategies will be provided upon full compliance for Braidwood Station, Unit 1 (Fall 2016).

Modifications - Complete The modifications required to support the FLEX strategies for Braidwood Station, Unit 2 have been fully implemented in accordance with the station design control process.

Equipment Procured and Maintenance & Testing Complete The equipment required to implement the FLEX strategies for Braidwood Station, Unit 2 has been procured in accordance with NEI 12-06, Sections 11.1 and 11.2, received at Braidwood Station, Unit 2, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 11 Maintenance and testing will be conducted through the use of the Braidwood Station, Unit 2 Preventative Maintenance program such that equipment reliability is achieved.

Protected Storage Complete The storage facilities required to implement the FLEX strategies for Braidwood Station, Unit 2 have been completed and provide protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Braidwood Station, Unit 2 is stored in its protected configuration.

Procedures Complete FLEX Support Guidelines (FSGs) for Braidwood Station, Unit 2 have been developed and integrated with existing procedures. The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

Training Complete Training for Braidwood Station, Unit 2 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

Staffing Complete The Phase 2 staffing study for Braidwood Station has been completed in accordance with 1 OCFR50.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 12), as documented in Reference 13.

National SAFER Response Center Complete EGC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PE[Co is ready to support Braidwood Station, Unit 2 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation Complete EGC has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) for Order EA-12-049.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 December 16, 2015 Page 12 FLEX Program Document - Complete The Braidwood Station, Unit 2 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of December 2015.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Braidwood Station NRC Project Manager, NRR Braidwood Station Mr. John D. Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety