RS-14-209, 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-12-049)

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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-12-049)
ML14248A239
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 08/28/2014
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-14-209
Download: ML14248A239 (47)


Text

IRONY

/Mr Admir' ExelonGeneration Order No. EA-12-049 RS-14-209 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

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-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-13-021)
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-13-121)
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-14-011)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page 2

8. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF1121 and MF1122), dated February 21, 2014 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs 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 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 pursuant to Section IV, Condition C. Reference 2 endorses 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 LaSalle County Station, Units 1 and 2 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station.

The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 8.

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 28th day of August 2014.

Respectfully submitted,

/

Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. LaSalle County Station, Units 1 and 2 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector LaSalle County Station, Units 1 and 2 NRC Project Manager, NRR LaSalle County Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. John P. Boska, NRR/DPR/MSD/MSPB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 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 (43 pages)

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Enclosure LaSalle County Station, Units 1 and 2 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 LaSalle County Station, Units 1 and 2 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 The second 6 Month Update was submitted in February 2014.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It 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.

Target Revised Target Activity Activity Status Completion Date Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Contract with National SAFER Response Complete Center Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Complete with Update 3 Aug 2014 this submittal.

Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started May 2018 See Section 5 of Submit Completion Report Sep 2017 Not Started this enclosure Page 1 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Target Revised Target Activity Activity Status Completion Date Completion Date Modification Development &

Implementation:

Unit 1 Modification Development (All Jan 2015 Started FLEX Phases)

Unit 1 Modification Implementation (All Mar 2016 Not Started FLEX Phases)

Unit 2 Modification Development (All Jan 2014 Started Oct 2014 FLEX Phases)

Unit 2 Modification Implementation (All Feb 2015 Not Started FLEX Phases)

Procedures:

Create Site-Specific Procedures Feb 2015 Started Validate Procedures (NET 12-06, Sect.

Feb 2015 Not Started 11.4.3)

Create Maintenance Procedures Feb 2015 Started Perform Staffing Analysis Oct 2014 Started Storage Plan and Construction Feb 2015 Started FLEX Equipment Acquisition Feb 2015 Started Training Completion Feb 2015 Started National SAFER Response Center Started Dec 2014 Operational Mar 2018 Unit 1 FLEX Implementation Mar 2016 Started See Section 5 of this enclosure Feb 2017 Unit 2 FLEX Implementation Feb 2015 Started See Section 5 of this enclosure Mar 2018 Full Site FLEX Implementation Mar 2016 Started See Section 5 of this enclosure Page 2 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 4 Changes to Compliance Method Several changes to the compliance method have been made since the February 2014 update (Ref. 7).

An update call was held with members of the Nuclear Regulatory Commission on April 4, 2014, to review the current design concepts. During detailed design activities occurring since the FLEX February 2014 6-Month Update Report, several changes were made to the compliance method. The changes were discussed during the April 4, 2014 update call. Attachments 1 and 2 to this update report depict the current water and electrical supply strategies.

The change to the water supply strategy involves the elimination of the pre-staged 480 VAC FLEX pumps in the Division 2 core standby cooling system (CSCS) pump room on each unit. The revised strategy consists of an appropriately sized portable diesel-driven pump (PDDP) located at the ultimate heat sink (UHS) that provides water for both units. Two (2) FLEX PDDP's will be procured to meet the 'N+1' equipment requirements of NEI 12-06. This PDDP will either be connected to the Division 2 Fuel Pool Cooling Emergency Makeup (FC EMU) piping (Primary connection point) or to the Division 1 FC EMU piping (Alternate connection point) on each unit. The available flow paths for both connection points are depicted on Attachment 1 and include the capability to provide flow to the reactor pressure vessel, spent fuel pool and the suppression pool. This strategy change was made as a result of the detailed design work related to pre-staging the 480 VAC FLEX pumps.

The change to the electrical supply strategy involves the elimination of the power supply need for the pre-staged 480 VAC FLEX pumps. Additionally, receptacles are shown on Attachment 2 for the spare 125VDC chargers. These receptacles are being installed to provide the capability of directly powering these chargers via the Alternate electrical supply connection strategy.

Note that Attachments 1 and 2 depict the water and electrical supply strategies for Unit 1. The strategies are the same for Unit 2.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter dated February 27, 2014 (Ref. 3), LaSalle County Station requested relaxation from certain schedule requirements of Order EA-12-049 (Ref. 2) related to installation of the severe accident capable containment vent required by Order EA-13-109 (Ref. 6). The NRC granted that schedule relief via letter dated April 15, 2014 (Ref. 4).

No additional need for relief/relaxation relative to Order EA-12-049 has been identified at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Staff Evaluation (ISE) (Ref. 5) and the status of each item.

Section Reference Overall Integrated Plan Open Item Status I

Sequence of Events (p.5) The times to complete actions in the NOT STARTED Events Timeline are based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and Page 3 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Section Reference Overall Integrated Plan Open Item Status procedures developed.

Sequence of Events (p.10) Initial evaluations were used to COMPLETED.

determine the fuel pool timelines. Determined that the initial Formal calculations will be performed to evaluations that were validate this information during performed are sufficient.

development of the spent fuel pool cooling strategy detailed design.

Sequence of Events (p.10) Analysis of deviations between Exelon's COMPLETED engineering analyses and the analyses Reference 8 contains the contained in BWROG Document analysis.

NEDC-33771P, "GEH Evaluation of FLEX Implementation Guidelines and documentation of results on Att. 1B, "NSSS Significant Reference Analysis Deviation Table." Planned to be completed and submitted with August 2013 Six Month Update.

Strategy Deployment (p.11) Transportation routes will be developed STARTED from the equipment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation.

Identification of storage areas and creation of the administrative program are open items.

Programmatic Controls (p.12) An administrative program for FLEX to STARTED establish responsibilities, and testing &

maintenance requirements will be implemented.

Core Cooling Phase 1 (p.17) Additional work will be performed STARTED during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

Fuel Pool Cooling Phase 1 (p.35) Complete an evaluation of the spent fuel STARTED pool area for steam and condensation.

Safety Functions Support Phase 1 Evaluate the habitability conditions for STARTED. LaSalle will the Main Control Room and develop a be applying the "toolbox" Page 4 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Section Reference Overall Integrated Plan Open Item Status (p.44) strategy to maintain habitability, approach for habitability.

Safety Functions Support Phase 1 Evaluate the habitability conditions for STARTED (p.44) the Auxiliary Electric Equipment Room (AEER) and develop a strategy to maintain habitability.

Safety Functions Support Phase 2 Develop a procedure to prop open STARTED (p.48) battery room doors upon energizing the battery chargers to prevent a buildup of hydrogen in the battery rooms.

Page 5 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Open and Confirmatory Items 0 'en Items Item Number Description Status 3.2.3.A Verify the modifications associated with Order EA 13- The modifications 109 on a Hardened Containment Vent System support associated with Order EA the sequence of events and actions associated with the 13-109 are scheduled to LSCS mitigating strategies. complete installation at LSCS in 2017 (Unit 2) and 2018 (Unit 1). The modifications will be designed to support the LSCS mitigating strategies.

STARTED Confirmatory Items Item Number Description Status 3.1.1.2.A Confirm that soil liquefaction will not prevent STARTED movement of equipment along transportation paths.

3.1.1.2.B Confirm that the egress path for personnel to reach the STARTED FLEX storage building is seismically robust, or multiple egress paths that are not seismically robust are identified.

3.1.1.4.A Confirm that the logistics for equipment transportation, STARTED area set up, and other needs for ensuring the equipment and commodities to sustain the site's coping strategies are available from offsite resources.

3.1.3.1.A If the licensee credits separation of storage sites to LaSalle Station is NOT address tornado threats, confirm that the axis of crediting separation of separation and distance between storage locations will storage sites to address provide assurance that a single tornado would not tornado threats.

impact all locations if the licensee relies on NEI 12-06, Section 7.3.1, configurations 1.b or 1.c for protection of the portable equipment from the high winds hazard.

3.2.1.1.A Confirm that benchmarks are identified and discussed COMPLETE.

that demonstrate that the Modular Accident Analysis See Attachment 5.

Program (MAAP) is an appropriate code for the simulation of an ELAP event at LSCS.

3.2.1.1.B Confirm that the collapsed level remains above Top of COMPLETE.

Active Fuel (TAF) and the cool down rate remains See Attachment 5.

within technical specification limits for MAAP analyses.

Page 6 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Open and Confirmatory Items 3.2.1.1.0 Confirm that MAAP is used in accordance with COMPLETE.

Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 See Attachment 5.

position paper (ADAMS Accession No. ML13190A201).

3.2.1.1.D Confirm that the licensee identifies and justifies the COMPLETE.

subset of key modeling parameters cited from Tables See Attachment 5.

4-1 through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1020236). This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant.

3.2.1.1.E Confirm that the specific MAAP analysis case that was COMPLETE.

used to validate the timing of mitigating strategies in See Attachment 5.

the Integrated Plan is identified and is appropriate for LSCS. Alternately, a comparable level of information may be included in the supplemental response.

3.2.1.2.A Confirm adequacy of the technical basis for the COMPLETE.

assumptions made regarding the leakage rate through See Attachment 5.

the recirculation pump seals and other sources. The analysis should include the assumed pressure-dependence of the leakage rate, and whether the leakage was determined or assumed to be single-phase liquid, two-phase mixture, or steam at the donor cell, and how mixing the leakage flow with the drywell atmosphere is modeled.

3.2.1.3.A Confirm that taking readings from a standpipe which is COMPLETE.

not safety related or seismic does not make the CST With a potential loss of level instrumentation inadequate for the automatic the CST Standpipe, which swap or informing the operators of CST loss so that is located inside of the they may respond with manual action using the control Turbine Building, the switches located in the main control room.

water would no longer be present to indicate high level; therefore, because the level instruments are seismically qualified, they will remain adequate to support the automatic suction source swap.

3.2.1.4.A Confirm that pump sizing results consider required STARTED water flow rates, the portable/FLEX pump complete Page 7 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Interim Staff Evaluation Open and Confirmatory Items I

head/flow characteristics, suction and discharge losses, system backpressure, elevation differences and piping losses to allow verification that this will be a successful strategy.

3.2.1.4.B Confirm the generator sizing results consider STARTED appropriate electrical loads and adequate capacity of portable/FLEX electrical generators planned for use during Phase 2 and Phase 3.

3.2.2.A Confirm completion of the evaluation of the SFP area STARTED for steam and condensation and implementation of a vent path strategy, if needed.

3.2.4.1.A Confirm that operation of RCIC with suction STARTED temperatures above 200°F is acceptable.

3.2.4.2.A Confirm that the licensee provides acceptable hydrogen STARTED gas ventilation.

3.2.4.4.A Confirm that the upgrades to the plant communication STARTED systems discussed in the licensee communications assessment (ADAMS Accession Nos. ML12306A199 and ML13056A135) in response to the March 12, 2012 50.54(f) request for information letter for Limerick (sic) and, as documented in the staff analysis (ADAMS Accession No. ML13114A067) have been completed.

3.2.4.6.A Confirm that the proceduralized "toolbox" approach STARTED can ensure vital area habitability and confirm the proper staging and protection of any equipment to implement this approach.

3.2.4.7.A Confirm that the design of the FLEX pump suctions STARTED will prevent introducing excessive amounts of entrained debris as a result of extreme external hazards (e.g., suspended solids especially from high wind debris) in the cooling water from the Lake Screen House/Lake.

3.2.4.10.A Confirm that the high/low temperature analysis (i.e., STARTED temperatures above/below those currently assumed in the sizing calculations) shows no adverse effects on expected battery life.

3.4.A Confirm conformance to considerations 2 through 10 STARTED of NE! 12-06, Section 12.2 for the use of offsite resources or that an acceptable alternate is developed.

Page 8 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 7 Potential Draft Safety Evaluation Impacts The FLEX strategy changes described in this update have the potential to impact the DRAFT Safety Evaluation.

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

1. LaSalle County Station'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 (ADAMS Accession No. ML13060A421).
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.
3. Exelon/LaSalle Request for Relaxation from NRC Order EA-12-049, dated February 27, 2014 (ADAMS Accession No. ML14059A076).
4. NRC Approval of Exelon/LaSalle Request for Relaxation from NRC Order EA-12-049, dated April 15, 2014 (ADAMS Accession No. ML14071A455).
5. LaSalle County Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies), dated February 21, 2014 (ADAMS Accession No. ML14030A220(package)).
6. NRC Order Number EA-13-109, "Order Modifying Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013
7. LaSalle County Station, Units 1 and 2 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-12-049), dated February 28, 2014 (ADAMS Accession No. ML14059A431)
8. LaSalle County Station, Units 1 and 2, 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-12-049), dated August 28, 2013 (ADAMS Accession No. ML13241A283) 9 Attachments
1. FLEX Water Supply Diagram
2. FLEX Electrical Supply Diagram
3. Portable Equipment Phase 2
4. Portable Equipment Phase 3
5. LaSalle Evaluation LS-MISC-025, Rev. 1, "Use of MAAP in Support of FLEX Implementation" Page 9 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 1 LA SALLE WATER SUPPLY STRATEGY (AUGUST 2014)

-- FUEL POOL PRIMARY CONNECTION POINT EMERGENCY f EMERGENCY ALTERNATE CONNECTION POINT (DIV 2 FT EMU PIPING) HOSE (SPRAY orr !WRAY OR FILL MAJ 1405E MTV. 1 FE ENS PIP,NG)

FC050B CONNECTION CARA FUEL POOL -1 CAPABILITY) CONNECTION FCOSCA 04 BTOMOB 9>1 (FILL 0.141.11 T HOSE CONNECTION t TO W RHR

  • FCC-.TA FLEX PUMP (PORTABLE DIESEL UNIT-2 04 F340 IHI FC (FUEL POOL I 144 COOLING AS,IS ) (ALTERNATE CONNECTION)

DRIVEN PUMP)

/* v HOSE CONNECTION

\ FROAI ALTERNATE SOURCE 04 04 j_

(PRIMARY CONNECTION) jI UHS SAKE)

DW5PRXY Ii ii FOND EDITS I ' OW VRAY A HEADER F0175 RIBA REACTOR LPCI I/

CS I, :4 g LPCI W SPIJTOOXSN COOlING RETURNS

)'4 F0530

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\ FOS3A SHUTCOMIN COOLING RETURN W

/

176' II

, POZZ RC1C 0241 EOM

<-'->Cr CONDENSATE STORAGE RR "EF RR N, TANK UPPRESSION CHAMBER SPRAY HEAVER 000 00 000 0 00 0 0 0 0 00 SUPPRESSION POOL 1

FMB 01 T 110 1 11 0 LL Page 10 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 2 LA SALLE ELECTRICAL STRATEGY (AUGUST 2014)

--I- -148;4"' "Ns a eKaa y (EP *I ANNE)

TO UNIT TO UNIT 2 SWGR 2410 SWGR 2420' GO DIG TO WIT 2 SWOR2MY 0140 0005 000 4100V SWOR 41620 SWGR 1470 41110.604 AIMMISOV 4160340Y

""Tmminv 100260/A rii TiU.NS 118Y 1004404 r-T 1 I/ r conovAl TRANS 1360 L tJ non ,say 1 L'f j 670140 1 401285000 lMX ANN MYER 12210 Lt 0 0 6 (31./e-SUMMI

  • Tr PM VALVES
  • My. 2 DO FL/EL TR/WM.1,M13 (SUB-BUSESI
  • W RH. VALVES
  • IS REACTOR /MORO. LOOP
  • REACTOR PECIRC LOOP 401. VALVES MOUTON VALVES
  • COMMON DG NIEL TRANSFER AUX BLDG NIONAC MCC I300(4 0 AUX BLOC ANNAC 000 12504 0 0 RECEPTACLE ROB ALTERNATE poweR SUPPLY RECEPTACLE KR INSTRIBUTTO ALTERNATE POWER PANEL ALTERNATE CONNECTION POINT

$000 4024840 FLEX GENERATOR gi 012300 1251/

BATTERY BATT 11k 0 12, Ul-121

-,/

2SOVDC 126400 (ASTMS. 111y BATT 16 0 6 666 0 125VOC DIST 11121. 1 Tgtil1411 COM WINCE NIX INSTRUMENTATION 8110 00$ TO 2 v.

810 200 TO UNIT 2 ROC ADS 125VDC DIST PK 212Y Page 11 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 3 LaSalle Portable Equipment Phase 2 Use and (potential / flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Two (2) Hale X X X Nominal 4,000 gpm Equipment maintenance IP4000DIM- main pump at 150 psig. and testing will be TCL portable Hydraulic booster performed in accordance diesel driven pumps nominal 2,000 with the industry pumps with gpm. templates, as outlined in two (2) JLD-ISG-2012-01 section hydraulic 6 and NET 12-06 section submersible 11.

booster pumps Three (3) 480 X X X X X 500kW Equipment maintenance VAC Portable and testing will be Diesel Driven performed in accordance Generators with the industry templates, as outlined in JLD-ISG-2012 -01 section 6 and NEI 12-06 section 11.

Two (2) X X X X X '2N' sets of cable Equipment maintenance tandem axle located on one trailer in and testing will be cable trailers protected FLEX performed in accordance with cable building. `+1' set of with the industry reels cable located on one templates, as outlined in trailer in commercial JLD-ISG-2012-01 section FLEX building. 6 and NET 12-06 section 11.

Page 12 o143

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Three (3) X X X Capable of hauling hoses, Equipment maintenance Tandem Axle fittings, and tools and testing will be Hose Trailers performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NE! 12-06 section 11.

Ford F750 X X X X Tow vehicle, portable Equipment maintenance Truck w/snow equipment refueling and testing will be plow and two vehicle, and debris performed in accordance (2) 118 gal removal vehicle with the industry diesel fuel templates, as outlined in tanks with JLD-ISG-2012-01 section pump and 6 and NEI 12-06 section dispensing 11.

equpment Six (6) 5.5 kW X 5.5 kW, 120/240VAC Equipment maintenance portable diesel and testing will be generators performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NE! 12-06 section 11.

Page 13 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Ten (10) X X 115 VAC, 5,000 SCFM Equipment maintenance portable fans and testing will be with ducting performed in accordance (Support RCIC with the industry and other room templates, as outlined in cooling) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Two (2) X 250 gpm Equipment maintenance Oscillating and testing will be Spray Fire performed in accordance Monitors with the industry (Support SFP templates, as outlined in Spray) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Miscellaneous X X X Various Equipment maintenance fire hose and and testing will be fittings performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Pale 14 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Miscellaneous X X X X X Various Equipment maintenance Electrical and testing will be Cable and performed in accordance Connectors with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

12 "spider" X X X X X Provide AC power for Equipment maintenance boxes to portable fans, lighting, etc. and testing will be distribute performed in accordance electrical with the industry power templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Portable X AC powered Equipment maintenance Inflatable and testing will be Tower performed in accordance Lighting (Ten with the industry 10' units, Four templates, as outlined in 14' units) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Page 15 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements 6 large area X AC. 13,300 cfm. Equipment maintenance fans and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Portable X AC/DC, variable speed, Equipment maintenance battery 5,000 to 15,000 cfm and testing will be operated fans performed in accordance (5) with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Hydraulic Max 236,250 psf lbf, 6 hp Equipment maintenance "rescue" diesel engine and testing will be cutters (1) performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Page 16 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Petformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Hydraulic 14 inch, 10 hp diesel Equipment maintenance circular saw engine and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Miscellaneous X Coveralls, gloves, hoods N/A cold weather gear Sleeping bags X N/A and cots Cooling vests X To support "toolbox" N/A and spare approach for area cooling packs habitability Porta-potties X N/A (4)

Portable (AC) X X X X X Equipment maintenance fuel transfer and testing will be pump and performed in accordance hoses with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Page 17 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 2 Use and (potential /flexibility,) diverse uses Petformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Three (3) X X X X X Move large trailers in/out Equipment maintenance battery- of FLEX storage buildings and testing will be powered trailer performed in accordance movers with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Sound- X X X X X Headsets, extra cable N/A powered phone sections equipment Handheld X X X X X Additional radios for use N/A radios in talk-around mode, batteries, chargers Page 18 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 4 BWR Portable Equipment Phase 3 (Generic Equipment)

Note: The equipment listed is the generic equipment list provided by the National SAFER Response Center and even though LaSalle does not require this equipment in our FLEX strategies, this equipment will be available from the National SAFER Response Center and could be utilized in the Phase 3 time period. (Based on AREVA "Regional Response Center Equipment Technical Requirements" document 51-9199717-007.)

Use and (potential /flexibility) diverse uses PerPrmance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Medium X X X X X 1 MW output at 4160 Voltage Diesel Vac, three phase Note1 Generator Low Voltage X X X X X 1100 kW output at 480 Diesel Vac, three phase Note 2 Generator High Pressure X 2000 psi shutoff head, 60 Injection Pump gpm capacity SG/RPV X 500 psi / 500 gpm Makeup Pump Low Pressure / X X X 300 psi shutoff head, Medium Flow 2500 gpm max flow Pump Low Pressure / X X X 150 psi shutoff head, High Flow 5000 gpm max flow Pump Cable / X X X X Various as determined by Electrical AREVA document # 51 -

Page 19 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 BWR Portable Equipment Phase 3 (Generic Equipment)

Note: The equipment listed is the generic equipment list provided by the National SAFER Response Center and even though LaSalle does not require this equipment in our FLEX strategies, this equipment will be available from the National SAFER Response Center and could be utilized in the Phase 3 time period. (Based on AREVA "Regional Response Center Equipment Technical Requirements" document 51-9199717-007.}

Use and (potential /flexibility) diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment 9199717 - 007 Hose / X X X Various as determined by Mechanical AREVA document # 51 -

Connections 9199717 - 007 Lighting X 40,000 lumens Towers (3/unit)

Diesel Fuel 500 gallon air-lift Transfer container Diesel Fuel 264 gallon tank, with Transfer Tank mounted AC/DC pumps Portable Fuel 60 gpm after filtration Transfer Pump Electrical 4160 V, 250 MVA, Distribution 1200 A System Note 1: 1 MW is the individual generator output, and 2 MW is the total standard output to be supplied by the Phase 3 MV generators to satisfy identified load demands. The total output is created by connection of several smaller generators in parallel. Loads in excess of 2 MW are planned to be addressed as additional generators classified as non-generic equipment (see Section 8.4).

Note 2: The 1100 kW unit is derated to 1000 kW.

Page 20 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 LaSalle Portable Equipment Phase 3 (Non-Generic Equipment)

Use and (potential / flexibility) diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment 2500/5000 X X X The Suction Booster Lift Exelon/LaSalle is currently GPM Pump will assist in pursuing participation in Suction providing 26 feet of this equipment group.

Booster suction lift to the Low Lift Pressure Medium Flow Pumps Pumps and the Low Pressure High Flow Pumps.

Pacre 21 o143

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment These types of equipment will be requested from site to site and utility to utility on an as required basis.

  • Survey instruments
  • Dosimetry
  • Off-site monitoring/sampling Commodities These types of commodities will be requested from site to site and utility to utility on an as
  • Food required basis.
  • Potable water Page 22 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Attachment 5 Copy of LS-MISC-025 Rev. 1 (20 pages including cover page)

Page 23 of 43

LaSalle County Station, Units I and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 RM DOCUMENTATION NO. LS-MISC-025 REV: 1 PAGE NO. 1 STATION: LaSalle UNIT(S) AFFECTED: Units 1 and 2 TITLE: Use of MAAP in Support of FLEX Implementation

SUMMARY

(Include UREs incorporated):

MAAP 4.0.5 calculations (LS-MISC-017-R1) were performed to estimate the containment pressure and temperature response to a variety of extended Station Blackout (SBO) events. The NRC has requested that some additional information be provided relating to the use of MAAP for FLEX analysis as part of the periodic update to the plants response to EA-12-049. The attached information is being provided to include in the next update to EA-12-049. Revision 1 includes discussion to provide additional details regarding the NRC's information request.

[ ] Review required after periodic Update

[ X ] Internal RM Documentation [ ] External RM Documentation Electronic Calculation Data Files: N/A Method of Review: [ X ] Detailed [ ] Alternate [ ] Review of External Document This RM documentation supersedes: Rev. 0 in its entirety.

0 Prepared by: Alex H. Duvall Print

/

Sign all/W/ 1124N Date Reviewed by: Gary W. Hayner / A4ALL4 AI / 7/u 4-Print Sign Dare Approved by: Edward T. Bums / o ...--. / 7 /z2//<('

Print Sign Date Page 24 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 RM DOCUMENTATION NO. LS-MISC-025 REV: 1 PAGE NO. 1 STATION: LaSalle UNIT(S) AFFECTED: Units 1 and 2 TITLE: Use of MAAP in Support of FLEX Implementation

SUMMARY

(Include UREs incorporated):

MAAP 4.0.5 calculations (LS-MISC-017-R1) were performed to estimate the containment pressure and temperature response to a variety of extended Station Blackout (SBO) events. The NRC has requested that some additional information be provided relating to the use of MAAP for FLEX analysis as part of the periodic update to the plants response to EA-12-049. The attached information is being provided to include in the next update to EA-12-049. Revision 1 includes discussion to provide additional details regarding the NRC's information request.

[ ] Review required after periodic Update

[ X ] Internal RM Documentation [ ] External RM Documentation Electronic Calculation Data Files: N/A Method of Review: [ X ] Detailed [ ] Alternate [ ] Review of External Document This RM documentation supersedes: Rev. 0 in its entirety.

Prepared by: Alex H. Duvall / /

Print Sign Date Reviewed by: Gary W. Hayner / /

Print Sign Date Approved by: Edward T. Burns /

Print Sign Date Page 25 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 TABLE OF CONTENTS Section Page 1.0 PURPOSE & SCOPE 3 2.0 REQUESTED INFORMATION ON THE USE OF MAAP 3

3.0 REFERENCES

19 LS-MISC-025-R1 doc 2 Page 26 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Use of MAAP in Support of LS Response to EA-12-049 1.0 PURPOSE & SCOPE The purpose of the included information is to respond to NRC questions relating to the use of the Modular Accident Analysis Program (MAAP) Version 4 in support of the plant's response to NRC Order EA-12-049 [1], The MAAP analysis is documented separately in LS-MISC-017-R1.

2.0 REQUESTED INFORMATION ON THE USE OF MAAP In response to the letter of October 3, 2013 from Jack Davis (NRR) to Joe Pollock (NEI)

[2], the following responses have been developed regarding the use of MAAP4 for estimating accident progression timing in support of the Overall Integrated Plan (01P) for LaSalle.

2.1 NRC ITEM 1 Question 1 From the June 2013 position paper, benchmarks must be identified and discussed which demonstrate that MAAP4 is an appropriate code for the simulation of an ELAP event at your facility.

Response to Item 1:

The generic response provided by EPRI Technical Report 3002002749, "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4, A Guide to MAAP Thermal-Hydraulic Models" [6]

concludes that MAAP4 is an appropriate code for the simulation of an ELAP at this facility.

2.2 NRC ITEM 2 Question 2 The collapsed level must remain above Top of Active Fuel (TAF) and the cool down rate must be within Technical Specification limits.

LS-M ISC-025-R1 doc 3 Page 27 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of M,4,4P in Support of LS Response to EA-12-049 Response to Item 2:

Attachment 1A of the LaSalle Integrated Plan (Feb. 2013) states that the operators would commence a cooldown of the RPV at 20 min at a rate of 20°F/hr which is within the Technical Specifications limit of 100°F/hr. The following plot of the RPV pressure from the MAAP4 analysis confirms this cooldown rate for the supporting MAAP4 calculation was modeled correctly.

1200 1000 sm.

800 (7) ct.

a 600 8: 400 a.

200 5 10 15 20 TIME, HOURS MAAP Calculation of RPV Pressure During RPV Depressurization LS-MISC-025-R1.doc 4 Page 28 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 For the representative MAAP4 run (Case 3.e), the collapsed RPV water level inside the shroud remains above Top of Active Fuel (TAF) for the duration of the analysis. The plots below shows that the lowest RPV water level, calculated by MAAP4, is approximately 60" (5') below instrument zero. TAF is located at -161" (-13.42') relative to instrument zero. As shown in the following plots, the collapsed RPV water level remains at least 8' above TAF for the duration of the analysis.

MAAP Plot Template Case: LS_FLEX_CASE3e 60 t 50 Collapsed 71)

RPV Water (J)

Level U 40 a)

TAF (30 54')

30

.:. 20 cr Instrument Zero (43 96) u10 20 40 60 TIME, HOURS MAAP Calculation of Collapsed RPV Water Level Inside the Shroud From 0 to 72 Hours (1) Instrument zero is at +527.5" (43.96) above vessel zero LS-MISC-025-R1.cloc 5 Page 29 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 MAAP Plot Template Case: LS_FLEX_CASE3e 60 2

a) 50 Collapsed RPV Water (1)

Level

`) 40

.o TAF (30.54) 30 Tu 4.3 20 Instrument tis Zero (43 96')

a. 10 2 4 6 8 10 TIME, HOURS MAAP Calculation of Collapsed RPV Water Level Inside the Shroud From 0 to 10 Hours 2.3 NRC ITEM 3 Question 3 MAAP4 must be used in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.

Response to Item 3:

The MAAP4 analysis performed for LaSalle was carried out in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper, EPRI Technical Report 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" [3]. The requirements of each of these sections of the generic guideline (EPRI Technical Report 3002001785) are dispositioned below.

LS-MISC-025-R1.doc 6 Page 30 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 2.3.1 Compliance with Section 4.1 Section 4.1 of the EPRI report discusses documentation of the verification and validation of the MAAP 4.0.5 installation [3]. The MAAP 4.0.5 BWR output provided by EPRI with the MAAP 4.0.5 installation (run on VVindows XP) was compared to the computer running output files generated on the computer system (operating Windows 7) that is used for all MAAP4 calculations in the LaSalle MAAP ELAP analysis. The Peach Bottom sample Parameter File provided with the MAAP 4.0.5 software installation package (PEACH4.par) was used to accomplish this validation.

The Peach Bottom Parameter File was executed using the MAAP 4.0.5 code with the large loss of coolant (LLOCA1.inp) and station blackout (SBO1A1 .inp) scenario input files provided with the MAAP 4.0.5 software installation package The output files generated from these executions as part of local code installation are compared with the output files for the same scenarios that were provided by EPRI with the MAAP 4.0.5 installation (i.e., post-executed files). The input and output files generated during this installation validation process are not included with this report; however, key results of the EPRI files and the validation files are compared below.

The following is the comparison of the EPRI sample outputs with the same cases performed on the computer used for LaSalle calculations. As noted in Section 4.1 of the June 2013 Position Paper, validation of the MAAP installation is adequate for alternate computer and operating systems if the figures-of-merit at the end of the user-generated log file agree with the figures-of-merit from the log file provided with the MAAP installation are within certain tolerances [3].

LLOCA-LARGE LOSS OF COOLANT ACCIDENT The first EPRI test case is the LLOCA sequence (LLOCA1.inp) initiated with a double-ended recirculation line break (28" break area) at the bottom elevation of the downcomer/reactor pressure vessel penetration. This break drains the reactor coolant into the drywell. All RPV injection sources are assumed to be unavailable. The end time of the sequence is 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. The Table 2-1 provides a comparison of LLOCA LS-M ISC-025- R1 doc Page 31 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the implementation of FLEX August 28. 2014 Use of MAAP in Support of LS Response to EA-12-049 results between the Windows XP MAAP 4.0.5 output files provided with the MAAP 4.0.5 installation (LLOCA1.1og) and the output file generated using a Windows 7 computer. A comparison of results shows a valid installation of the software. The output results show slight but acceptable differences (i.e., within code tolerances) between the Windows XP run provided by EPRI and the VVindows 7 run performed as part of this installation assessment. This comparison confirms that there are no issues using Windows 7 to perform MAAP 4.0.5 calculations.

LS-MISC-025-R1 doc 8 Page 32 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 Table 2-1 PEACH BOTTOM (PEACH4) LLOCA COMPARISON Calculated Parameter Value PEACH4.par PEACH4.par MAAP 4.0.5 with MAAP 4.0.5 with Parameter Windows XP Windows 7 Time Core Uncovery 41.8 sec 41.8 sec Time of Core Temp >2499K 1381.4 sec 1382.1 sec Time of First Relocation to 5909.6 sec 5984.6 sec Lower Plenum Time of First Vessel Failure 12287.5 sec 11733.3 sec First Vessel Failure Mode, CRD tube ejection CRD tube ejection Node UO2 Mass in Pedestal 81514.9 kg 81518.9 kg UO2 Mass in Diywell 77057.9 kg 77054.4 kg Csl Mass in Containment 29.0203 kg 29.0786 kg Sr0 Mass in Corium 70.7301 kg 71.2745 kg Fraction of Zr Clad Reacted in 0.1988 0.2118 Vessel STATION BLACKOUT The second EPRI test case is the SBO sequence (SBO1A1 .inp) modeled as the loss of onsite and offsite AC power. Battery backed injection systems (i.e., HPCI and RCIC) are available for the life of the battery charge. The end time of the sequence is 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

The table below provides a comparison of the SBO results between the Windows XP MAAP 4.0.5 output file provided with the MAAP 4.0.5 installation (SBOlAl.log) and the output file generated using the Windows 7 computer. A comparison of results shows a valid installation of the software. The output results show slight but acceptable differences (i.e within code tolerances) between the Windows XP run provided by EPRI and the Windows 7 run performed as part of this installation assessment. This comparison confirms that there are no issues using Windows 7 to perform MAAP 4.0.5 calculations.

LS- M ISC-025-R1 doc 9 Page 33 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 Table 2-2 PEACH4 SBO COMPARISON Calculated Parameter Value PEACH4.par PEACH4.par MAAP 4.0.5 with MAAP 4.0.5 with Parameter Windows XP Windows 7 Time Core Uncovery 27783.3 sec 27783.3 sec Time of Core Temp >2499K 31246.7 sec 31246.7 sec Time of First Relocation to 46372.9 sec 46428.1 sec Lower Plenum Time of First Vessel Failure 47832.2 sec 47890.3 sec First Vessel Failure Mode, CRD tube ejection CRD tube ejection Node UO2 Mass in Pedestal 76008.7 kg 76331.9 kg UO2 Mass in Drywell 82589.3 kg 82265.8 kg Csl Mass in Containment 20.4359 kg 19.4627 kg Sr0 Mass in Corium 69.0067 kg 68.5566 kg Fraction of Zr Clad Reacted in 0.5031 0.5031 Vessel 2.3.2 Compliance with Section 4.Z This section discusses the testing requirements of the MAAP 4.0.5 Parameter File. Testing and review of the LaSalle MAAP 4.0.5 Parameter File is documented in Exelon Risk Management document LS-PSA-009, Rev. 2 [5], which concludes that the Parameter File has been adequately tested and reviewed.

2.3.3 Compliance with Section 4.3 This section discusses the preparation and confirmation requirements of MAAP 4.0.5 input files. The LaSalle MAAP FLEX analysis, LS-MISC-017, Rev. 1 [7], documents the creation of these input files in Section 6 and Attachment 1 and the results of the analysis output in Section 7 and Attachment 1.

LS-MISC-025-R1 doc 10 Page 34 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Use of MAAP in Support of LS Response to EA-12-049 2.3.4 cCoMDlidflICe With section 4,4 This section discusses the requirements for control of the analysis model files, the analysis documentation, and the review of the analysis. LS-MISC-017, Rev. 1, provides documentation of the analysis and was reviewed by Exelon qualified staff. The MAAP scenario input and output files are stored appropriately.

2.3.6 Compliance with Section 4.6 This section discusses the requirements of qualified individuals to perform the analysis.

Preparation and review of the MAAP analysis in LS-MISC-017, Rev. 1 was conducted using Exelon engineering training certification guide ENANRM08. All personnel responsible for the analysis are qualified in this certification guide.

2.4 NRC ITEM 4 Question 4 In using MAAP4, the licensee must identify and justify the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1020236) [4]. This should include response at a plant-specific level regarding specific coding options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant.

Although some suggested key phenomena are identified below, other parameters considered important in the simulation of the ELAP event by the vendor / licensee should also be included.

a. Nodalization
b. General two-phase flow modeling
c. Modeling of heat transfer and losses
d. Choked flow
e. Vent line pressure losses
f. Decay heat (fission products / actinides / etc.)

LS- M ISC-025-R1 doc 11 Page 35 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Use of MAAP in Support of LS Response to EA-12-049 Response to Item 4:

a. The reactor vessel nodalization is fixed by the MAAP code and cannot be altered by the user, with the exception of the detailed core nodalization.

The LaSalle MAAP 4.0.5 Parameter File divides the core region into 5 equal volume radial regions and 13 axial regions. The axial nodalization represents 10 equal-sized fueled nodes, 1 unfueled node at the top, and 2 unfueled nodes at the bottom. The LaSalle MAAP 4.0.5 Parameter File is documented in LS-PSA-009, Rev. 2 [5]. The figure below, taken from the MAAP Users Manual, illustrates the vessel nodalization scheme.

SRV LOCA 4 Upper Head 0

to 0 LOCA 3 Key StrandPIPes Separators O Gas Flow PRIM No.

Arf eat Sink 4-1 Surface No.

5 Opoer 0 Heat Sink Dawn-corner 0 e rA it zed 0

I 0 ied 3

4 C:) j (Row Path 8 1

Not Amicable tor 441*4114.0(34.1 GE BWR's)

LS-MISC-025-R1.doc 12 Page 36 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 Containment nodalization is defined by the user. The standard nodalization scheme is used in the LaSalle MAAP 4.0.5 Parameter File and represents the following individual compartments:

1. Upper Pedestal
2. Drywell
3. Suppression chamber (Wetwell)
4. Lower Pedestal The figure below illustrates the LaSalle containment nodalization along with an identification of containment flow junctions.

Junction Description 1 Upper Pedestal Door to Drywell Drywell Vent/failure 2 Drywell to Upper Pedestal Drains 3 Upper Pedestal Upper 13 Leakage Drain line Failure to Pedestal Lower Pedstal 4 Upper Pedestal to Lower Pedestal Corium Junction 5 Downcomers 7,8,9,10 5 6 Lower Pedestal to Wetwell Opening Wetwell Vent/failure 7,8,940 Vacuum Breakers 11 Drywell vent/failure 12 Wetwell Lower vent/failure Pedestal 13 Drywell leakage LS-MISC-025-R1 doc 13 Page 37 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049

b. General two-phase flow from the reactor vessel is described in the EPRI Technical Report 3002002749, Section 2 [6]. In the case of the scenario outlined in the integrated plan, flow can exit the RPV via the open SRV(s) and from the assumed recirculation pump seal leakage. Flow from the SRV(s) will be single-phase steam and flow from the recirc pump seal or other RPV leakage will be single-phase liquid due to the location of the break low in the RPV with RPV level maintained above TAF. Upon exiting the RPV, the seal leakage will flash a portion of the flow to steam based on saturated conditions in the drywell, creating a steam source and a liquid water source to the drywell. As described in the EPRI Technical Report 3002002749, "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4 A Guide to MAAP Thermal-Hydraulic Models", Section 2, [6]

there are two MAAP parameters that can influence the two-phase level in the RPV FCO (void concentration factor) and FCHTUR (churn-turbulent critical velocity coefficient). The following table confirms that the parameter values match the recommended values as outlined in the EPRI Technical Report 3002002749, Section 3. The LaSalle MAAP 4.0.5 Parameter File is documented in LS-PSA-009, Rev. 2 [5].

VALUE USED IN THE EPRI PARAMETER NAME LASALLE MAAP ANALYSIS RECOMMENDED VALUE FCO 1.5248 1.5248 FCHTUR 1.53 1.53

c. Modeling of heat transfer and losses from the RPV are described in Section 2 of the EPRI Technical Report 3002002749 [6]. The MAAP parameters that control these processes, as defined in the EPRI report, are provided below with the values selected to represent LaSalle.

LS-PSA-009, Rev. 2, documents the LaSalle MAAP 4.0.5 Parameter File [5].

VALUE USED IN THE PARAMETER NAME LASALLE MAAP ANALYSIS COMMENT 000 not-thru-insulation 3.753E6 BTU/hr Plant specific value based on drywell heat heat transfer from RPV removal to coolers during normal during normal operation. operation. Typical values range between 1-2 MW (3.4E6 to 6.8E6 BTU/hr).

FINPLT number of plates 10.0 Plant-specific value in reflective insulation XTINS average reflective 0.2917 ft Plant-specific value insulation thickness LS-MISC-025-R1 doc 14 Page 38 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 At the request of the NRC, the following information, as used in the MAAP analysis, is provided.

PARAMETER VALUE USED IN THE PARAMETER DEFINITION NAME IN MAAP LASALLE MAAP ANALYSIS Power level, MWth CORD 3546 MWth Initial CST water volume, gal VCSTO (ft) 262,482.2 ft2 Initial CST water temperature, F HOST (enthalpy) 95'F Initial suppression pool water mass, lbm Calculated from input 8,119,000 Ibm Initial suppression pool water level, ft KA/RBO(i), where i is node 26,5 ft number for wetwell Initial suppression pool water TWRBO(i), where i is node 105.0'F temperature, F number for wetwell Drywell free volume, ft3 VOLRB(i), where I is node 220,402.4 ft3 number for drywell VVetwell free volume, ft3 VOLRB(i) volume of 295757.0 ft3 suppression pool water from initial pool mass Containment vent pressure, psia Refer to MAAP analysis 26.32 psia document RCIC max flow rate, gpm WVRCIC 625 gpm Max FLEX pump flow rate, gpm Refer to MAAP analysis 300 gpm document Lowest set SRV flow rate, lb/hr Derived from SRV area, 862,400 ASRV Lowest set SRV pressure, psia PSETRV 1090.7 Recirc pump seal leakage, gpm Value that was used to define 36 LOCA area, ALOCA (18 gpm per pump)

Total leakage used in the transient, gpm Value that was used to define 100 LOCA area, ALOCA d Choked flow from the SRV and the recirculation pump seal leakage (as break flow) is discussed in the EPRI Technical Report 3002002749 in Section 4 and Section 2, respectively [6]. The parameters identified that impact the flow calculation are listed below with input values identified. LS-PSA-009, Rev. 2, documents the LaSalle MAAP 4.0.5 Parameter File [5].

VALUE USED IN THE EPRI PARAMETER NAME LASALLE MAAP ANALYSIS RECOMMENDED VALUE ASRV effective flow area for 0.0927 ft2 Plant-specific value relief valve (based on rated flow at pressure)

ALOCA seal leakage area 1.55E-3 ft2 Plant-specific value (100 gpm at normal conditions)

FCDBRK discharge coefficient 0 75 0.75 for seal leakage LS-MISC-025-R1 doc 15 Page 39 of 43

LaSalle County Station, Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Use of MAAP in Support of LS Response to EA-12-049

e. Containment vent line pressure loss can be represented in two ways.

The actual piping flow area can be input along with a discharge coefficient (FCDJ). An alternative method would be to calculate the effective flow are given the estimated piping losses, and input a loss coefficient of 1.0. For the LaSalle analysis, the vent area is input based on a 10" diameter pipe and a discharge coefficient of 0.75 was selected. For this vent flow, MAAP assumes a compressible, adiabatic, critical flow between containment and the environment. This flow is only adjusted for pressure loss using the discharge coefficient (i.e., the physical losses from piping and pipe components are not independently considered, rather the effects are averaged as the discharge coefficient). The vent is assumed to cycle in the open and close states via operator actions to maintain wetwell pressure between 5 and 8 psig.

f. The decay heat calculation in MAAP is discussed in the EPRI Technical Report 3002002749, Section 2 [6]. Input parameters used to compute the decay heat are identified in the EPRI report and are listed in the following table along with their values used in the LaSalle analysis. LS-PSA-009, Rev. 2, documents the LaSalle MAAP 4.0.5 Parameter File [5].

VALUE USED IN THE EPRI PARAMETER NAME LASALLE MAAP ANALYSIS RECOMMENDED VALUE FENRCH normal fuel enrichment 0.0381 Plant-specific value EXPO average exposure 29,549.6 MW-day/ton Plant-specific value FOR total capture rate of U-238 I 0.323 Plant-specific value total absorption rate FFAF total absorption rate / total 2.30 Plant-specific value fission rate FQFR1 fraction of fission power 0.510 Plant-specific value due to U-235 and PU-241 FQFR2 fraction of fission power 0.405 Plant-specific value due to PU-239 FQFR3 fraction of fission power 0.085 Plant-specific value due to U-238 TIRRAD average effective 26,280 hours0.00324 days <br />0.0778 hours <br />4.62963e-4 weeks <br />1.0654e-4 months <br /> Plant-specific value irradiation time for entire core LS-MISC-025-R1 doc 16 Page 40 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 2.5 NRC ITEM 6 Question 6 The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in the integrated plan must be identified and should be available on the ePortal for NRC staff to view. Alternately, a comparable level of information may be included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down to confirm that the cool down is within Technical Specification limits.

Response to Item 5:

The MAAP analysis performed in support of the LaSalle 01P is documented in calculation LS-MISC-017 Rev. 1 [7] and is available on the ePortal Case 3e was the specific MAAP run selected to represent the scenario as described in Attachment 1A of the integrated plan.

2.6 ADDITIONAL ITEMS Additionally, this document responds to the following question:

Additional Question (Question 6)

Confirm adequacy of the technical basis for the assumptions made regarding the leakage rate through the recirculation pump seals and other sources. The analysis should include the assumed pressure-dependence of the leakage rate, and whether the leakage was determined or assumed to be single-phase liquid, two-phase mixture, or steam at the donor cell, and how mixing the leakage flow with the drywell atmosphere is modeled.

LS-MISC-025-R1 doc 17 Page 41 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049 Response to Item 6:

Leakage is estimated for LaSalle to be 18 gpm of recirculation pump seal leakage per pump (36 gpm total) in addition to 25 gpm to account for additional primary system leakage (61 gpm total) per Table 15.9-1 of the LaSalle UFSAR. This estimated leakage rate is conservatively modeled to be 100 gpm and is assumed to initiate at t = 30 minutes relative to accident initiation. This leakage is modeled in MAAP4 using a fixed junction flow area that achieves a total of 100 gpm leakage at full operating pressure and temperature. As the RPV is depressurized, leakage will decrease because the leakage flow rate is dependent on upstream pressure. Although actual recirculation pump seal leakage may initiate much later following transient initiation (e.g., an hour or more), this modeling approach is a reasonable upper bound representation of actual recirculation pump seal leakage.

General two-phase flow from the reactor vessel is described in Section 2 of EPRI Technical Report 3002002749 [6]. The location of the modeled leakage in the MAAP4 analysis is approximately at the elevation of the recirculation pump seals and hence is expected to be a single-phase liquid in the donor cell for the scenarios examined.

However, MAAP calculates the conditions in the donor cell each timestep. Based on these conditions, as well as the flow characteristics and downstream node conditions, MAAP4 will determine if the leakage flashes into steam or is released as a single-phase liquid. MAAP4 assumes homogenous mixing in the drywell and adds the discharged mass and energy to the appropriate phases in the downstream node.

LS-M ISC-025-R1 doc 18 Page 42 of 43

LaSalle County Station. Units 1 and 2 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Use of MAAP in Support of LS Response to EA-12-049

3.0 REFERENCES

[1] NRC EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (BDBEE), March 2012.

[2] Jack R. Davis (NRR) to Joseph E. Pollock (NEI), U.S. Nuclear Regulatory Commission, ADAMS Accession No.: ML13275A318, October 3, 2013.

[3] "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications," EPRI, Palo Alto, CA: 2013. 3002001785.

[4] MAAP4 Application Guidance. EPRI, Palo Alto, CA: 2010. 1020236.

[5] LS-PSA-009, LaSalle MAAP 4.0.5 Parameter File Notebook, Rev. 2.

[6] Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4, A Guide to MAAP Thermal-Hydraulic Models. EPRI, Palo Alto, CA: 2010. 3002002749.

[7] LaSalle MAAP Analysis to Support Initial FLEX Strategy, LS-MISC-017, Rev. 1.

LS-M ISC-025-R1.doc 19 Page 43 of 43